Document V9no1bo9B50w4VQoe520ZwxZ

FILE NAME: Kaiser Gypsum (KG) DATE: 1996 DOC#: KG047 DOCUMENT DESCRIPTION: Legal - Updated Responses to Interrogatories PATRICK J. HAGAN, E5Q. (State Bar #68264) 1 R. JANE WELLS, ESQ. (State Bar #112178) 2 DILLINGHAM & MURPHY 225 Bush Street, Sixth Floor 3 San Francisco, CA 94104-4207 (415) 397-2700 5 Attorneys for Defendant KATSER GYPSUM COMPANY, INC. 6 '' 7 SUPERIOR COURT FOR THE STATE OF CALIFORNIA 8 FOR THE COUNTY OF SAN FRANCISCO . 9 10 IN RE: SAN FRANCISCO COUNTY 11 COMPLEX ASBESTOS LITIGATION 12 13 14 CASE NO. 828684 . KAISER GYPSUM COMPANY, INC.'S UPDATED RESPONSES TO PLAINTIFFS' STANDARD INTERROGATORIES TO DEFENDANTS 15 PROPOUNDING PARTY 16 RESPONDING PARTY 17 5 -. : Plaintiffs : Defendant Kaiser Gypsum Company, Inc. : Standard 18 q j -'t : December 30, 1996 19 COMES NOW defendant Kaiser Gypsum Company, Inc. (hereinafter 20 "Kaiser Gypsum"), and provides the following updated responses to 21 ^'aintiffs' standard interrogatories propounded pursuant to San 22 Francisco County Complex Asbestos Litigation General Order No. 29: 23 KAISER GYPSUM'S PRELIMINARY STATEMENT AND OBJECTIONS 24 Kaiser Gypsum was constituted in 1952 and has been 25 headquartered in California since that date. Kaiser Gypsum 26 disposed of its last operating manufacturing plant in August 1978 27 and subsequently has not engaged in manufacturing or product sales 28 anywhere in the United States. Thus, all Kaiser Gypsum product sales occurred between 1952 and 1978. Therefore, Kaiser Gypsum's responses to plaintiffs' standard interrogatories are based almost entirely on its ongoing review of documents presently available to the These updated interrogatory responses reflect Kaiser Gypsum's knowledge at this time and supersede any previous interrogatory answers. Kaiser Gypsum reserves the right to further supplement these responses in the event that more complete or accurate information becomes available. Kaiser Gypsum notes that these responses are made without reference to the factual circumstances of any particular case, and, accordingly, Kaiser Gypsum reserves the right to si_ate additional objections or provide supplemental responses that might be appropriate in the specific context of a given plaintirf's claim(s). . Kaiser GyDSum objects to requests for information that are unlimited as to geographical scope on the grounds that such reauests are unduly burdensome and are not reasonably calculated to lead to the discovery of evidence admissible in cases that are subject to General Order No. 29. Accordingly, Kaiser Gypsum's present resDonses hereto are limited to products sold and ooerations conducted within the State of California. ,, Kaiser Gypsum objects to these interrogatories to the extent that they call for information protected by the attorney/client Drivilege or work product doctrine. This Preliminary Statement and the objections contained herein are incorporated into each of the responses set forth below. / / / KAISER GYPSUM'S RESPONSES TO INTERROGATORIES RESPONSE TO INTERROGATORY NO. 1: (a) Joseph R. Hobby. (b) 2680 Bishop Drive, Suite 225, San Ramon, 94583. (c) Vice President. (d) 1 2 /1 /95-present: Vice President RESPONSE TO INTERROGATORY NO. 2: Kaiser Gypsum is a corporation. (a) Its full and correct corporate name is Kaiser Gypsum Company, Inc. (b) Kaiser Gypsum is incorporated under the laws of the State of Washington. (c) Kaiser Gypsum was organized in 1952 through a somewhat complicated process. Specifically, on June 19, 1952, Permanente Cement Company (new known as Kaiser Cement Corporation) formed a wholly owned subsidiary named Kaiser Gypsum Company, a California Corporation. On August 1, 1952 Kaiser Gypsum Company purchased from the Henry J. Kaiser Company two gypsum wallboard plants located at Long Beach and Redwood City, California. On December 1, 1952, Kaiser Gypsum Company was merged into Pacific Coast Cement Company, another subsidiary of Permanente Cement Company, with Pacific Coast Cement Company, a Washington Corporation, which at the time of the merger had no assets or operations and which was incorporated on November 28, 1927, being the survivor. The name of the combined company was then changed to Kaiser Gypsum Company, Inc. 1 (d) Kaiser Gypsum's principal place of business is located 2 at 3000 Busch Read, Pleasanton, California 94566. 3 (e) Kaiser Gypsum has held a certificate of authority to do 4 business in California from 1952 to the present. 5 (f) Kaiser Gypsum's California "registered agent" is CT 6 Corporation, 818 West Seventh Street, Los Angeles, CA 90017. 7 (g) Kaiser Gypsum is a wholly owned subsidiary of Kaiser 8 Cement Corporation, whose principal place of business is located 9 at 3000 Busch Road, Pleasanton, California 94566. 10 RESPONSE TO INTERROGATORY NO. 3: 11 . Yes. See the history of Kaiser Gypsum's formation in 1952 12 that is provided in its answer to Interrogatory 2(c) above. 13 RESPONSE TO INTERROGATORY NO . 4: 14 (a) No. 15 (b) Not applicable. 16 (c) Not applicable. ]_7 RESPONSE TO INTERROGATORY NO. 5: 18 No. ` 19 RESPONSE TO INTERROGATORY NO. 6: 20 (a) Kaiser Gypsum's corporate records are located at its 21 headquarters, whose address is 3000 Busch Road, Pleasanton, 22 California 94566; at 2680 Bishop Drive, San Ramon, CA 94583; and 23 at a commercial storage site or sites located in the greater San 24 Francisco area. 25 (b) Joseph R. Hobby, Vice President, 2680 Bishop Drive, San 26 Ramon, California. 27 RESPONSE TO INTERROGATORY NO. 7: 28 (a) through (h): No. 1 RESPONSE TO INTERROGATORY NO. 8: 2 (a) See response to 8 (e) and 3(g) 3 (b) No. 4 (c) See response to 8 (e) and 8(g) . 5 (d) See response to 8 (e) and 8(g) - 6 (e) Yes. 1953 to 1976. 7 (f) See response to 8 (e and 8(g) 8 (g) Yes. 1953 to 1976. 9 RESPONSE TO INTERROGATORY NO. 9: 10 Not applicable. 11 RESPONSE TO INTERROGATORY NO. 10: 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 I. Kaiser Gypsum's Business: Gypsum Plaster, Gyps'TM Lath, and Gypsum Wallboard - No Asbestos Used Kaiser Gypsum was organized by Henry J;. Kaiser (1882-1967), the famous industrialist and World War II hero, in 1952 and terminated its United States sales and manufacturing in 1978. Between 1952 and 1978, Kaiser Gypsum's principal business consisted of manufacturing and marketing gypsum plaster, gypsum lath and gypsum wallboard. The word "gypsum" is derived from the Greek word "gypso," meaning chalk. "Gypsum" is hydrous calcium sulfate. Gypsum plaster is sometimes called Plaster of Paris, because gyDSum.plaster was widely used in the capital of France during the 19th century. Gypsum occurs in nature in rock form, and is found in abundance in Baja California, Mexico. A. Gypsum Plaster Products During Kaiser Gypsum's first years in business, most houses and many other buildings had interior walls that were made with plaster. The plaster products sold by Kaiser Gypsum were 1 essentially finely-ground gypsum rock packaged in bags. Such 2 gypsum plaster products were mixed with water and an aggregate 3 (most commonly sand) at the construction site to form a paste. 4 The paste was applied by hand and smoothed with a trowel to form a 5 wall or ceiling surface. Sometimes several layers of plaster were 6 used, with the underneath layers being brown in color and the 7 surface layer being white. When dried, the plaster became quite 8 hard. A plaster wall or ceiling typically was' finished by 9 painting the plaster surface or covering- it with wallpaper. 10 Kaiser Gypsum's plaster products designed for the above 11' construction uses included Hardwall Plaster, Fibered Hardwall 12 Plaster, Dual Purpose Fibered Hardwall Plaster, Dual Purpose 13 LJnfibered Hardwall Plaster, Wood Fibered Hardwall Plaster, Slow 14 Set Gauging Plaster, and Quick Set Gauging Plaster. They also 15 included plaster products for casting (e.g., making ornaments or 16 statues including Casting Plaster and Slow Set Casting Plaster). 17 Kaiser Gypsum also manufactured Plaster Retarder and Structural 18 Gypsum (Pre-Mixed Gypsum Concrete).' Kaiser Gypsum plaster 19 products also included Red-E-Mix plaster, a pre-mixed product 20 which combined plaster and aggregate, that was introduced in 1956. 21 Gun Plaster, introduced in 1957, was applied by mixing the sacked 22 product on the job site in special portable mixing machines, and 23 it was then pumped through a large diameter hose to the inside of 24 a building where it was sprayed by plasterers onto walls, with 25 comparative speed and economy. Kaiser Gypsum never used asbestos 26 as a component in any of those products. J 27 28 B. Gypsum Lath Products The surface to which gypsum plaster was applied was called "lath." Lath was sometimes made of wire, but lath also could be made of hard, paper covered sheets of gypsum plaster (called gypsum stucco), sometimes made with holes in them. The lath sheets would be affixed to the interior wall framing, and plaster would then be applied to the lath. The holes in the lath would help keep the plaster in place while it dried. Kaiser Gypsum made gypsum lath of this type. Kaiser Gypsum lath products included Plain Lath and Perforated Lath, Foil-Back Insulating Lath, Duralath, Gypsum Veneer Base, and Kaiserwall. Kaiser Gypsum never used asbestos as a component in any of those products. C . Gypsum Wallboard Products - In years following the Korean War, there were numerous innovations in housing construction, including many changes intended to lower housing construction costs. One such change was the substitution of gypsum wallboard, or drywall, for plaster. Gypsum wallboard, like gypsum lath, is.basically a hard sheet of gypsum plaster that is affixed to the wall framing. Typically i gypsum wallboard would be made in pieces that were 4 feet wide and 8 feet long. They typically were 1/2 inch or 5/8 inch thick. During the manufacturing process, the wallboard's core of gypsum plaster was covered by a special paper that could be painted or covered with wallpaper. Because more walls, partitions or ceilings could be made using gypsum wallboard in a given period of time than could be made by plastering over lath, constructing houses, apartments and other buildings with wallboard was less expensive. Over time, as 1 building codes were amended to permit use of gypsum wallboard, 2 more construction of interior Walls, partitions and ceilings was 3 done using wallboard and less using plaster. Reflecting this 4 trend, Kaiser Gypsum's business focused more on gypsum wallboard 5 as time passed. By 1960 about half of the construction in 6 California used wallboard and half still used plaster. Plaster use 7 continued to decline, and by the early 1970's substantially all of 8 the market demand was for gypsum wallboard. Kaiser Gypsum never 9 used asbestos as a component in any of its gypsum wallboard 10 products. 11 D . Non-Asbestos Products Exceeded 90% Of Total Sales 12 The bulk of Kaiser Gypsum's sales has always consisted of 13 products that did not use asbestos as a component. To illustrate, 14 the following chart shows sales totals in dollars for the years 15 1969-1975, the last full year prior to the complete cessation of 16 the use of asbestos as a component in Kaiser Gypsum products: 17 Year Non-Asbestos Non-Asbestos Product Products Total Sales Percentage Of Total 18 1969 $41,360,000 $43,299,00-0 96% 19 1970 $37,258,000 $39,457,000 94% 20 1971 $48,403,000 $51,671,000 94% 1972 $58,468,000 $63,056,000 931 21 1973 $65,803,000 $71,382,000 92% 22 1974 $64,996,000 $70,139,000 93% 23 1975 $41,318,000 $43,935,000 94% 24 As these figures illustrate, Kaiser Gypsum's sales of non 25 asbestos-containing products always were substantially more than 26 90% of its business. 27 28 1 I I . Accessories For Use With Gyps-urn Wallboard 2 A. Nails, Wall And Door Frames, Cornerbead, 3 Paper Products - No Asbestos Used_____ 4 With the expansion of its gypsum wallboard business, Kaiser 5 Gypsum also began selling other products needed i_o construct 6 interior walls, partitions or ceilings using gypsum wallboard. 7 These included special nails and other devices used to attach 8 wallboard to the supporting frame. They also included metal wall 9 or partition frames especially made for installing wallboard, 10 metal "cornerbead" used to make partition corners hard, and metal 11 doorframes for use in walls made using gypsum wallboard. Partly 12 to ensure that it could get access to adequate amounts of the 13 special paper used to make wallboard (by covering its gypsum 14 plaster core), Kaiser Gypsum acquired paper plants, where it also 15 manufactured commercial paper products such as cardboard boxes. 16 Gyosum .never used asbestos as a component in any of thosa 17 products. 18 B. Wallboard Joint Compounds - Asbestos Used As A Component . 19 When the walls or ceilings of a room are made from gypsum 20 wallboard, large pieces of wallboard are installed side by side, 21 leaving small spaces where two pieces of wallboard meet. These 22 spaces need to be filled so that they cannot be seen afi-er the 23 wall is painted or covered with wallpaper. The products used to 24 perform that task are called joint compounds or joint finishing 25 compounds. At the time of use, these joint compounds are thick 26 putty or mud-like substances, which permits them to be pushed into 27 the spaces and smoothed with a putty knife or spatula. Paper or 28 cloth reinforcing tape is pushed into the joint compound to help prevent cracking as the joint compound dries. The joint compound dries to form a hard rock-like substance. Kaiser Gypsum manufactured and marketed such wallboard joint compounds, and prior to the mid-1970's, these joint compounds contained a small percentage of chrysotile asbestos as a component. The purpose of the chrysotile asbestos component was to prevent cracks from forming as the joint -compound dried. "Asbestos" is the Greek word for "incombustible," 'which refers to things that will not burn. Chrysotile is the most common type of asbestos used in products in the United States. Chrysotile is a fibrous rock material derived from the rock "serpentine" which is very common in California, where it is the "state rock.' These Kaiser Gypsum products were: ; 1. Joint Cement/Joint Compound 2. Finishing (Topping) Compound 3. - 3-Purpose Wallboard Compound . 4. One-Day Joint Compound 5. Pre-mix Joint Compound 6. Pre-mix Finishing Compound 7. Pre-mix Dual Purpose Joint Compound 8. Pre-mix Topping Compound 9. Laminating Compound : Kaiser Gypsum's separate responses to interrogatory subparts (a)-(f) for each of these- products are as follows: 1. Joint Cement/Joint Compound (a) The trade name of this product originally was Kaiser joint Cement; about 1957 it was changed to Kaiser Joint Compound. (b) Kaiser Gypsum marketed Kaiser Joint Cement in 1952, but did not manufacture the product itself. Kaiser Gypsum does not know whether the product marketed in 1952 contained asbestos as a 1 component. Kaiser Gypsum began manufacturing Kaiser Joint Cement 2 in 1953, at which time chrysotile asbestos was used as a 3 component. 4 (c) Kaiser Gypsum last manufactured Kaiser Joint Compound 5 with chrysotile asbestos as a component in 1975. 6 (d) The Kaiser Gypsum California plants that made this 7 product were located at Redwood City and Antioch. These plants 8 were in operation at different times. The product was 9 manufactured at Redwood City from 1953 through 1957 and at Antioch 10 from 1957 to 1975. -Because of the heavy weight of the product, 1 1 low profit margin and high transportation costs, distribution 12 tended to center around the location of the manufacturing plant. 13 The product consisted primarily of minerals including casein or 14 polyvinyl, clay, talc, limestone and mica. The product 15 manufactured in Kaiser Gypsum's California plants included between 16 8% by weight and 16% by weight chrysotile asbestos as a component 17 decending on the formula in effect at a given date. 18 (e) This product was a white to off-white powder. It was 19 packaged and sold in sacks of 10 to 25 lbs. and in boxes of 5 and 20 18 lbs. Each container was labeled with the name of the 21 manufacturer, Kaiser Gypsum Company, Inc., the name of the product 22 and directions for its use. 23 (f) This product was a dry powder which, when mixed with 24 water, formed a thick paste. Upon application it dried to a hard, 25 durable surface. It was used to fill gypsum wallboard joints, 26 embed joint reinforcing tape, finish joints and to cover and 27 finish nail heads and metal cornerbead. 28 1 2. Finishing (Topping) Compound O. (a) The trade name of this product was Kaiser Gypsum 3 Finishing (topping) Compound. 4 (b) Kaiser Gypsum began manufacturing finishing (topping) 5 compound in 1955, and chrysotile asbestos was used as a component 6 at that time. 7 (c) Kaiser Gypsum last manufactured finishing (topping) 8 compound with chrysotile asbestos as a component in 1975. 9 (d) The Kaiser Gypsum California plants that made this 10 product were located at Redwood City and Antioch. These plants 11 were in operation at different times. The product was 12 manufactured at Redwood City from 1955 to 1957 and at the Antioch 13 plant from 1957 to 1975. Because of the heavy weight of the 14 product, low profit margin and high transportation costs, 15 distribution tended.to center around the location of the 16 manufacturing plant. This product consisted primarily of minerals 17 including casein or polyvinyl, clay, talc, limestone and mica. 18 The product included between 5.3% by weight and 16% by weight 19 chrvsotile asbestos as a component depending on the formula in 20 effect at a given time. 21 (e) This product was a white to off-white powder. It was 22 packaged and sold in sacks of 25 lbs. Each container was labeled 23 with the name of the manufacturer, Kaiser Gypsum Company, Inc., 24 the name of the product and instructions for its use. 25 (f) This product was a dry powder which, when mixed with 26 water, formed a thick paste. Upon application it dried to a hard, 27 durable surface. It was used to top and finish gypsum wallboard 28 joints. 1 3 . 3-Purpose Wallboard Compound 2 (a) The trade name of this product was Kaiser Gypsum 3- I Purpose Wallboard Compound. 4 (b) Kaiser Gypsum began manufacturing 3-Purpose Wallboard 5 Compound in 1968, and chrysotile asbestos was used as a component 6 at that time. 1 (C) Kaiser Gypsum last manufactured 3-Purpose Wallboard 3 Compound with chrysotile asbestos as a component in 1976. 9 (d) The Kaiser Gypsum California plant that made this lOj I product was located at Antioch. Because of the h--avy weighu of 11 the product, low profit margin and high transportation costs, 12 distribution tended to center around the location of phe 13 manufacturing plant. This product consisted primarily of minerals 14 I including casein or polyvinyl, clay, talc, limestone and mica. 15 The product included between 5.1% by weight and 14.2^ by weight 16 chrysotile asbestos as a component. 17 (e) The product was a white to off-white powder. It was 18 packaged and sold in sacks of 25 lbs. .Each sack was labeled with 19 the name of the manufacturer, Kaiser Gypsum Company, Inc., the 20 name of the product and directions for its use. (f) This product was a dry powder which, when mixed with 22 water, formed a thick paste. Upon application it dried to a hard, durable surface. It was used to tape, top and finish gypsum wallboard joints, nailheads and metal cornerbead. 4 . One-Day Joint Compound (a) The trade name of this product was Kaiser Gypsum One-Day 27 Joint Compound Powder. 1 (b) Kaiser Gypsum began manufacturing One Day Joint Compound 2 Powder in 1968, and chrysotile asbestos was used as a component at 3 that time. 4 (c) Kaiser Gypsum last manufactured One Day Joint Compound 5 Powder with chrysotile asbestos as a component in 1975. 6 (d) The Kaiser Gypsum California plants that made this 7 product were located at Santa Ana and Antioch. Because of the =8 heavy weight of the product, low profit margin and high 9 transportation costs, distribution tended to center around the 10 location of the manufacturing plant. The product consisted 11 primarily of casein-limestone and mica. The product included 12 3.4% by weight chrysotile asbestos as a component. 13 (e) This product was a white to off-white powder. It was 14 packaged and sold in sacks of 25 lbs. Each sack was labeled with 15 the name of the manufacturer, Kaiser Gypsum Company, Inc., the 16 name of the product and directions for its use. .17 (f) This product was a dry powder which, when mixed with 18 water, formed a thick paste. Upon application it dried to a hard, 19 durable surface. It was used to fill gypsum wallboard joints, 20 embed joint reinforcing tape, finish joints and to cover and 21 finish nailhead and metal cornerbead. 22 5. Pre-Mix Joint Compound 23 (a) The trade name of this product was Kaiser Gypsum Pre-Mix 24 Joint Compound. 25 (b) Kaiser Gypsum began manufacturing Pre-Mix Joint Compound 26 in 1959, and chrysotile asbestos was used as a component at that 27 time. 28 1 (c) Kaiser Gypsum last manufactured Pre-Mix Joint Compound 2 with chrysotile asbestos as a component in 1962. 3 (d) The Kaiser Gypsum California plant that made this 4 product was located at Long Beach. Because of the heavy weight of 5 the product, low profit margin and high transportation cost, 6 distribution tended to center around the location of the 7 manufacturing plant. This product consisted primarily of minerals 8 including casein or polyvinyl, clay, talc,-limestone and mica. 9 The product included chrysotile asbestos as a component. The 10 percentage presently is unknown. Investigation is continuing. 11 (e) This product was a white to off-white colored paste. It 12 was packaged and sold in cans of 4 or 5 gallons and in cartons of 13 5 gallons. Each container was labeled with the name of the 14 manufacturer, Kaiser Gypsum Company, Inc.,:the name of the product 15 and directions for its use. 16 (f) This product was a thick paste like material which upon 17 application dried to a hard, durable surface. It was used to fill 18 gypsum walibcard joints, embed joint reinforcing tape, finish 19 joints and to cover and finish nailheads and cornerbead. 20 6 . Pre-Mix Finishing Compound 21 (a) The trade name of this product was Kaiser Gypsum Pre-Mix 22 Finishing Compound. 23 (b) Kaiser Gypsum began manufacturing Pre-Mix Finishing 24 Compound in 1959, and chrysotile asbestos was used as a component 25 at that time. 26 (c) Kaiser Gypsum last manufactured Pre-Mix Finishing 27 Compound with chrysotile asbestos as a component in 1962. _ 28 1 (d) The Kaiser Gypsum California plant that made this 2 product was located at Long Beach. Because of the heavy weight of 3 the product, low profit margin and high transportation cost, 4 distribution tended to center around the location of the 5 manufacturing plant. This product consisted primarily of minerals 6 including casein or polyvinyl, clay, talc, limestone and mica. 7 The product included chrysotile asbestos as a component. The 8 percentage presently is unknown. InvestigatrTbh is continuing. 9 (e) This product was a white to off-white colored paste. It 10 was packaged and sold in cans of 4 or 5 gallons and in cartons of 11 - 5 gallons. Each container was labeled with the name of the 12 manufacturer, Kaiser Gypsum Company, Inc., the name of the produce 13 and directions for its use. 14 (f) This product was a thick paste like material which upon 15 application dried to a hard, durable surface. It was used to 16 finish gypsum wallboard joints and to cover and finish nailheads 17 and ccrnerbead. 18 7. Pre-Mix Dual Purpose Joint Compound 19 (a) The trade name of this product was Kaiser Gypsum Pre-Mix 20 Dual Purpose Joint Compound. 21 (b) Kaiser Gypsum began manufacturing Pre-Mix Dual Purpose 22 Joint Compound in 1960, and chrysotile asbestos was used as a 23 component at that time. 24 (c) Kaiser Gypsum last manufactured Pre-Mix Dual Purpose 25 Joint Compound with chrysotile asbestos as a component in 1975. 26 (d) The Kaiser Gypsum California plants that made this 27 product were located at Long Beach, Antioch and Santa Ana. 28 Because of the heavy weight of the product, low profit margin and i 1 high transportation costs, distribution tended to center around 2 the location of the manufacturing plant. This product consisted 3 primarily of minerals including polyvinyl, clay, talc, limestone 4 and mica. The product included between 1.5% by weight and 6% by 5 weight chrysotile asbestos as a component depending on the formula 6 in effect at a given date. 7 (e) This product was a white to off-white or light buff 8 colored paste. It was packaged and sold in 5 gallon metal cans or 9 plastic pails, and 4 or 5 gallon cartons. Beginning in 1966 small 10 amounts were sold in 5 quart plastic buckets as an accommodation 11 product for lumber dealers under the name 3-purpose premix 12 compound. Each container was labeled with the name of the 13 manufacturer, Kaiser Gypsum Company, Inc., the name of the product 14 and directions for its use. 15 (f) This product was a thick paste like material which upon 16 application dried to a hard, durable surface. It was used to 17 finish gypsum wallboard joints, embed joint reinforcing tape, 18 finish joints and to cover and finish nailheads and metal 19 cornerbead. 20 8. Pre-Mix Topping Compound 21 (a) The trade name of this product was Kaiser Gypsum Pre-Mix 22 Topping Compound. 23 (b) Kaiser Gypsum began manufacturing Pre-Mix Topping 24 Compound in 1968, and chrysotile asbestos was used as a component 25 at that time. 26 (c) Kaiser Gypsum last manufactured Pre-Mix Topping Compound 27 with chrysotile asbestos as a component in 1976. 28 (d) The Kaiser Gypsum California plants that made this product were located at Santa Ana and Antioch. Because of the heavy weight of the product, low profit margin and high ^j^ansDortation costs, distribution tended to center around the location of the manufacturing plant. This product consisted primarily of minerals including casein or polyvinyl, clay, talc, limestone and mica. The product included between 0.9% by weight and 2% by weight chrysotile asbestos as a component depending on the formula in effect at a- given date. (e) This product was a white to off-white or light bufr colored paste. It was packaged and sold in metal and plastic buckets of 4 or 5 gallons and in cartons of 4 gallons^ Each container was labeled with the name of the manufacturer, Kaiser Gypsum Company, Inc., the name of the product and directions for its use. (f7) This product was a thick paste like material which upon application dried to a hard, durable surface. It was used to top and finish gypsum wallboard joints. 9. Laminating Compound (a) The trade name of this product was Kaiser Gypsum Laminating Compound. (b) Kaiser Gypsum began manufacturing Laminating Compound in 1961, at which time chrysotile asbestos was used as a component. (c) Kaiser Gypsum last manufactured Kaiser Gypsum Laminating Compound with chrysotile asbestos as a component in 1972, at which time the product was discontinued. (d) The Kaiser Gypsum California plants that made this product were located at Antioch and Santa Ana. These plants were 1 in operation at different times. The product was manufactured at 2 Antioch from 1961 through 1970 and at Santa Ana in 1971 and 1972. 3 Because of the heavy weight of the product, low profit margin and 4 high transportation costs, distribution tended to center around 5 the location of the manufacturing plant. The product consisted 6 primarily of soya, flour and limestone. The product included 7 between 6.5% by weight and 10% by weight chrysotile asbestos as a 8 component depending upon the formula in effect at a given date. 9 (e) This product was a white to off-white powder. It was IQ packaged and sold in sacks of 25 lbs. Each container was labeled 11 with the name of the manufacturer, Kaiser Gypsum Company, Inc., 12 the name of the product and directions for its use. 13 (f) This product was a dry powder, which when mixed with 14 water formed a thick paste. It was used as an adhesive to 15 laminate one piece of gypsum wallboard to another, which was 15 occasionally done to create gypsum drvwall partitions having 17 thicker wallboard than could be created by a single sheet. For 13 examcle, gypsum wallboard typically came in sheets 1/2 inch and 19 5/8 inch thick. If one wanted a gypsum wallboard that was 1 inch 20 thick, this would be created by laminating together two pieces of 21 gycsum wallboard that were each 1/2 inch thick. Laminating 22 compound was used for this purpose. Additionally, it was used to 23 laminate gypsum wallboard to sound deadening board, which would 24 increase the wall's capacity to prevent transmission of sound from 25 one room to another. 26 * -k * 27 28 1 Kaiser Gypsum's responses to interrogatory subparts (g)-(j) 2 applicable to all of the eight wallboard joint compound products 3 discussed above are as follows: 4 (g) Kaiser Gypsum is unsure as to the intended meaning of 5 "The U.S. Government's 'Qualified Products List'," but has no 6 knowledge that any of its wallboard joint compound products ever 7 appeared on such a list. 8 (h) Kaiser Gypsum is aware of the following suppliers of 9 chrysotlle asbestos: 10 John K. Bice 11 Harrison & Crosfield Carmonia Chemical Co. 12 Western Chemical Co. Philip Carey Corp. (Carey Canadian Asbestos) 13 Johns-Manville 14 Union Carbide Corp. E . S . Browning . . 15 Loomis Chemical Co. Benson Chemical 16 Paul W. Wood (Johns-Manvilie) 17 Current addresses, if any, are nor known to Kaiser Gypsum. 18 Most of the specific time periods during which these firms 19 supplied asbestos are unknown. 20 (i) (i through iii) Kaiser Gypsum is not aware of ever selli 21 such products to shipyards, power companies or refineries. Kaiser 22 Gypsum sold such products to non-governmental customers in Norther 23 California from approximately 1952 to 1976. These customers consis 24 largely of building contractors or building materials dealers. 25 Kaiser Gypsum has some retained sales orders and sales 26 invoices for some years which identify the purchasers of Kaiser 27 Gypsum products, the dates of sale, the amount of each product 28 sold and, in some cases, the sites to which the products were to 1 be delivered. These documents do not distinguish between sales of 2 asbestos-containing products and other products. 3 (j) Sales orders and sales invoices. See also Response to 4 Interrogatory 6(b). 5 C. Decorative Texture Finishes For Interior Walls 6 or Ceilings - Asbestos Used As A Component____ 7 Drywall partitions or walls made from gypsum wallboard are 8 sometimes decorated with wall covering or wallpaper that is fixed 9 to the wall by an adhesive or glue. On other occasions such walls are finished by painting them. There are many varieties of paint, 10 11 including some that are intended to create a textured surface (rather than a smooth surface). Kaiser Gypsum manufactured and 12 marketed several texture paint products that during certain years 13 used chrysotile asbestos as one of numerous components. Drywall 14 ceilings are sometimes finished with decorative products, as are 15 the cement slab ceilings found in some high-rise buildings. 16 Kaiser Gypsum also manufactured and marketed decorative texture 17 products for use on such interior ceilings that, during certain IS years, used chrysotile asbestos as one of numerous components. 19 The Kaiser Gypsum decorative wall and ceiling texture products 20 were: 21 22 1. Cover-Tex texture paint 2. Spray-Tex or Spray Cover-Tex texture paint 23 3. Kaiser-Tex texture paint 4. Covertex (TSS) wall texture 24 5. K-Spray ceiling texture 25 Kaiser Gypsum's responses to interrogatory subparts (a)-(f) 26 for each of these products are as follows: 27 28 1. Cover-Tex Texture Paint (a) The trade name of this product was Cover-Tex texture paint. (b) Kaiser Gypsum marketed Cover-Tex texture paint in 1952, but it did not manufacture the product itself. Kaiser Gypsum does not know whether the product marketed in 1952 contained asbestos. Kaiser Gypsum began manufacturing this product in 1953, at which time chrysotile asbestos was used as a component. (c) Kaiser Gypsum last manufactured Cover-Tex texture paint with chrysotile asbestos as a component in 1967, when the product was discontinued. (d) The Kaiser Gypsum California plants that made this product were located in Redwood City and Antioch. These plants were in operation at different times. The product was manufactured at Redwood City from 1953 through 1957 and at the Antioch plant from 1957 through 1967. Because of the heavy weight of rhe product, low profit margin and high transportation costs, distribution tended to center around the location of. the manufacturing plant. The product consisted primarily of casein, limestone and mica. The product included between 4.4% by weight and 8.6% by weight chrysotile asbestos as a component depending upon the formula in effect at a given date. (e) This product was a white to off-white powder. It was packaged and sold in sacks of 25 lbs. and sacks of 50 lbs. Each container was.labeled with the name of the manufacturer, Kaiser Gypsum Company, Inc., the name of the product and directions for its use. (f) This product was a dry powder which, when mixed with water formed a texture paint. It was used to produce texture effects over gypsum wallboard surfaces. 2. Spray-Tea: Or Spray Cover-Tea: Texture Paint (a) The trade name of this product was Spray-Tex. Later it was changed to Spray Cover-Tex texture paint. (b) Kaiser Gypsum began manufacturing this product in 1956, at which time chrysotile asbestos was used as a component. (c) Kaiser Gypsum last manufactured Spray Cover-Tex texture oaint with chrysotile asbestos as a component in 1967, when the product was discontinued. (d) The Kaiser Gypsum California plants that made this product were located in Redwood City and Antioch. These plants were in operation at different times. The product was manufactured at Redwood City from 1956 through 1957 and at the Antioch plant from 1957 through 1967. Because of the heavy weigh of the product, low profit margin and high transportation costs, disoributicn tended to center around the location of the manufacturing plant. The product consisted primarily of casein, limestone and mica. The product included between 6.6% by weight and 36.6% by weight chrysotile asbestos-as a component depending upon the formula in effect at a given date. (e) This product was a white to off-white powder. However, some colored versions of the product were offered. It was packaged and sold in sacks of 25 lbs. and sacks of 50 lbs. Each container was labeled with the name of the manufacturer, Kaiser Gypsum Company, Inc. The name of the manufacturer, Kaiser Gypsum Company, Inc., the name of the product and directions for its use (f) This product was a dry powder which, when mixed with warer formed a texture paint that was used to produce texture effects over gypsum wallboard surfaces. 3. Kaiser-Tex Texture Paint (a) The trade name of this product was Kaiser-Tex texture paint. (b) Kaiser Gypsum marketed Kaiser-Tex texture paint in 1952, but it did not manufacture the product itself. Kaiser Gypsum does not know whether the product manufactured in 1952 contained asbestos. Kaiser Gypsum began manufacturing this product in 1953, at which time chrysotile asbestos was used as a component. (c) Kaiser Gypsum last manufactured Kaiser-Tex texture paint with chrysotile asbestos as a component in 1967, when the product was discontinued. (d) The Kaiser Gypsum California plants that made this product were located in Redwood City and Antioch. These plants were in ooeration at different times. The product was manufactured at Redwood City from 1953 through 1957 and at the Antioch plant from 1957 through 1967. Because of the heavy weight of the product, low profit margin and high transportation costs, distribution tended to center around the location of the manufacturing plant. The product consisted primarily of casein, limestone and mica. The product included between 4.0% by weight and 8.0% by weight chrysotile asbestos as a component depending upon the formula in effect at a given date. (e) This product was a white to off-white powder; however, some colored paints were sold. It was packaged and sold in sacks of 10 lbs. and sacks of 25 lbs. Each container was labeled with the name of the manufacturer, Kaiser Gypsum Company, Inc., the name of the product and directions for its use. (f) This product was a dry powder which, when mixed with water formed a texture paint. It was used to produce texture effects over gypsum wallboard surfaces. 4. Cover-Tex (Tss) Wall Texture (a) The trade name of this product was Kaiser Gypsum Cover Tex (TSS) wall texture paint. (b) Kaiser Gypsum began manufacturing Cover-Tex Wall Texture in 1968, at which time chrysotile asbestos was used as a component. (c) Kaiser Gypsum last manufactured Cover-Tex Wall Texture with chrysotile asbestos as a component in 1975. (d) The Kaiser Gypsum California plants that manufactured this product were Santa Ana and Antioch. These plants were in operation an different times. The product was manufactured at Santa Ana from 1968 through 1975 and at the Antioch plant from 1968 chrough 1975. Because of the heavy weight of the product, low profit margin and high transportation costs, distribution tended to center around the location of the manufacturing plant. The product consisted primarily of casein, limestone and mica. The product included between 4.2% by weight and 8.7% by weight chrysotile asbestos as a component depending upon the formula in effect at a given date. (e) The product was a white to off-white powder. It was packaged and sold in 50 lb. sacks. Each container was labeled with the name of the manufacturer, Kaiser Gypsum Company, Inc., the name of the product and directions for its use. 1 (f) This was a dry powder which when mixed with water formed 2 a paint-like product designed for hand or spray application. When 3 dry, it produced a hard, durable surface. It was used to produce 4 texture effects over gypsum wallboard surfaces. 5 5. K-Spray Ceiling Texture 6 (a) The trade name of this product was Kaiser Gypsum K-Spray 7 Ceiling Texture. 8 (b) Kaiser Gypsum began manufacturing K-Spray Ceiling 9 Texture with chrysotile asbestos as a component in' 1961. 10 (c) Kaiser Gypsum last manufactured K-Spray Ceiling Texture 11 with chrysotile asbestos as a component in 1975. 12 (d) The Kaiser Gypsum California plants that manufactured 13 this product were Santa Ana and Antioch. These plants were in 14 operation at different times. The product was manufactured at 15 Santa Ana from 1973 through 1975 and at the Antioch plant from 16 1961 through 1971. Because of the heavy weight of the product, 17 low profit margin and high transportation costs, distribution 18 tended to center around the location of the manufacturing plant. 19 The product consisted primarily of casein, limestone and mica. 20 The product included between 1.3% by weight and 9.9% by weight 21 chrysotile asbestos as a component depending upon the formula in 22 effect at a given date. 23 (e) The product was a white powder with polystyrene 24 aggregate. It was packaged and sold in 32 lb. sacks. Each 25 container was labeled with the name of the manufacturer, Kaiser 26 Gypsum Company, Inc., the name of the product and directions for 27 its use. 28 (f) This was a dry powder which when mixed with water formed a paint-like product designed for spray application. When dry, it produced a hard, durable surface. It was used to produce texture effects over gypsum wallboard or interior concrete ceilings. * -k * Kaiser Gypsum's responses to interrogatory subparts (g)-(j) applicable to all of the five decorative texture products discussed above are as follows: (g) Kaiser Gypsum is unsure as to the intended meaning of "The U.S. Government's 'Qualified Products List'," but has no knowledge that any of its decorative texture products ever appeared on such a list. (h) Kaiser Gypsum is aware of the following suppliers of chrysotile asbestos: John K. Bice Harrison & Crosfield Carmcnia Chemical Co. Western Chemical Co. Philip Carey Corp. (Carey Canadian Johns-Manville Union Carbide Corp. E. S. Browning Loomis Chemical Co. Benson Chemical - Paul W. Wood (Johns-Manville) Asbestos) ., Current addresses, if any, are not known to Kaiser Gypsum. Most of the specific time periods during which these firms supplied asbestos are unknown. (i) (i through iii) Kaiser Gypsum is not aware of ever selling such products to shipyards, power companies or refineries Kaiser Gypsum sold such products to non-governmental customers in Northern California from approximately 1952 to 1975. These 1 customers consisted largely of building contractors or building 2 materials dealers. 3 Kaiser Gypsum has some retained sales orders and sales 4 invoices for some years which identify the purchasers of Kaiser 5 Gypsum products, the dates of sale, the amount of each product 6 sold, and, in some cases, the sites to which the products were to 7 be delivered. These documents do not distinguish between sales of 8 asbestos-containing products and other products. 9 (j) Sales orders and sales invoices. See also Response to 10 Interrogatory 6(b). 11 D. Electric Radiant Heat System Finishing 12 Products - Asbestos Used As A Component 13 In areas where electricity was expected to be particularly 14 inexpensive, some houses and apartments were constructed with 15 electric radiant heating systems. In some such radiant heating 16 systems, grooves were cut in gypsum wallboard ceilings and 17 electrical hearing cables secured in the grooves. The groove 18 cracks were then filled and the ceiling covered with a decorative 19 finish. In other systems, electric heating wires were stapled to 20 the surface of wallboard. Then the ceiling was covered with a 21 thick decorative finish that would conceal the heating wires. 22 Kaiser Gypsum made several products for finishing such systems, and these products used chrysotile asbestos as one of numerous 23 components. These Kaiser Gypsum products were: 24 25 1. Filler Compound 2. Radiant Heat Compound 26 3. Radiant Heat Scrimless Surfacing Compound 27 Kaiser Gypsum's responses to interrogatory subparts (a)-(f) 28 for each of these p r o d u c t s are as follows: 1 1. Filler Compound 2 (a) The trade name of this product was Kaiser Gypsum Filler 3 Compound. 4 (b) Kaiser Gypsum began manufacturing Filler Compound in 5 1961, at which time chrysotile asbestos was used as a component. 6 (c) Kaiser Gypsum last manufactured Filler Compound with 7 chrysotile asbestos as a component in 1972, when the product was 8 discontinued. 9 (d) The Kaiser Gypsum California plant that made this 10 product was located at Antioch. It manufactured Filler Compound 11 from 1961 to 1970. Because of the heavy weight of the product, 12 the low profit margin and high transportation costs, distribution 13 tended to center around the location of the manufacturing plant. 14 The product consisted primarily of minerals including limestone - 15 and mica. The product used chrysotile asbestos as a component in 16 izs formula but the amount of asbestos called for in the formula 17 used to manufacture the product at the Antioch plant is uncertain IS Investigation is continuing. 19 (e) This product was a white to off-white powder. It was 20 packaged and sold in sacks of 50 lbs. Each container was labeled 21 with contained the name of the manufacturer, Kaiser Gypsum 22 Company, Inc., the name of the product and directions for its use 23 (f) This product was a dry powder, which when mixed with 24 water formed a thick paste. Upon application it dried to a hard, 25 durable surface. It was used to cover radiant heating system 26 ceiling surfaces. 27 28 1 2. Radiant Heat Compound 2 (a) The trade name of this product was Kaiser Gypsum Radiant 3 Heat Compound. 4 (b) Kaiser Gypsum began manufacturing this product in 1968, 5 at which time chrysotile asbestos was used as a component. 6 (c) Kaiser Gypsum last manufactured Radiant Heat Compound 7 with chrysotile asbestos as a component in 1974, when the product 8 was discontinued. 9 (d) The Kaiser Gypsum California plant that made this 10 product was located in Santa Ana, where it was manufactured from 11 1968 through 1974. Because of the heavy weight of the product, 12 the low profit margin and high transportation costs, distribution 13 tended to center around the location of the manufacturing plant. 14 The product consisted primarily of sand and;; white portland cement. 15 The product included between 3.3% by weight and 3.6 by weight 16 chrysotile asbestos as a component. . 17 (e) This product was a white to off-white powder. It was 18 packaged and sold in sacks of 60 lbs. Each container was labeled 19 with the name of the manufacturer, Kaiser Gypsum Company, Inc., 20 the name of the product and directions for its use. 21 (f) This product was a dry powder, which when mixed with 22 water formed a thick paste that was used to cover radiant heating 23 cables stapled to ceiling surfaces. 24 3. Radiant Heat Scrimless Surfacing Compound 25 (a) The trade name of this product was Kaiser Gypsum Radiant 26 Heat Scrimless Surfacing Compound. 27 28 1 (b) Kaiser Gypsum began manufacturing this product in 2 California in 1972, at which time chrysotile asbestos was used as 3 a component. 4 (c) Kaiser Gypsum last manufactured Radiant Heat Scrimless 5 Surfacing Compound with chrysotile asbestos as a component in 6 1974, when the product was discontinued. 7 (d) The Kaiser Gypsum California plant that made this 8 product was located in Santa Ana, where it was'manufactured from 9 1972. Because of the heavy weight of the product,- the low profit 10 margin and high transportation costs, distribution tended to 11 center around the location of the manufacturing plant. The 12 product consisted primarily of sand, silica flour and mica. The 13 product included 5% by weight chrysotile asbestos as a component. 14 (e) This product was a greenish powder. It was packaged and 15 sold in sacks of 25 lbs. and in sacks of 50 lbs. Each container 16 was labeled with the name of the manufacturer, Kaiser Gypsum 17 Company, Inc., the name of the product and directions for its use. 18 (f) This product was a dry powder, which when mixed with 19 water formed a thick paste that was used to cover radiant heating 20 cables embedded in ceiling surfaces. 21 * * * 22 Kaiser Gypsum's responses to interrogatory subparts (g)-(j) 23 applicable to all of the three radiant heating system surfacing 24 products discussed above are as follows: 25 (g) Kaiser Gypsum is unsure as to the intended meaning of 26 "The U.S. Government's 'Qualified Products List'," but has no 27 knowledge that any of its radiant heating system surfacing 28 products ever appeared on such a list. 1 (h) Kaiser Gypsum is aware of the following suppliers of 2 asbestos: 3 John K. Bice Harrison & Crosfield 4 Carmonia Chemical Co. Western Chemical Co. 5 Philip Carey Corp. (Carey Canadian Asbestos) 6 Johns-Manville Union Carbide Corp. 7 E. S. Browning Loomis Chemical Co. 8 Benson Chemical 9 Paul W. Wood (Johns-Manville) 10 Current addresses, if any, are not known to Kaiser Gypsum. 11 Most of the specific time periods during which these firms 12 supplied asbestos are unknown. 13 (i) (i through iii) Kaiser Gypsum is nor aware of ever 14 selling such products to shipyards, power companies or refineries. 15 Kaiser Gypsum sold such products to non-governmental customers in 16 Northern California from approximately 1952 to 1976. These 17 customers consisted largely of building contractors or building 18 materials dealers. . Kaiser Gypsum has some retained sales orders and sales 19 invoices for some years which identify the purchasers of Kaiser 20 21 Gypsum products, the dates of sale, the' amount of each product sold, and, in some cases, the sites to which the products were to 22 be 'delivered. These documents do not distinguish between sales of 23 asbestos-containing products and other products. 24 (j) Sales orders and sales invoices. See also Response 25 26 Interrogatory 6(b). 27 E . Gypsum Wallboard Accessories For 28 Exterior Use - Asbestos Used As A Component 1 Kaiser Gypsum experimented with gypsum wallboard products for 2 use on the exrerior surfaces of buildings, but those products 3 proved unsuccessful. Kaiser Gypsum never discovered a way for 4 them to be manufactured that would allow them to effectively 5 withstand the wide variety of weather and temperature conditions 6 that exterior products confront. Those exterior gypsum products 7 were marketed in several test areas and, as in the case of 8 interior gypsum drywall products, required the use of materials 9 to fill the spaces between pieces of gypsum wallboard and to 10 provide a decorative finish. Kaiser Gypsum offered products for 11 those purposes whose components included small percentages of 12 chrysotile asbestos. These products were: _ 13 1. X-Terior Premix Prefill Compound 14 2. X-Terior Premix Wall Texture Compound Kaiser Gypsum's responses to interrogatory subparts (a)-(f) for each of these products are as follows: 1. X-Terior Premix Prefill Compound (a) The trade name of this product was Kaiser Gypsum X- Terior Premix Prefill Compound. (b) & (c) Kaiser Gypsum began and ceased marketing this product during 1975. Chrysotile asbestos was used as a component for the brief period during which this product was manufactured. (d) The Kaiser Gypsum California plant that made this product was located at Antioch. The product was marketed in a limited market area where exterior gypsum wallboard was being sold on a test basis. Kaiser Gypsum X-Terior Premix Prefill Compound was made primarily of raw gypsum, PVA emulsion and mica. The product included 1.5% by weight chrysotile asbestos as a 2 component. ' 3 (e) This product was a white to off-white paste. It was 4 packaged and sold in metal cans and plastic buckets of 60 lbs., 5 and in cartons of 48 and 60 lbs. Each container was labeled with 6 the name of the manufacturer, Kaiser Gypsum Company, Inc., the 7 name of the product and directions for its use. 8 (f) This product was a paste that was used to pre-fill 9 joints in gypsum wallboard installed on building exteriors. 10 2 . X-Terior Premia: Wall Texture Compound 11 , (a) The trade name of this product was Kaiser Gypsum X- 12 Terior Premix Wall Texture Compound. 13 (b) & (c) Kaiser Gypsum began and ceased marketing this 14 product during 1975. Chrysotile asbestos-was used as a component 15 for the brief period during which this product was manufactured. 16 (d) The Kaiser Gypsum California plant that made this 17 product was located at Antioch. The product consisted primarily 18 of limestone, acrylic emulsion and mica. The product included 19 1.5% by weight chrysotile asbestos as a component. 20 (e) The product was a white to off-white paste. It was 21 packaged and sold in 58-lb. metal cans, plastic buckets and 22 cartons. Each container was labeled with the name of the 23 manufacturer, Kaiser Gypsum Company, Inc., the name of the product 24 and directions for its use. 25 (f) This product was a white to off-white paste that was 26 used to provide surface texture to gypsum wallboard installed on 27 building exteriors. 28 * * * 1 sold, and, in some cases, the sites to which the products were to be delivered. These documents do not distinguish between sales of 3 asbestos-containing products and other products. 4 (j) Sales orders and sales invoices. See also Response to 5 Interrogatory 6(b). 6 III. Products Made At Kaiser Gypsum's Oregon Plant 7 From 1956 to 1978 Kaiser Gypsum owned and operated a plant 8 located at St. Helens, Oregon whose basic capability was to make 9 building construction products by compressing wood fibers 10 extracted from wood chips to make various types of sheets and 11 boards. 12 A. Firtex Products - No Asbestos Used 13 The overwhelming majority of the products Kaiser Gypsum made 14 at its Oregon plant were sold with the trademark "Firtex." No 15 product sold under this trade name ever used asbestos as a 16 component. Firtex products included various types of materials 17 j_j^0 iibed to provide insulation against outside temperatures or to 18 dampen noise. Such products included sneuuhing thei_ was nailed i_o 19 walls before outer layers of bricks or siding were installed. They 20 also included sheet products for insulating roofs. They also 21 included sound deadening board that was used in partitions to 22 reduce the noise that could be heard from adjacent rooms. 23 Firtex products also included materials intended for use on 24 ceilings. One type was tiles that could be glued or tacked to 25 ceilings to reduce noise. Another group of such products was used 26 in suspended ceilings. Suspended ceilings are made by hanging a 27 wood or metal frame from the structural members of a ceiling and 28 then laying square or rectangular decorative and insulating pieces 1 into the frame. Those pieces were termed "lay in boards. Such 2 suspended ceilings used a significant amount of the room's 3 vertical space and because that vertical space cost money to 4 build, suspended ceilings were most commonly found in commercial 5 buildings or office buildings, which typically had higher ceilings 6 than houses during the 1956-1978 period when Kaiser Gypsum made 7 the products. The Firtex line of products was quite successful, 8 and Kaiser Gypsum sold them in great volume, z: 9 B . Mineral Fiber Products 10 1. Kaiser Gypsum Ordinary And 1-Hour Fire Rated 11 Mineral Fiberboard Products - No Asbestos Used 12 As high-rise buildings became more common in California 13 during the 1960's, building code authorities became increasingly 14 concerned about the risks of fires in those buildings and 15 encouraged the development and use of products that were less 16 likely to burn. Since its Firtex wood-chip products would burn, 17 Kaiser Gypsum sought to develop other ceiling tile and lay-in 18 board produces that would be more resistant to fire. Kaiser 19 Gypsum found that the manufacturing machinery at its St. Helens, Oregon plant could be used to make ceiling tiles and lay-in boards 20 21 for suspended ceilings with various types of mineral wool as the 22 principal component (instead of wood chips). Mineral wool is the 23 name given to products made by heating various types of rock to extremely high temperature (where they melt), spinning them into 24 threads, and then letting them cool. Mineral wool looks something 25 like steel wool that is used for rubbing rust off of metal or used 26 in certain kitchen scouring pads. Mineral wool does resist fire 27 and Kaiser Gypsum was successful in developing ceiling tiles and 28 1 Mineral Fibreboard - U .L . Fire Rated (Unjgrwriters1 Laboratories., Inc. Design) 2 (a) The trade name of this product, a mineral fiber product, 3 4 was Kaiser Mineral Fibreboard - U.L. Fire Rated (Underwriters' Laboratories, Inc. Design). The same product was cut into ceiling 5 tiles and lay-in boards for use in suspended ceilings.. It was 6 used for acoustical ceiling tile and suspended lay-in board in 7 circumstances where a 2--hour fire resistance classification was 8 specified. Both the ceiling, tiles and the lay-in boards were sold 9 under the trade name "Kaiser Mineral Fibreboard-UL Fire Rated 10 (Underwriters' Laboratories, Inc. design)." 11 (b) Kaiser Gypsum began manufacturing Mineral Fibreboard- 12 U.L. Fire Rated with c'nrysotile asbestos as a component in 1963. 13 (c) Kaiser Gypsum last manufactured Mineral Fibreboard-U.L . 14 Fire Rated with chrysotile asbestos as a component in 1974, when 15 the 2-hour fire-rated product was discontinued. 16 (d) The plant that made this product was located at St. 17 Helens, Oregon. This product included 1.6% by weight chrysotile 18 asbestos as a component. 19 (e) This product consisted of ceiling tiles and lay-in 20 boards with face side white or colored and with perforated or 21 fissured design for acoustical treatment. The tiles were 1/2" or 22 5 /8 '< by 12" by 12" and. the lay-in boards came in two sizes: 1/2" 23 or 5/8" by 24" by 24" and 1/2" or 5/8" by 24" by 48." They were 24 packaged and sold in boxes of various quantities. The boxes 25 contained the name of the manufacturer, Kaiser Gypsum Company, 26 Inc., the name of the product and other printed material. Kaiser 27 Gypsum's 2-hour fire-rated ceiling tiles and suspended ceiling 28 lay-in board products (in which chrysotile asbestos was used as a 2 component) were required to be specially marked because they 3 looked similar to other Kaiser Gypsum mineral fiberboard ceiling 4 tiles and lay-in boards (that did not contain asbestos as a 5 component) and building inspectors wanted to be able to check to 6 make sure that products with a 2-hour fire resistance 7 classification actually were being used by the building contractor 8 when those had been specified. It is believed that 2-'nour fire 9 rated ceiling tile and suspended ceiling lay-in board was stamped 10 on the back with either the initial "KG" or the word "Kaiser 11 Gypsum." It is believed that this marking was employed during the 12 entire period that the 2-hour fire-rated products were 13 manufactured by Kaiser Gypsum. 14 (g) Kaiser Gypsum is unsure as to the intended meaning of 15 "The U.S. Government's 'Qualified Products List'," but has no 16 knowledge that any of its 2-hour fire-rated mineral fiberboard 17 products ever appeared on such a list. 18 (h) Kaiser Gypsum is aware of the .following suppliers of 19 asbestos : 20 John K. Bice Harrison & Crosfield 21 Carmonia Chemical Co. 22 Western Chemical Co. Philip Carey Corp. (Carey Canadian Asbestos) 23 Johns-Manvilie 24 Union Carbide Corp. E. S. Browning 25 Loomis Chemical Co. Benson Chemical 26 Paul W. Wood (Johns-Manville) 27 28 1 Current addresses, if any, are not known to Kaiser Gypsum. 2 Most of the specific time periods during which these firms 3 supplied asbestos are unknown. 4 (i) (i through iii) Kaiser Gypsum is not aware of ever 5 selling such products to shipyards, power companies or refineries. 6 Kaiser Gypsum sold such products to non-governmental customers in 7 California from approximately 1963 to 1974. These customers 8 consisted largely of building contractors or building materials 9 dealers. 10 Kaiser Gypsum has some retained sales orders and sales 11 invoices for some years which identify the purchasers of Kaiser 12 Gypsum products, the dates of sale, the amount of each product 13 sold, and, in some cases, the sites to which the products were to 1 14 be delivered. These documents do not distinguish between sales of 15 asbestos-containing products and other products. 16 (j) Sales orders and sales invoices. See also Response to 17 Interrogatory 6(b). 18 IV. Types Of Products Kaiser Gypsum Hevey Made And Never Marketed 19 Kaiser Gvosum has never mined, milled or marketed asbestos. 20 Kaiser Gvpsum never designed, manufactured, or marketed any 21 product in which amosite, crocidolite or other amphibole forms of 22 asbestos was used as a component. Kaiser Gypsum never designed, 23 manufactured, or marketed floor tile, pipe insulation or pipe 24 covering, refractory products, boiler insulation, acoustical 25 plaster, or sprayed fireproofing or sprayed thermal insulation 26 products. Kaiser Gypsum never designed, manufactured or marketed 27 any sort of brake products. It never designed, manufactured or 28 1 marketed paper products, textile products, or roofing products in 2 which asbestos was used as a component. Kaiser Gypsum never 3 designed, manufactured or marketed any products intended for use 4 in ships or shipyards, or any products intended for use in trains 5 or other railroad equipment or railroad facilities. 6 V. 7 Null-A-Fire Type-X Gypsum Wallboard Allegedly Contaminated Vermiculite Ore This part of Kaiser Gypsum's response, though not directly 8 called for by the subject interrogatories, is being made in light 9 of earlier versions of Kaiser Gypsum's responses to these 10 interrogatories and evolving knowledge, in the context of 11 historical regulatory uncertainties and disputes about whether 12 vermiculite ore used as a component in some Kaiser Gypsum Null-A 13 Fire Type-X Gypsum Wallboard products may have been contaminated 14 in a way that caused certain workers to be exposed to airborne 15 "asbestos." Kaiser Gypsum's position is that no Kaiser Gypsum 16 Null-A-Fire Type-X Gypsum Wallboard using vermiculite ore as a 17 component could have been a substantial contributing factor to an 18 disease caused by exposure to airborne asbestos fibers. 19 As background, in 1954 Kaiser Gypsum introduced Null-A-Fire 20 brand wallboard, a 5/8" thick gypsum wallboard that was approved 21 by the Research Committee of the Pacific Coast Building Officials 22 Conference and certified by the National Board of Fire 23 Underwriters for a one-hour fire rating. This product was 24 developed in response to the appearance of California building 25 code requirements that walls in several types of public buildings 26 must have such one-hour fire resistance. The term one-hour fire 27 rating meant that, when used as a wall surface, the gypsum 28 I wallboard would resist the passage of flame and heat for at least 2 one hour. The certified product had to be made in accordance with 3 Underwriters Laboratories Code No. 3543. Wallboard products thai_ 4 were fire rated were labeled as "Type X" to distinguish them from 5 ordinary gypsum wallboard products that had not passed fire-rating 6 tests. 7 When introduced in 1954, the primary component of Kaiser 8 Gypsum's Null-A-Fire wallboard was gypsum stucco, which is the 9 gypsum plaster that forms the greatest percentage by weight of all 10 gypsum wallboard. Gypsum plaster, including wallboard stucco, 11 - does not burn, and consequently, all gypsum plaster and gypsum 12 drywall construction poses less risk of fire than does wall 13 construction featuring wood or plastic paneling. However, the 14 ordinary 5/8" gypsum wallboard did not pass the one-hour fire 15 test, because the heat of the test caused the gypsum plaster to 16 shrink and crack, letting the fire through in less than an hour. 17 Kaiser Gypsum found that by adding small proportions of glass 18 fiber and perlite a board could be constructed that would resist 19 shrinking and cracking under the heat of the fire test for the 20 required one-hour period. Perlite is a very light substance, 21 white in color, that looks like puffed"breakfast cereal. It is 22 often used in soil for potted plants to help keep the soil from 23 caking. Perlite is made by heating little pieces of volcanic 24 glass to very high temperatures, which causes them to pop like 25 popcorn. 26 Kaiser Gypsum continued to market its Null-A-Fire Type X 27 gypsum wallboard products that contained perlite for more than a 28 decade following -their introduction in 1954. However,, other manufacturers introduced fire-rated wallboard products that used vermiculite instead of perlite to provide added fire protection. Vermiculite is a mica-like mineral found in the ground in a number of places. In the 1890's it was known by gold prospectors as "fool's gold," because it sparkled in the sun like precious metal. Vermiculite does not weigh much, which makes it useful as a component of construction materials and the melting point of vermiculite is about 2500 degrees, which makes it valuable as fireproofing. Vermiculite consists of many layers of thin plates that have small amounts of water trapped in them. When heated, the water turns to steam causing these plates to expand. Such expanded vermiculite is used by nurseries everywhere to help hold air and moisture in plant soil so that young plants will grow faster and stronger. Uncil 1965, Kaiser Gypsum could not use vermiculite to orovide fire protection in gypsum wallboard, because other companies had secured patents from the United States- government which gave them exclusive rights to use vermiculite in their gypsum wallboard products. In 1965, Kaiser Gypsum secured patent licenses from other companies which authorized Kaiser Gypsum to begin with vermiculite in its wallboard products to provide increased protection against fire. Kaiser Gypsum then began to develop such wallboard products and to present them for fire testing. Since vermiculite expands when it is heated, vermiculite used in a wallboard tends to offset the shrinkage that occurs in gypsum when it is heated, and thus, vermiculite could serve to help a wallboard to hold its shape and provide the desired fire 1 protection. Because the capacity to expand was desired, the Kaiser Gypsum products used as 'the ingredient vermiculite that had not previously been heat-expanded. This unexpanded vermiculite was referred to sometimes as vermiculite ore. When testing and fire code authorities recognized and certified these Kaiser Gypsum products as fire-rated, or qualified to be marketed as "Type X," Kaiser Gypsum began marketing vermiculite-containing gypsum wallboard under its Null-A-fire brand. Kaiser Gypsum manufactured limited quantities of 1/2" Null-A-Fire Type X wallboard beginning 10 in 1967, and began manufacturing 5/8" Null-A-Fire Type X wallboard 11 in 1969. It continued to market such products until it disposed 12 of the last of its gypsum business in April 1978. Like other 13 wallboard products, those Null-A-Fire wallboards consisted 14 primarily of gypsum piaster. The formulas varied over the years 15 but the vermiculice ore percentage did not exceed 4% by weight of 16 the products. Controversv concerning vermiculite reflects the regulatory proDosals published and regulations adopted by the U.S. 19 Occupational Safety and Health Administration ("OSHA") and the resoonses of vermiculite companies to those government actions. OSHA is a U.S government agency, created by federal legislation in 1970, that adopts and enforces workplace safety and health regulations. OSHA has been politically controversial from the beginning. California originally established a parallel state program administered by its Division of Occupational Safety and Health, but that agency and program were terminated several years 27 ago. 28 The federal OSHA undertook to regulate exposure to "asbestos" 2 in the workplace as one of its first regulatory undertakings, and 3 OSHA adopted regulations on asbestos in 1972. (See Kaiser 4 Gypsum's response to Interrogatory No. 15, below.) Thereafter, it 5 undertook to enrorcs those regulations. In due course, it began 6 to threaten manufacturers who used various substances other than 7 asbestos with charges of violating the OSHA asbestos exposure 8 regulations, This triggered a long-lasting legal and scientific 9 dispute concerning what minerals are "asbestos" for purposes of 10 the OSHA regulations and what minerals should be regulated like 11 asbestos even if they are not asbestos. 12 In that context, vermiculite supplier W.R. Grace & Co. 13 ^j^0 y~0 inafter "Grace") issued an "Important Notice to Vermiculite 14 Ore Processors," dated March 17, 1976 warning that "employers of 15 workers handling vermiculite ore" should be "aware of the OSHA 16 regulations," because OSHA was applying them to Grace vermiculite 17 plants and proposed to make the regulation of dust more strict 18 under the regulations. Grace stated that the issues related to 19 vermiculite reflected a "tramp" mineral "found in vermiculite 20 deposits" named "tremolite, defined by OSHA as one of the asbestos 21 family." Disputes over these OSHA proposals persisted for years. 22 Then, on June 20, 1986, OSHA published in the Federal Register (at 23 51 Fed. Reg. 22612) a "Final Rule" that defined "asbestos" to 24 include "tremolite" and applied asbestos exposure limits and 25 warnings to tremolite. However, shortly thereafter those 26 regulations were "stayed," that is, not made effective, by OSHA as 27 to tremolite and several other minerals to prevent the federal 28 courts from deciding whether the regulations were arbitrary and capricious." (See 51 Fed. Reg. 37002; Oct. 17, 1986.) The scientific and regulatory debate continued for more years until OSHA published regulations in 1992 (57 Fed. Reg. 24310; June 8 , 1992) declaring that some tremolite is "platy" or non-fibrous, and "platy tremolite" would not be deemed to be asbestos. However, OSHA found other tremolite was fibrous or "asbestiform" and that such "asbestiform tremolite" would be t regulated as asbestos. OSHA further limited these regulations by ( providing that even products with asbestiform tremolite would not 1 < be subject to asbestos regulation if asbestiform tremolite "is 1 : present in a product- in concentrations less than 1 . 0 percent by 1 ; weight." i Kaiser Gypsum admits that for a limited number of years some l of its Nuli-A-Fire products contained vermiculite, but Kaiser l Gypsum denies that these products contained asbestiform tremolite. l Kaiser Gypsum further contends that any attempt under state law to i deem any products that have less than the amount that would subject them to federal regulation to be asbestos-containing products would be preempted by federal law and the Supremacy Clause of the U.S. Constitution. RESPONSE TO INTERROGATORY NO. 11: Not applicable. RESPONSE TO INTERROGATORY NO. 12: Kaiser Gypsum is unaware of entering into any such rebranding agreements. ' RESPONSE TO INTERROGATORY NO. 13: During 1952 Kaiser Gypsum purchased Joint Cement, Cover-Tex texture paint and Kaiser-Tex texture paint from Wesco Waterpaints, I Inc., then located in Berkeley, California, that was packaged in 2 Kaiser Gypsum's name. It is unknown to Kaiser Gypsum whether 3 asbestos was used as a component of those products. During 4 December 1953, after Kaiser Gypsum began manufacturing joint 5 compounds and texture paints, Kaiser Gypsum entered into an 6 agreement with Wesco Waterpaints, Inc., then located in Berkeley, 7 California, to purchase joint cement, topping compound and texture 8 paint packaged in Kaiser Gypsum's name for a ^period of 90 days. 9 It is unknown to Kaiser Gypsum whether any purchases'were made 10 pursuant to this agreement or whether any products purchased had 11 asbestos as a component. In an abundance of caution, Kaiser 12 Gypsum is providing the information it has obtained from its 13 records. Kaiser Gypsum has no information demonstrating that any 14 product obtained from Wesco Waterpaints, Inc. was an asbestos- 15 containing product. Kaiser Gypsum knows of no other agreement io entered by it that provided for rebranding any product of another 17 company's which may have been an asbestos-containing product m 18 Kaiser Gypsum's name for sale in California. 19 RESPONSE TO INTERROGATORY NO. 14: 20 Kaiser Gypsum did not purchase or acquire asbestos from the 21 "General Service Administration" or any branch or agency of the 22 United States Government. 23 RESPONSE TO INTERROGATORY NO. 15: 24 Yes, as to products marketed in 1972 or thereafter. 25 (a) Beginning in 1972, in response to regulations adopted by 26 the U.S. Occupational Safety and Health Administration (see 37 27 Fed. Reg. 11318, June 7, 1972), Kaiser Gypsum affixed caution 28 labels to the packages and containers of its asbestos-containing 1 products. The OSHA regulations requiring this label were made 2 subject to the limitation that "no label is required where 3 asbestos fibers have been modified by a bonding agent, coating, 4 binder, or other material so that during any reasonably 5 foreseeable use, handling, storage, disposal, processing, or 6 transportation, no airborne concentrations of asbestos in excess 7 of the exposure limits prescribed in paragraph (b) of this section 8 will be released." In light of then-existing ambiguities as to 9 what tests OSHA would recognize as adequate to demonstrate a 10 product's falling within this exception, Kaiser Gypsum applied the 11 caution label to all its then-manufactured products in which 12 chrysotile asbestos was used as a component. 13 Initially, the labels were four inches by eight inches in 14 size and had yellow backgrounds with red letters. They were 15 affixed to the bag or container of the product by adhesive in a 16 prominent place. Later, as new bags and containers were 17 purchased, the labels were printed onto the side of the bag or 18 container and are believed to have been the same color or colors 19 as the bag/container or the printing thereon. The label read: 20 CAUTION: contains asbestos fibers; avoid 21 creating dust; breathing asbestos dust may 22 cause serious bodily harm. 23 ' (b) Beginning in 1972; exact date unknown. 24 (c) This label caution remained the same during the 25 remaining time the products upon which it was used continued to 26 use asbestos as a component. 27 RESPONSE TO INTERROGATORY NO. 16: 28 Not applicable. 1 RESPONSE TO INTERROGATORY NO. 17: 2 Most of Kaiser Gypsum's products were sold in the form of a 3 powder or paste; therefore, the.name of the company was on the 4 packaging of the product. However, Kaiser Gypsum's 2-hour fire 5 rated ceiling tiles and suspended ceiling lay-in board products 6 (in which asbestos was used as a component were specially marked 7 because they looked similar to other Kaiser Gypsum mineral 8 fiberboard ceiling tiles and lay-in boards (that did not contain 9 asbestos as a component) and building inspectors wanted to be able 10 to check to make sure that 2 -hour fire-rated products actually 11 were being used by the building contractor when those had been 12 specified. It is believed that each piece of 2-hour fire-rated 13 ceiling tile and suspended ceiling lay-in board was stamped on the 14 back with either the initial "KG" or the word "Kaiser Gypsum. " 15 Such marking was employed during the entire period that the 2-hour 16 fire-rated products were manufactured by Kaiser Gypsum. 17 RESPONSE TO INTERROGATORY NO. 18: 18 Harlan C. Dupuis, former Manager of Research and Development, 19 was deposed on April 16, 1985, in the following case: Katherine 20 Maksim v. U.S. Gypsum, et al., San Francisco County Superior Court 21 No. 768674. 22 Melissa A. Youngman, former Secretary/Treasurer, was deposed 23 on March 4 and 5, 1993, in the following cases: Donald Breslin v. 24 ABEX, et al., San Francisco County Superior Court, Case No. 25 943928; Coy Cossey v. ABEX, et al., San Francisco County Superior 26 Court, Case No, 920148; Norma E. Olsen v, ABEX, et al., San 27 Francisco County Superior Court, Case No. 914076; Lynn Weimer v. 28 ABEX, et a l ., San Francisco County Superior Court, Case No. 1 914594; and Rav Person v. ABEX, et al., San Francisco County 2 Superior Court, Case No. 944872. 3 Thomas V. Smith, former Technical Supervisor for Accessory 4 Products, was deposed on March 11, 1992, in the following case: 5 Michael F. Richie, et al. v. Raybestos-Manhattan, et al._, Superior 6 Court of the State of California for the County of San Francisco, 7 Civ. 933324. 8 RESPONSE TO INTERROGATORY NO. 19 9 Kaiser Gypsum has no knowledge that it ever purchased or 10 otherwise acquired an asbestos-containing product line rrom 11 another company. 12 RESPONSE TO INTERROGATORY NO. 20: 13 Kaiser Gypsum has retained a number of brochures, pamphlets, 14 catalogs and other product information documents. Many of these 15 documents discuss both asbestos-containing products and other 16 products, and many of the documents are similar. For these 17 reasons, rather than attempting to identify each individual 18 document, Kaiser Gypsum will make representative documents 19 available for inspection upon reasonable notice at the offices of 20 Dillinqnam & Murphy, 225 Bus, 6 th Floor, San Francisco, 21 California. 22 (a) through (c) - See statement above. 23 (d) To provide potential users of such products with 24 information about the products. 25 (e) Some of these documents still exist. 26 (f) See above statement. 27 (g) See Response to Interrogatory No. 6 (b). 28 RESPONSE TO INTERROGATORY NO. 21: Not applicable. RESPONSE TO INTERROGATORY NO. 22: No, not to Kaiser Gypsum's knowledge. RESPONSE TO INTERROGATORY NO. 23: The interrogatories define "contract unit" to "mean a branch or division of a defendant which has been or is now engaged in installation and/or removal of 'raw asbestos fibers' and/or 'asbestos-containing products'." Kaiser Gypsum never has had such a unit. RESPONSE TO INTERROGATORY NO. 24: Not applicable. RESPONSE TO INTERROGATORY NO. 25: Kaiser Gypsum had product liability insurance during the period of time it manufactured or sold asbestos-containing products. . 1 RESPONSE TO INTERROGATORY NO. 26: a)-(d) Kaiser Gypsum is'insured under a number of general corporate liability insurance policies that were issued by primary insurance carriers, including Truck Insurance Exchange, Fireman's Fund, The Home Insurance Company and National Union Insurance Company, which Kaiser Gypsum maintains provide coverage for personal injury claims. Certain policy terms and conditions are subject to disputes between Kaiser Gypsum andiits carriers. Kaiser Gypsum also believes that it is insured under 'a number of 10 excess liability insurance policies that were issued by a number 11 of different insurance carriers, including some that may no longer 12 be capable of responding to their obligations. The terms and 13 conditions or these excess policies may be subject to dispute. 14 Kaiser Gypsum will supplement this response in the event the 15 circumstances in a particular case may make mere detailed 16 information on insurance policies of relevance, taking into 17 account the carrier and dispute resolution status percaining at 18 that time. 1 DATE: 20 /d i o H i T 2 22 2 . DILLINGHAM & MURPHY Bv: PATRICK UT HAGAN, ESQ. E. JANE WELLS, ESQ. Attorneys for Defendant Kaiser Gypsum Company, Inc. 24 25 26 27 28 1 VERM .CAIim 2 3 I, the undersigned say: 4 5 I have read the foregoing document; to the extent that the information set forth 6 in the foregoing document is personally known to me, the information is true and correct to 7 the best of my knowledge; to the extent that the information set forth in the foregoing 8 document is not known to me but is required by law to be provided in said responses, I believe 9 the responses to be correct; to the extent that the responses state legal objections, the responses 10 have been prepared by my attorneys based on their work product and other information known ' 11 to them, and are not within my personal knowledge. 12 I declare under penalty of perjury under the laws of the State of California, that 13 the foregoing is true and correct. 14 Executed this > day of , 1996, at San Ramon, California. 15 16 17 Kaiser Gypsum Company, Inc.'s 18 Updated Responses to Plaintiffs' Standard Interrogatories to 19 Defendants In Re: San Francisco Superior Court 20 Complex Asbestos Litigation 21 22 23 24 25 26 27 28 PttOrVF1 OF SERVICE BY MAIL TC.C.P. 1013a. 2015.51 I, the undersigned, declare: That I am employed in the City of San Francisco, County of San Francisco, State of California; that I am over the age of eighteen years and not a party to the within cause; that my business address is 625 Market Street, Fourteenth Floor, San Francisco, California 94105-3315. That on today's date I served the attached: KAISER GYPSUM COMPANY, INC.'S UPDATED RESPONSES TO PLAINTIFF'S STANDARD INTERROGATORIES TO DEFENDANTS on the parties in said cause, by placing a true copy of each document enclosed in a sealed envelope with postage thereon fully prepaid, in the United States mail at San Francisco, California, addressed as follows: Alan R. Brayton, Esq. Brayton Harley Curtis 222 Rush Landing P.O. Box 2109 Novato, CA 96723 (see also attached service list) I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Dated: December 30, 1996 proof.mal Christine Willis IN RE COMPLEX ASBESTOS LITIGATION PLAINTIFFS' COUNSEL SERVICE LIST B ruce L. A hnfeldt, Esq., P .O . Box 6 0 7 8 , N apa, C A 94581 Law O ffices o f M arc C . B arulich, 1721 Court S tre et, R ed d in g , CA 96001 B rayton H arley C urtis, 2 22 Rush Landing, P .O . Box 2 0 1 9 , Novato, C A 949 48 C a s e y , G erry, C as ey , W estb ro o k, R eed & S ch en k, 110 Laurel S treet, S an D iego, C A 9 2 1 0 1 , Attn: F rederick Schenk Law O ffices o f Jack K. C lap p er, 6 2 Princess S tre e t, S au salito , CA 9 4 9 6 5 Law O ffices o f Frank H. F in n ey, 2 0 3 3 North M ain S tre e t, S u ite 4 3 0 , W aln u t C reek, CA 94596 Law O ffices O f C hristopher E. G rell, 685 M arket S tre et, S u ite 540, S an Francisco, C A 94105 V iss e & Y a n e z, LLP, O ne D an iel Burnham C ourt, S uite 2 2 0 -C , San Francisco, CA 9 4109-5460 G e o rg e W . K ilboum e, Esq., 661 A ugusta D rive, M orag a, C A 94556 K enneth L. K napp, Esq., 1 1 0 9 Q uail S treet, N ew po rt B each , CA 9 2 6 6 0 w O ffices o f J. K enneth Lynch, O ne Sansom e S treet, S uite 2 1 0 0 , San Francisco, .A 94105 M cC arth y, Johnson & M iiler, 5 9 5 M arket S treet, S u ite 2 2 0 0 , San Francisco, CA 94105 '' Law O ffices o f John C . R obinson, 365 Notre D am e D rive, V allejo , C A 9 4 5 8 9 R obles & G o n zales , O ne B ayfron t P laza, Suite 9 0 0 , 100 S. Biscayne B oulevard, M iam i, FL 33131 S teven B. S tein , E sq., O n e E m barcad ero C en ter, S u ite 2 1 1 2 , San Francisco, CA 94111 Law O ffices o f S tern s, W a lk e r & Lods, 100 First S treet, S u ite 2300, San Francisco, CA 94104 W a rtn ick, C h ab er, H aro w itz, Sm ith & T igerm an, 101 C alifornia S treet, S uite 2200, S an F rancisco, C A 94111 7 07-224-6547 Fax: 7 07-224-2518 9 16-244-0988 4 15 -898-1555 Fax: 415-898-1247 6 1 9 -2 3 8 -1 8 1 1 Fax: 6 19 -544-9232 4 1 5 -3 3 2 -4 2 6 2 Fax: 415-331-5387 5 10 -256-3307 Fax: 5 10 -256-3308 4 1 5 -5 4 1 -9 8 6 6 Fax: 4 15-541-9869 4 15-441-1707 F ax:415-441-0340 5 1 0 -3 7 2 -3 3 0 4 7 14-851-1200 4 15-951-4616 Fax: 415-951-4653 4 1 5 -8 8 2 -2 9 9 2 7 07 -554-2393 Fax: 707-554-2394 3 05 -371-5944 4 15-543-0152 F ax:415-626-2185 4 1 5 -8 9 6 -5 5 6 6 Fax: 415-986-5896 com plxpl.lst TN ~RF: COMPLEX ASBESTOS LITTGATTON Defense Counsel Service List . Revised 1/16/96 Adam s, Nye, Sinunu & Walker, 633 Battery SL, Sth Floor, San Francisco, 415/982-8955 CA 94111, Attn: Barbara R. Adams F a r 415/982-2042 On behalf of. General Plumbing Supply CoJForderer Comice Works, IncTPrecsson Auto Parts/ The Bolster Go/Tim es Mirror Co/The Brose Co./Monument C ar Parts/Steel Grip, InciAce Hardware/ Sears Roebuck & CoJPottar Eectric/Burt Williams & Son, IncXrossfield Products Corpi Plumbers Specsalty C o - IncJBroadway-Webster Medical Plaza/Qualitex Co., IncJJanos Industrial Insulation Corp/The Industrial Maintenance Engineering Contracting Co. (T1MEC)/Calaveras Asbestos/ Janos Industrial Corp. ' Andersen, Bonnffield & Stevens, 1355 Willow W ay, Suite 255, Concord, CA 94520 510/502-1400 Attn: R.M. Bonnifield c hi S1 ( 8 2 5 4 )1 4 3 On behalf o f Patrick J. Ruane, incJPetrochemicai Insulation, IncJO.G. Supply, IncXlose Building Materials, Ino/Gasket Engineering & Machine, Inc. Anderson, Galloway & Lucehesa, 1676 North California Blvd., Suite 500, 510/943-6383 W alnut Creek, CA 94596, Attn: Marty Everson F a r 510/943-7542 On behalf o f Babcock & Wilcox ; Archer, McComas, Bresiin, McMahon & C hritton, 2033 N. Main SL, Suite 800, P O Box 8035, Walnut Creek, CA 94596, Attn: Rand Chritton Far 510/930-6600 510/930-6620 On behalf o f Hofmann CoJContinental Can CoJLa Habra Products, IncJBay City Boilers & Engineering/ Aetna Life & Casualty CoJBank of Canton of Califomia/Sentry Insurance CoJZum Industries/Piedmont Lumber CoJOhio Casualty Group/Caritsle CorpJCahill Construction CoJDurant Insulated Pipe CoJ Anning-Johnson CoA/icior Equipment CoJCathedral Hill Hotel, IncJAnderson, Rowe & Buckley/ Waldron Duffy, Inc/lreland-Robinson & Hadley, IncJDillingham Construction N A , IncJRoss Island Sand & Gravel CoJFairfax Building Supply/J.G. MacPhee Company/Coiumbia Pipe & Supply Am elle Hastie, McGee, Willis & Greene, One Market Plaza, Spear Street Tower, 415/495-4747 39th Floor, San Francisco, CA 94105-1123, Attn: Otis M cGee, Jr. F a r 415/495-5123 On behalf o f Eaton CorpXrown Coach, lncJChrysler CorpJAMC/NARMCO, IncJWorid Becherer, Beers, ,,Murph.y., iK/a_n_nejtjt. & rS*_c!_h_w-eitzer., T225f0i0nDP^oiw/nellll CSttrrnexeaft, QSiuiifttenf8lDlR5^, Emeryville, CA 94608, Attn: Patrick J. Becherer Far On behalf of: Chrysler Carporation/Bridgesone-Firestone, Inc. B arger & W olen, 101 California Street Suite 4725, San Francisco, CA 94111-5848 Attn: Gary A Bresee - - ^ax On behalf o f The Equitable Life Assurance Society of the United States Law Offices of Susan !_. Benett, 1550 The Alameda, Suite 3o0, San Jose, CA S5125 Attn: Susan L Benett Far Savings & Loan 510/658-3600 510/658-1151 415/434-2800 415/434-2533 408/287-2030 408/287-1303 On behalf o f United Airlines . , B ennett & Rowland, One Embarcadre Center, Suite 950, San Francsco, CA 94111 Attn: Allison D. Daniels/Stanley M. Wessels Far 415/95&-480Q 415/788-5948 . On behalf o f Honda North America, Inc. B ennett, Samuelsen,. Reynolds & Allard, 1951 W ebster S treet Suite 200, ' Oakland, CA 94612-2940, Attn: Richard L Reynolds . 510/444-7688 F a r -5-1--0--/4--44--5- 849 On behalf o f Dresser Industries, IncJHarbison-Walker/Indresco/O.C. McDonald CoJSIakey Brothers/ O .C . McDonald CoJPitt-Des Moines, Inc. _.............. _ A rth u r Paul Berg, Attorney at Law, The Woodlands, 1635 Wabasso W a y ,............ - Glendale, CA 91208, Attn: Arthur Paul B e rg ------------------ ----------------- ~ Far 818/547-9575 818/547-0461 On behalf o f Rock.Woof Manufacturing Co B erry & Berry,'Station D .P .O . Box 70250 (1300 Clay S treet 9th Floor), Oakland, CA 94612-0250, Attn: Carolyn ColTins Far 510/873-6700 510/835-5117 Designated Defense Counsel . . B everidge & Diamond, One Sansoma Street Suite 3400, San Francisco, CA 94104 Attn: Brett P. Moffatt ~ ; On behalf o f D elW eb^^rtfom ia CorpJMiles, I n c . `i l _^3 r - Bishop, Barry, Howe, Haney & Ryder, 275 Battery SL, 12th Floor, San Francisco, CA 94111, Attn: Nelson C. Barty .......... . .. Far 415/397-0100 415/397-4238 415/421-3550 415/362-4730 On behalf of: PPG tndustries/Plant Products &^Supply C JA.H. Bennett CoJPacific Ship R epaiH ^C ^ I Bjork, Lawranca, Poesehl & Kohn, 483 Ninth Street, Oakland, CA 94607 Attn: Dorine P. Kohn Far On behalf oh Dunn-Edwards CorpJRockbestos/Cerro Metal Products Co. Bledsoe, Cathcart, Diestel, Livingston & Pedersen, 601 California SL, 16th Roor, . San Francisco, CA 94108, Attn: Gregory L Spallas Far On behalf oh Cincinnati Gasket Packing & Mfg. CoJTJd. Cobb CoJBeronio U m b e r CoJ 510/832-8134 510/832-0461 415/981-5411 415/981-0352 Scherba's Auto Stores, Inc. Boom azian, Jensen & Garthe, 1800 Harrison SL, 25th Roor, 94612, Mailing: 510/834-4350 P.O. Sox 12925, Oakland, CA 94604, Attn: Robert Crow Pax: 510/839-1897 On behalf oh NACCO Materials Handling Group, Inc., Successor-in-interest to HysterCo. Borton, Petrini & Conron, One Sansome SL, Suita 1000, San Francisco, CA 94104 415/981-4415 Attn: Richard E Korb F a * 415/391-5538 On behalf oh Ford Whoisale Co., IncjThrowbot. Inc. Boughey, Garvie & Bushner, One Post SL, Suite 2400, San Frandsco, CA 94104 415/398-4500 Attn: Todd J. Holcomb Fax: 415/398-2455 On behalf oh Service Engineering CoJH&H Ship Service CoJMatthew G . Norton Co./Southwest Marine Bowles & Verna, 2121 N. California Blvd., Suite 875, P.O. Box 8180, W alnut Creek, 510/935-3300 CA 94596, Attn: Robert D. Phillips, Jr. . Fax: 510/935-0371 On behalf oh Anheuser-Busch, IncJKilpatrick's Bakeries _ _ Bradley, Curley & Asiano, 150 Spear SL, 12th Roor, San Francisco, CA 94105-1535 415/442-4888 Attn: Ann M. Asiano " Fax: 415/442-4884 On behalf oh Power Engineering & Equipment CoJlndudotherm Industnes, Inc. Branson, FitzGerald & Howard, 643 Bair Osiand Rd., Suite 400, P.0 . Box 2189, 415/365-7710 ~ Redwood City, CA 94064-2189, Attn: Henry D. Rome Fax: 4-1--5--/-3--6--4---52S7 On behalf of: Synkoloid/Gow Supply CqTValley Stucco & Putty Plant IncJArtra Group, Inc., Successor to Dutch Boy, IncJPine Cone Lumber Co., Inc. _ Brobeck, Phleger & Harrison, One Market Plaza, Spear Street Tower, 415/442-0900 San Francisco, CA 94105, Attn: William P. Griffin Far. 415/442-1010 On behalf of: Rbreboard CorpJAtlantic Richfield/CIBA-Geigy Carp./Western MacArthur CoJ Brobeck, Phleger & Harrison, One Market Plaza, Spear Street Tower, J415/442-0900 San Francisco, CA 94105, Attn: John Carlson- Fax: 415/442-1010 On behalf oh L D . Brinkman Co. _ Brobeck, Phleger & Harrison, 4675 MacArthur Court, Suite 1000, Newport Beach, CA 92660-1846, Attn: Kathlene W . Lowe Far 714/752-7535 714/752-7522 On behalf oh Koll Real Estate Group, Inc. _ Bronson, Bronson & McKinnon, 505 Montgomery SL, San Frandsco, CA 94111 Attn: Lawrence M. Cirelli Far 415/986-4200 415/982-1394 On behalf oh BOC Group, IncJAirco Gas & Gear Corp./Electrical Insulation Suppliers, Inc. _ Brown, Pistone, Hurley & Van Vlear, 8001 Irvine Center Drive, Suite 900, 714/727-0559 Irvine, CA 92718, Attn: Michael K. Wolder F a r 714/727-0656 On behalf oh Advance Mechanical Contractors, Inc. - 1 _ Capps, Staples, W ard, Hastings & Dodson, 1777Botelho Drive. Sufte 100, . .. . 510/939-4411 Walnut Creek, CA 94596, Attn: Marsha L Stephenson ' _ ... F a r .510/939-5241 _ -LJ-On behalf oh Graybar B edric/U .S. Borax, line. - - ----------------_ Carroll, Burdick & McDonough, 44 Montgomery S t, Suite 400, San Frandsco, 415/989-5900 -- CA 94104, Attn:Jam es B. Ciapp/Robert G. Miller - ~- -- F-- F a r -- 415/989-0932 On behalf of: McDonnell Douglas CorpAevi Strauss & CoJSchlage Lock/C.F. Braun/Oscar E Erickson/ . "^In g ere o il-R arfl Co7J.P. Stevens & Co., IncJD. Zelinsky & Sons, ln c /n ie ` D r CorpJSuperibr Boiler Works ~ 'C a rro ll, Burdick & McDonough, 44 Montgomery SL, Suite 400, San Frandsco, 415/989-5900 .CA 94104 rAttn: Teke Kelley' _ . * - - - - - -- ~_Fax: -4 1 5 /9 8 9 -0 9 3 2 On behalf oh Ericsson, Inc. (Anaconda) _ Carroll, Burdick & McDonough, 44 Montgomery SL, Suite 400, San Francisco, 415/989-5300 CA 94104, Attn: Roberta J. Beringer - F a r 415/989-0932 On behalf oh SL Francis Hotel/Selas Corporation of America/Home Savings of America -- - - ..... - _ Caswell, B ell,H illison,B urnside & Greer, 5200 N. Palm A ve.,Fresno,C A 93704-2228 209/225-6550 ...L (Mail: P.O . Box 5259, Fresno, CA 93755-5259), Attn: RandoIfKrbechefe =:Fax: 209/225-7912 On behalf of: Terminal Air Brake Supply, Inc. Clapp, Moroney, Beilagamha, u -v is & Vucinich, 4400 Bohannon Drive, Suit iQO, 415/327-1300 Menlo Park, CAS4025, Attn: Christopher W . Wood - Fax: 415/327-3707 On behalf of: E.V. Roberts & Associates, IncJAcousta-Lite/Floorcraft/B Cartuno Parts CoTClaude Short Dodge/Guy F. Atkinson CoJKeystone Consolidated Industries/Power Boiler Sales, Inc/Delm er's 8rakes/ W ismer & Becker Contracting Engtneers/Archie Brothers, lnc/Cteaver Brooks, A Division of Aqua-Chem/ Pacific Mechanical CorpJCoca-Cola Co/Venton Plastaring/South Bay Taping/Westem States Stone Co. Coddington, Hicks & Danforth, 555 Twin Dolphin Dr., Suite 300, Redwood City, 415/592-5400 CA 94065. Attn: David Levine Fax: 4157592-5027 On behalf of: United Airlines, IncJHexcal Corp. Connor & Bishop, 870 Market SL, Suite 600, San Francisco, CA 94102 415/434-3006 Alin: Charles S. Bishop ' F a r 415/434-1445 On behalf oft Mine Safety & Appliances CoTWabash Power Equipment Co. Cooper, W hite & Cooper, 201 CaliforniaSL, 17th Floor, San Francisco, CA 94111 - .415/433-1900 Attn: Christopher J. Mead/John P. Makin F a r 415/433-5530 On behalf oft California Hydronics Corporation Cooper, W hite & Cooper, 201 California SL, 17th Floor, San Francisco, CA 94111 415/433-1900 Attn: Lawrence J. Siskind/Daniel A . Metsal F a r 415/433-5530 On behalf oft The Kendall Company . C rosby, Heafey, Roach &. May, 1999 Harrison StreeL Oakland, CA 94612 510/763-2000 Attn: Judie Warren F a r 510/273-8866 On behalf oft Chrysler CorpJAMC/Hobart Brothers CoVDelaval Steam Turbine C o /M O Industries/ Bridgestone/Firestone, IncAJruon Pacific Railroad CoJLincoln Electric CoVF.P. Lathrap Construction Co. Crosby, Heafey, Roqch & May, 1999 Harrison Street Oakland, CA 34612 510/763-2000 Attn: Julie Unn F a r 510/273-8866 On behalf of: Phillips Petroleum CoVGayiord Container Corp/Tosco CorpTSpreckels Sugar Co Cullom & Burland, 550 California SL, Suite 700, San Francisco, CA94104 4-15/781-7999 Attn: Freeman D. Cullom F a r 415/788-0335 On behalf oft Crane Packaging/John Crane-Houdaille C yril & Crowley, 456 Montgomery SL, 17th Floor, San Francisco, CA 94104 Attn: Wendy J. Hannum/Mark D. Fenske F ar' 415/989-1100 415/421-6651 On behalf oft Colberg, IncJTRW CorpjM oorej.-McCormack Resources C yrii & Crowley, 456 Montgomery SL, 17th Floor, San Francisco, CA 94104 415/989-1100 Attn: Michael W . Freld/Mark D. Skilling F a r 415/421-6651 On behalf oft Pyramid Investment Corp/Transamerica Corporation/TIG Premier Insurance Co. . Danaher, Tedford, Lagnese & N eal, P.C., 700 Capitol Place, 21 Oak Street 203/247-3666 Hartford, CT 06106 . F a r 203/5471321 On behalf oft Pittsburgh Coming Corporation Daniels, Baratta A Fine, 1801 Century Park East 9th Floor, Los Angeles, CA 90067 31Q/556-7S00 Attn: Stephanie J. Berman F a r 310/556-2807 On behalf oft Highland Stucco & Lime Products, Inc. Davidovrtz & Yaron, 111 Pine S treet 12th Floor' San Francisco, CA 94111-5614 415/658*2929 Attn: Jeffrey J.Fadeff ------------ - .......................... F a r 415/658-2930 On behalf oft Todd Shipyard/Mervyn's/Pierce Enterprises/American Standard, In c/T ran aC o / Railroad Friction Products CorpJColombiru Construction " D ew ey BaUantine, 333 South Hope S treet Los Angeles; CA 90071 - ~~ - -- 213/626-3399 On benaif oft Champion International C o rp .___ . . . ' . Fa r 213625-0562 - Dickson, Carison & CampHlo,~120 Broadway,"Suite 300, Santa Monica, CA 90407, ~ - `310/451-2273 _ Mailing: P.CLBox 2122,Santa Monica,,CA 90407-2122,Attn: Eric M. Z y i a ^ r r - F a r -- 310/451-907.1 On behalf oft R.T. Vanderbilt C o /t^ e r jn c /^ e r fc a n Cyanamid -- -- ^ -7 --!^ -- - - ^ - r -- -1 Dickson, Carlson & Cam pillo, 120 Broadway, Suite 300, Santa Monica, CA 90407 310/451-2273 Mailing: P.O. Box 2122, Santa Monica, CA 90407-2122, Attn: Roxanne M. Wilson F a r -310/451-9071 On behalf oft Plant Insulation Company (Subic Bay only) Dillingham & Murphy, 625 Market S treet 14th FIoor, San Francisco, C A 94105-3315,Attn:JohnDahlberg /- - On behalf of: AT&T Technologies/Conoco, Inc. -- : - - ` " v- ' - Fax:. "7' ' - 415/896-0400 4 1 5 /8 8 2 ^ 2 0 2 Dillingham Murphy, 625 Market Street, 14th Floor, San Francisco, CA 941u>-3315 415/896-0400 Attn: William K. Bissei Fax: 415/764-1970 On behalf of: Kaiser Cement CorpjKaiser Gypsum Co,, incJGasket Specialties, In c i pg_ Dolan Lumber CojGoulds Pumps, Inc. D rath, C lifford, Murphy, W ennerhoim Hagen, 44 Montgomery Street, Suite 1500, San Francisco, CA 94104, Attn: John M . Drath Fax: 415/392-3006 415/391-3348 On behalf oft USX Corp. Dryden, M argoles, Schimaneck, Hartm an, K elly W ait, One California S t, Suite 2500, 415/362-6715 San Francisco. CA 84111, Attn: Lawrence Margoles F a r 415/362-0633 On behatf oft Rggie International, IncJFond Motor Co./Sherwin-Wniiams Co./Phillips Petroleum CoJ Mack Trucks, IncJQBrien CorpJCapco Pipe Co., Ino/Jaguar Care Duncan, B all, Evans Ubaldi, 641 Fulton Avenue, Second Floor, Sacramento, CA 95825, Attn: Jeny M. Duncan Far 916/488-1666 .916/488-1699 On behalf oft Mercy San Juan Hospital Ericksen, A rbuthnot Brown, K ilduff Day. 530 W ater SL, Suite 720, Oakland, CA 94607-3746, Attn: William J. Hoback Far 510/832-7770 510/832-0102 On behalf oft BJ". Goodrich CoTNatkin & Co. . Ericksen, Arbuthnot, Kilduff, Day U ndstrom , Inc., 20 Califomia Street, Suite 300, San Francisco. CA 94111-4803, Attn: AndrewP. S dar Far 415/362-7126 4,15/362-6401 On behalf oft Aratex/Aramark Services, Inc. (Successor-In-Interest to U.S. Industrial Glove Co.) S_yd,ney E. Fairbair__n, Attorney ja,*t ILaiwn, SC/ewvreannHMiHL ILeaesseeann HDrriitv/ea, Suite rDL-11*3L4L, j4H15^/479-0940 San Rafael, CA 94903, Attn: Sydney E. Fairbairn Fax: 415/479-0940 On behalf of: H. Goldman & Sons Farella, Braun Martel, 235 Montgomery SL, 30th Floor, San Francisco, CA 94104 415/954-4400 Attn: Dennis M. Cusack/Barry T . Ryan On behalf of: Shorenstein Co./Rockwell International John D. Feeney, Southern Pacific Ones. Law DepL, 8th Floor. One Market Plaza, San Francisco, CA 94105 Fax: On behalf of: Southern Pacific Transportation Co. Fenton Keller, 2801 Monterey-Salinas Highway, P.O. Box 791, Monterey, CA 93942 On behalf oft Lorillard Tobacco Co. - Fax: Flynn, Delicti & Wise, 580 Califomia StreeL Suite 1750, San Francisco, CA 94104 Attn: Faye Lee . On behalf of: General Steamship International, Ltd. - Far. Folger & Levin, 275 Battery StreeL 23rd Floor, San Francisco, CA 94111 Attn: Julie Matlof Fax: On behalf oft Amfac Distribution CorpJHilton Hotels Corp. Christie L Fraser, A Law Corporation, 201 Filbert S treet San Francisco, CA 94133 Attn: Christie L Fraser Fax: 415/541-1000 415/541-1734 408/373-1241 408/373-7219 4 1 5 /6 9 3 -5 5 6 6 , 415/693-041 415/986-2800 415/986-2827 415/394-8880 415/394-5665 On behalf of: Pan-Pacific Supply Co., Inc. Fredrickson, Mazeika & G rant 550 West *C* Street Suite 1410, San Diego, CA 92101, Attn: Tomas V. Mazeika . 6 1 9 /2 3 4 ,1 7 2 2 F a r 619/234-1759 :;O n behalf oft University Mechanical & Engineering Contractors - Freeburg, Judy Nettets* 600 South Lake Avenue, 2nd Roor, ^PasaderfafCA 91106-3955,Attn: J'. Lawrence Judy . _O n behalf oft Ftintkote/Genstar/Blue Diamond -- ...................... .. Far. - -- ----------- 818/585-4150 818/585-0718 Frost Healy, 1930 Sonoma Blvd., Vallejo, CA 94590, Attn: Norbert U. Frost T 07/643-5696~ _OOn benhaailrfonft NappaawGloovve wC oi,m;inec.;^== ----------11- --- " --~~ -F a r 707/643-1916 G allaw a, Brown, Kroesch K auffroath, 2207 J S treet Sacramento, CA 95816 = := z r :8 1 6/444-8364 Attn: W alter Gallawa :-- . .: . F a r . 916/444-5921 On behalfof. Amsted IndusinWGriffin W heel Co. " - .7 - .......... " G ardiner, Koch & Hines, 53 West Jackson Blvd., Suite 1550, Chicago, IL 60604 .Attn: Tom Gardiner - . . Far 312/362-0000 312/362-0440 On behalf oft Ellis Corporation _ _ _ . . rG ia n li& Fores, 014 16th Street P.O. Box 3212,.Modesto,CA 95353 lA ttn: Robert.P. fores -y-- - =r~. - T-- --- . . ------------^ .. :" f 209/521-6260 .F a r -- 209/521-6971. drTbehalfoft Motor Parts- Distributors Gibson, Dunn t Cmtcher, One Montgomery Street, San Francisco, CA 94104 ^ Attn: William D . Connell On behalf of: Champion International Carp. N icora, Minor & SulBwan, 30 Raj^dale Drive, Suite 201, X a r e y . CA 93940, Attn: Timothy J. Minor/Steven D. Penrose Fax: 415/393-3200 415/986-5309 408/373-5900 408/373-5991 510/947-1300 510/947-1594 ft Gariodc incJColt Industries/The MMs Building/Fairmont Hotel CoJSaoamento Tires, Banodes r * * CoXookbood Gbuspy 4 Glaspy. 353 Sacramento S t, Suita*1500, San Franasco, CA 94111 Attn: Brian S. O'Malley On behalf oft Morrison KnudsenCorp. G lynn, Cefta & U n g e, 100 Pringle Avenue, Suite 600, W alnut Creek, CA 94596 ^ Attn: James D. Luhmann 415/398-8261 41SOS8415/398-4416 510/210-2800 510/945-1975 S S S E p X X d| S S d C . n ter , R oor. Son Francbco. CA 9411, ^ 4 ,^ 9 0 0 N e t a U Boiler Co., IncJJ.W. S Sons/LN. C o te 4 SonsAVostsm Bulkins Metennls/ Fraser-Edwards CoJHolloway & Freeman, Inc . r A q41n Gordon & Rees, 275 Battery Street, 20th floor, San Francisco, CA 9 Attn: Sara Spees On behalf oft Dow Coming Corp. . U i1 1 Gordon & Rees, 275 Battery Street, 20th Floor, San Franasco, CA 94111 Attn: Michael T. Lucey/S. Mitchell Kaplan On behalf oft Bendix (Allied Corp.)/Allied-Signal, Inc. Gordon & Rees, 275 Battery Street, 20th Floor, San Franasco, CA 94111 Attn: Michael T. Lucey OGnorbdeohnal&f oRfteFeOs,S2E7C5OB,aItntecr.y Street 20th Floor. San Frana.sco. rCaAa.9ri.-1M i Attn: Jewel Kolllng Basse On behalf oft Union Oil of California (UNOCAL) CA 94111 Gordon & Rees, 275 Battery Street 20th Floor, San Franasco, CA 94 par ' ^ ' ^ , . ^ ` ^ 415/986-5900 415/986-8054 415/986-5900 415/986-8054 415/936-5900 415/986-8054 415/986-5900. 415/986-5900 415/986-5900 415/986-8054 ^ ^ s TM a f t TripleAMachine Shop^astco/lndustrial Safe^C om ^ Gordon & Rees, 275 Battery Street 20th Floor. San Franasco, CA 9411 Attn: P. Gerhardt Zacher/Richard D. Fike On behalf oft Rapid American Corp. . Gordon & Rees,275 Battery Street 20th Roor. San Franasco, CA 941 Attn: P_ Gerhardt Zacher/ThomasC. Crosby . . : 415/986-5300 ^ 4 1 5 /9 8 6 -8 0 5 4 - 415/98^-5900 ^ 415/986-8054 213/487-6660 ^ ^ S T p h ffip R .C o s g ro v e _ FWC 213/487-4896 On behalf oft General Motors Corporation 94111 G raftam &Jam es, One Maritime Plaza, 3 rd Roor, S ^ F ra n a s ra ^ C A W 415/954-0200 415/391-2493 .. Attn: Andrew I. Port , Rubber CoJAmerada Hess/Alcoa CoJHendy International/ Keystone Shipping StandardOU ofc a m o m t a m e s . " ~ . A_m_et:_^_nnP_re_sIidinGonct/iRJllnwh^ajtlMoatreilneDrilling/PacificGulfManne Gudmundson, Siggtns, Stone & Skinner, une San Francisco. CA 94111, Attn: Richard J. Siggins . . .no hAhalf of: American Cyanamid ---------""1. JL:____1------- Co/ ,350. ^ ;;415139M200 415/989-4739 O, Cf H a iijM .B ro .ra i.S o n a s te a U O , Sansome S t, Suita 300, San Francisco, CA S S Detendants/Ohio Ucomow. Crana CoJLard C o rp o ra S o n M ^ ia ra n te l C i, audios, In c , <an Francisco Sourdough Bakeries, Inc/Tarketf Inc. ... Ske t 100 Spear Street Suite 310, San Franasco, CA 94105 4, a15c/c51<2i -77<1n0n0 ^ 415/512-7103 ^ ^ o f A v o n P r o d u c t s , IncJDiamond Walnut Growers, Inc S 0- ' " "" n ~ c t S o la r. 10th Floor, Sao F r a n * . < * ? ! Vr' P rrfti^ n d a T w d te ra Hanna, Brophy, MacLean, McAteer ^ San Francisco. CA 94105, Attn: Neville H. McGltchnst ' Sulte 900' Fax; I " " - 415/981-5550 415/955-2599 415/981-5550 415/955-2599 415/543-9110 415/896-0901 510/444-3131 5_10/839-7940 94612, Attn: Peter A. Strotz . * " F . 510/444-3131 510/839-7940 510/444-3131 510/839-7940 94612 Attn: Bruce McLeod/Peter A. Strotz 510/444-3131 510/829-7940 94612 Attn: Marshall A. Thompson 510/444-3131 510/839-7940. Sa-- 95814, I n p : F.O. 916/449-3800 916/449-3888 mo. B rett R. H arrell, P .0. Box 1130, Modesto, CA 9-353 Far ` S a " ^ L ^ o i Jo " S n ter, n i W . S M . 8 U M . Floor. Los Anpales, c 4 - 90017, Attn: William H. Finney . ... On behalfoftFordMotorCoJNavistarInternatonal ^ Cra ^ CA _ Hassard Bonnington.Two Bntarcadero Center,Surte1800,San Franasco,CA ^ 209/579-3717 209/579-3719 - 213/489-3222 213/623-7929 . 415/288-9800 415/288-9801 Hospital/Golden M , M d in p C oXoldon Gateway - xC A 95833r Attn: Stephen S_Talt - ~~ ---------:-------- - --------- '*-- "~r;-- ~ -O n behalf oft Kirichill Rubber Company . ~ c ,n c TM n m ' CA 94104-2878 H aller, H u m a n , W hite 4 McAulffle. 333 Bush StraeL San F ra n c a , CA '415/772-6000 Attn: Ann 6 . Grimaldi Attn:CraigJ.W hitney .......... ,, 213/620-0460 213/624-4840 _ ... ____ :.............. "Attn: Gene Genson _On behalf of. Uniroyaf In c .____ 818/999-4811 :zFaxr -'213/380-8946 .Hoge, Fenton, Jones & Appel, In c . 60 South Market S t, Suite 1400, San Jose, jTM C T7-8501 CA 95113-2396, Attn: Nora Frimann '? 3C ^ r 287' 2583 On behalf of. The Austin Company/American Rubber Manufacturing CoJContoner Corp. Q lf^ a n c a Howarth & Smith, 700 South Rower Street Suite 2900, Los Angeles, CA 90017 Attn: Thomas F.Vandenburg . Fax 221133//995555--09400 213/522-0791 On behalf o f Georgia-Pacific Corporation Howrey & Simon, 550 South Hope Street Suita 1400, Los Angeles, CA 90071 213/892-1800 Attn: Kathryn M. Conway Fax: 213/892-2300 On behalf o f Mohawk Rush Doors, Inc. Hudgins & H u n t 135 Main S treet Suite 1350, San Francsco, CA 94105 Attn: Kevan T . Hunt 415/979-0100 F a r 415/979-0747 On behalf o f Uniroyal, Inc. x . ,,,, Law Offices o f Michael R. Hudson, 500 Sansome S treet Surte 601, San Frandsco, CA 94111, Attn: Michael R. Hudson ,415/882-1556 F a r "415/986-1430 On behalf o f Skinner Corporation Hyde & Holcomb, 1646 North California Blvd., Suite 550, Walnut Creek, CA 94596 Attn: Patrick J. Hyde Far 510/939-7700 510/939-2248 T m o tiry ^ H y d e n , Attorney X U w , 18 Crow Canyon CL, #380, San Ramon, CA 94583 510J831-06g S ^ i^ T a d lo c k ^ K e ^ e y .^ ^ N ^ in tg o m e ry S t. Suite 1000, San Francisco, CA 94104 ^ 8 9 - 8 6 8 7 Attn: Robert C. Keeney/Edgar Hawkyard Fax. 415^89-764 On behalf o f A.W. Chesteron CoJGeorge Raymond CoJRaymond Intenor S y s te m ^ * _ Im ai, Tadlock & Keeney. 180 Montgomery S t, Surte 1000. San Francsco, CA 94104 415/989-3687 Attn: Theodore T. Cordery . . ,, ,, . ... n ~ , On behalf of: See's Candies/Campbel! Soup Co./Simpson Paper CoJHumboldt Bay Pulp CoJ Elliott Co/Rich-Tex, Inc/Basic Vegetable Products/James River CorpJA^chor Hocking C a Jackson, T u fts, Cole & Black, 650 California Street San Francsco, CA 94108 Attn: Lynn A. Starr ' On behalf of: Fort Kent Holdings, Inc. ,,_ . a, , n . Jackson & W allace. 580 California Street 15th Floor, San Francsco, CA 94104 ^ JJ^S oO Orfbehalf o f New York Life Insurance C o/Fluor CorpJRadiator Sperialty/Landor& ^sodates/FerraC oipJ Kraft General Foods, Inc/Miiwhite, IncJM. Slayen & Assodates/Republic Supply Ca/Fraser'sBader Serv.ce/ The Okonite Co/Plant Insulation Co/Arm co. Inc/Chicago Rrebnck Co./Alfred Dunhill of London/Wale Apparatus Co/Hamon Goofing Tower Co/Bethlehem Apparatus/Crown Zellerbach InternationaUnc Jaffe, T^rutani.ch., S_ca.tena & Blu_m , j1f5-5 eS*a_n~some Street, SCnurifteaT7H0H0, SSaann PFrraanncritsccoM, A4115V/339977--9S006 CA 94104, Attn: Michelle M. Lambre F a r 415/397-1339 On behalf o f KSC Recovery ,, x Jedeikin, Green, Meadows & Schneider, 300 Montgomery Street Surte 450, San Frandsco CA 94111, Attn: Joseph Jedeikin ^ax: 415/781-7050 4--15/421,-5.658 On behalf o f City National Bank/Sunset Homes, Inc/Bryan Steam C orp/E . & J. Gallo Winery/Heublein/ ' J e f f r & H ^ e S n n , 685 Market S treet Suite 330, San Frandsco, CA 94105 ~ On behalf o f Burnham Corporation Fax in an aitfian n -Jones, LaMore, B razier & Riddle. 1570 The Alameda, Surte 150, San Jose, CA - ,, - 4 0 8 ^ 8 9 ^ 0 0 _95126-2306.Attn: James C . Jones ` On behalf of: Caterpillar, ihc. : 94111-3984, Jordan, Keeler & Seiigman, Two Embarcadero Center, 19th San Frandsco, CA Attn: David H . Gartshore Floor, ... - On behalf o f Stone & W ebster Engineering Corporation Kaufman &. Logan, 111 Pine S treet Suite 1300, San Francsco. CA 94111 Attn: Peter J. Logan -4 1 5 /3 9 7 -4 6 0 0 ' F a r .415/392-2059 415/392-6677 F a r 415/391-4639 On behalf o f Keck, Mahin First Interstate Bank & Cate, One Maritime Plaza, 23rd-F [o-o/^ S: an' . '~ Francsco, CA 9 4 1 1J-3577 415/332-7077 -- F a r 415/392-3962-, -Attn: Robert E. Paterson On behalf of: Abex Corporation/Wheelabrator Group, Inc. m Kesai, Young Logan, Four Embarcadre Canter, Surte.1500, San Francisco, ^ n i b e h llf'o fL e a rSegler S S i e d Holdings Corp/Progresso Foods Co/Pullman Standard. In c/ TO aLew is Foods, Inc/Tishman Realty Construction C o/The Pullman Company Kenney, Surd & Markowitz, Two Embarcadre Center. Suite 470, San Francisco, CA 94111, Attn: Stephen C. Kenney a3C 415/397-3100 415/397-3170 On behalf of. BP Chemicals ' _. . Kinder, W uerfei & Chotakian, 555 Montgomery SL, 9th Floor, San Francisco, CA 94111, Attn: Edwin S. Nakagawa .. : pa3C 415/398-1551 415/398-3301 On behalf o f Yoiiand Materials Co. _ Kinseila, Boesch, Fujikawa & Tow le, 1901 Avenue of the Stare, 7th Floor, Los Angeles, CA 90067, Attn: Leonard M. Javera 310/201-2000 Fax 310/284-6020 On behalf o f Parker-Hannifin C orp/ElS Division ^ . Knight, Boland & Riordan, 88 Kearny Street, Suite 1310, San Franosco, CA 94104 Attn: Samuel G. Ware n n bshaif o f MetroDoOtan Life Insurance Co. S o , Lemmon, A nipolsky & Sheridan, 300 Capitol Mall, Suite 1170, Sacramento, CA 95814, Attn: Susan J. Sheridan pax 415/362-0684 415/956-2750 916/448-9911 916/448-2566 On behalf o f Kenworth Trucking Co. Knox Ricksen, 1999 Harrison S treet Suite 1700, Oakland, CA 94612 510/893-1000 510/446-1946 On behalf o f Combustion Engineering/Syntex Corp/Oshkosh Truck Corp/Meyers Chemicals/ W ells Fargo Bank/Glidden Co/Southwestern Portland Cement Lafayette! Kumagai & Clarke, 100 Spear SL, Suite 400, San Francisco, CA 94105 " Attn:KevinM .Clarke Fax: On behalf o f Procter & Gamble/Folger Coffee Co/KMart Corporation La S e t t e , Johnson, De Haas, Fesler & Ames. 50 California Street 35th Floor, " San Francisco, CA 94111, Attn: Joanne Rosendm Fax: 415/357-4600 415/896-0683 415/433-7610 415/392-7541 On behalf o f Grefco, Inc/General Refractories Co. La Follette, Johnson, De Haas, Fesler & Ames. 50 California Street 35th Floor, " San Francisco, CA 94111. Attn: Kelley Reid Fax: 415/433-7610 415/392-7541 On behalf of: Gentex Corp. . Landais, Ripley & Diamond, 350 Steuart Street San Francisco, CA 94105-1250 Attn: Morgan GHhuly . ,, Far. On behalf o f J.R. Simplot/Stanford University Hospital/Stanford University Lane Powell Spears & Lubersky, Two Embarcadre Center, Suite 2330, San Francisco, CA 94111. Attn: Kevin C. Mayer Far On behalf o f Hercules, Inc/Mobil Oil Corp/Hofmann Co/Chevron/Ashland, Inc. __ U rs T n i Burnham 1901 Harrison S t, 11th F t, Oakland 94612. Mailing: P.O. Box119, 415/788-5000 415/788-7550 415/421-8624 415/421-8625 510/444-6800 510/835-6666 n'behalfof D ViTN ie ls o n Corp/Golden Gate Drywall, Inc/State Shingle Co/Jack Horton Drywli, In c/ McC^lre & H ^ w /G e ^ B ra lV e n e e rM fg .C o /H y a ttC o rp /F ra n k ^ ff6 ry, t J&H Marine & industrial Engineering Co/Caiifomia Drywall C o /W a ^ i^ Co^rudential Insurance C o / Carter Construction Co/Daniel Smith Plastering, inc/Vicior Kemp Co/Fr^enck MeBw.nkei in c / ..- Whfaker Corp/Borg-Wamer Corp/Mannington Mills/Hitton Hotels ^rp-^afifom m Shingle & Shake C o / - S n a n Lumber /B a k e r's Pride Oven Co.,!ncr/Great Western BanldMedalOon CarpetertJnrvar Corp/ _ MataLs COJW.F- Hayward Co/FruehatrfTrailer orp/Borg-Wamer Automofave, Inc/ _ . ....Cv6ennttrr3ail Souupupilyy Cwuo*. -iL ~-:~i - --" 1**'.'..'.*.*.*.'..~.".*.m.1.*-"**j~........ - *- * * '*' _** Le B ouef, Lamb, G reni^ MacRaeTOne Bnbarcadero Center, San Francisco, " CA 94111, Attn: Lorraine A. Barrabee ~ On behalf o f Alcoa Company Lem ieux & O'Neill, 200 North Westlake Blvd., Suite 100, Westiake Village, " CA 91362-3755, Attn: T a r iL Cody - Far - On behalf o f OFCCO Construction, Inc. (Oil Reid Construdiopi Company, Inc.) Lew is, D'Amato, Brisbois &_Sisgaard,221 North F t e u e r a a S U e e t . ^ ^ = T oL su oA /n" Ugl yew!ei uso ;, CA 900112, A'*t*t"o" rSteverr Mark Lev. y- - = --------:-------- - -- -- - hax: On behalf of: American Standard, Inc/PmdenaUnsurance -415/951-1100 ,4 1 5 /9 5 1 -1 1 8 0 805/495-4770 805/495-2787 213/250-1800 -2 1 3 /2 5 0 -7 9 0 0 --8 U ebm an, Reiner, 4 Walsh, 3255 Wilshire Btvd., 12th Roor, Los Angeles, 213/387-0777 CA 90010, AHn: Craig Nelson Fax 213/383-6754 On behalf o t Riverside Cement Co. (Amcard, Inc.) Lossina & Elston, 100 first Street, 25th Roor. San Francisco, CA 94105- Attn: Kevin Gray 415/882-4200 Fax 415/882-4050 On behalf of: Hunt-Wesson, Inc. Low , Ball & Lynch, 801 California Street, San Francisco, CA 94108 Attn: Celeste M. Scott 415/981-6630 Fa--x 4--1--5--/-9--8--2--1.634 On behalf of: Beck Bectric Supply/JA . Sexauer/The Montague CojCroeniger 4 CoTScott Company/ Moore Dry Dock CaJEF.Mitchler/San Jose Drywall CorpJAilas Heating &Ventilating Co., UdJ Johnson 4 Mape Construction CoJDouglass Insulation C o., IncJThe Branson School/Sono-Ceil CoJ MBL, IncJJohn Ray CoJDyson-JCssner-Moran CorpJBrown Sheet Metal 4 Mechanical/Coen CoJ Darcoid Company of Califomia/Pearfs Auto Supply, Inc. . Lynch, Loofbourrow, Gilardi '& Grummer, 50 Francisco S treet Suite 400, ' 415/397-2800 San Francisco, CA 94133, Attn: Robert V . Betetta Fax: 415/397-0937 On behalf oft CJD. Ericson Co., IncJCalifomia State Automobile Assodation/Shamrock Materials, IncJ Wright-Austin Co., IncJMasonite CorpJP. Green Services, InciAmerican Biltrite, IncJSwinerton & W alberg/ Van Bokkelen Cole CoJJ.C. Penney Co., Inc. M ackenroth Ryan Jacobson Fong, 1610 Arden W ay, Suite 250, Sacramento 95815, Mailing: P.O. Box 255800, Sacramento, CA 95865, Attn: James R. Wright Fax: 916/924-1912 916/923-3872 On behalf oft Deere & Company - Marron, Reid 4 Sheehy, 601 California Street Suite 1200, San Francsca, CA 415/434-0800 94108, Attn: Michael Marron Fax: 415/986-1374 On behalf oft Georgia-Padfic/Colonial Sugar & Refining, Lid. M cCutchen, Doyle, Brown 4 Enersen, Three Embarcadero Center. San Francisco, 415/393-2000 CA 94111, Attn: Patricia Thrash Fax: 415/393-2286 On behalf of: Shape Industries, IncJU.S. Steel/C&H Sugar CoVJames River II, IncVAtlantic Richfield/ American President Lines/McKesson CorpJCatholic Healthcare West McCutchen, Doyle, Brown 4 Enersen, 1331 N. California Blvd., 5th F t, Walnut Creek, 510/975-5331 CA 94596 Mailing: P.O. Box V, Walnut Creek, CA 94596, Attn: Susan A. Ogdie Fax 510/975-5390 On behalf of: Exxon CorpJTexaco, IncJCoastal W est Ventures/Domtar Gypsum America, IncJ Bombardier, IncJAubum Technology, Inc. McGJynn, McLorg 4 Ritchie, 177 Steuart S t, Suite 200, San Francisco, CA 94105 Attn: Craig M. Stainbrook ' Fax 415/543-9000 415/543-8300 On behalf of: Ross General Hospital/The Clorox Co. - M cinem ey 4 Dillon, One Kaiser Plaza, 18th Roor, Oakland, CA 94612 Attn: Carol K. Watson _' _ 510/465-7100 Fax: 510/465-8556 On behalf ot University Mechanical & Engineering Contractors M cLem ore, Collins 4 Toschi, 200 Webster S treet Suite 350, Oakland, CA 94607 Attn: Gregory M. Doyie . Far 510/835-3400 510/835-7800 On behalf oft Northwestern Equipment 4 Supply Co., Inc. . McNamara,. Houston, Dodge, McClure 4 Ney, 1211 Newell, Suite 202, Walnut Creek, Mailing: P.O . Box 5288, Walnut Creek, CA 94596; Attn: Thomas E. Pfalzer Fax 510/939-5330 5--1--0--/9--3--9-0203 On behalf ot.S t Joseph's Hospital/Congoleum/Dap, IncJPlibrico Sales 4 Service, IncJSutter Memorial Hosortal/Sutter General Hospital/FMC CorpJDameron Hospital/American Terrazzo Co. -- M cNam ara, Houston, Dodge, McClure 4 Ney, 1211 Newell, Suite 2 ^ , Walnut Creek, S10 39-K30 rM aping: P.O . Box 5288, Walnut Creek, A 94596, Attn: Douglas C. McClure .F a x _ 510/939-0203 -.O n behalf oft niryal, Inc. ' . ' - - ,,,, _ Mencfes~& Mount 725 South Figueroa Street 19th Floor, Los Angeles, CA 90017 -A H n : Suzanne N. McNutty/Richard Nelson - Fax r On behalf oft Lockheed CorpJBP Chemicals (HlTCOyCurtis-Wright Carp. M iller, Morton, Caillat 4 Nevis, 50 W . San Fernando S t, Suite 1300, San Jose, : CA 95113, Attn: Pamela J. Silberstein ' - Fa3C --On behalf oft.B.T.Mandni Co., IncJBrookman Co. ' \ nn ~ ' Misciagna & Colombatto, 27 Maiden Lane, 4th Floor, San Francisco. CA 94108 ."ttri: P.Fchard Colombatto ' On behalf of: Metalclad Insulation Co. - ~- ^ ' *213/955-7700 213/955-7725 408/292-1765 408/292-4484 415/391-6182 f * 1 5/391-2904 M itchell, S iib eiterg 4 Knupp, 11377 West Olympic Boulevard, Los Angeles, CA 90064-1683, Attn: Hayward J. Kaiser 310/312-2000 Far 310/312-3100 On behalf of: Shapco, Inc. ,,_ . _ Moore 4 One Embarcadre Center, Suite 1200, San Francisco, CA 94111 Attn: Robert Moore Fax* . 415/394-7004 415/981-1592 On behalf oft. Claremont Hotel Corporation Morgenstern 4 Juberer, One Market Plaza, Spear Street Tower, 32nd Floor, 415/896-0666 San Francisco, CA 94105, Attn: Charles LaGrave F a r 4.15/8_9--6----5--592 On behalf oft Owens-tilinofe/Crosby Steam 4 Valve C o X ath edral Hill Hotel, IncJSan Frandsco Ladies' Protection 4 Relief Sodety/Libbey-Owens-Fordff'Uldngton Aerospace/Sammons/Dixon Boiler W orks, Inc. Morton 4 Lacy, Three Embarcadre Center, Suite 2280, San Frandsco, CA 94111 4155//229966--990000C0 Attn: Alan E. Lacy F a r 415/398-3205 On behalf oft E H . O'Neill Co., IncJXE. Steigerwald . M unger, Tolies 4 Olson, 33 New Montgomery Tower, .19th Floor, San Francisco: 415/512-4000 CA 94105-9781, Attn: M. Elizabeth Deane Pzc 415/512-4077 On behalf oft Tennessee Gas Pipeline Company N icol & Isaac, 4002 22nd Street, San Francisco, CA 94114, Attn: Lisa Nicol 415/821-4497 On behalf oft California Safety 4 Supply Co. . O-Brien 4 Hammond. 220 Sansome S t, 7th Floor, San Francisco, CA 94104 Fa3C 415/821-0791 415/362-2040 Attn: James D. Hammond _ 3X1 . 415/362-1050 On behalf oft LaSalle Deitch Co., IncAlniversal Foods CorpJNabtsco Brands/B.F. Goodnch O 'Connor Cohn, Dillon 4 Barr, 101 Howard S t, 5th Floor, San Frandsco, CA 94105 4157281-8888 Attn* Mark Oium ' F a r 415/281-8890 On behalf oft Federal-Mogul CorpA/alien Safety Supply CoJAiliedSignal (Allied ChemicaI)/Vapor CorpJ Walgreen Co. . . O rrick, Herrington 4 Sutcliffe, 400 Sansome Street, San Francisco, CA 94111 Attn: James R. Madison Fax* On behalf of: Grove Valve & Regulator Co. , ene O tis 4 Hogan, One Maritime Piaza, Suite 1600, San Francsco, CA 94111-3506 Attn: J. Morrow Otis . Fai On behalf of: WTl Rust Holdings, IncJRust Industrial Services, IncJRalph M. Parsons Co. Pace Dryw all, Legal Department P.O. Box 573, Concord, CA 94522 Fax: Pacific Bell Legal D ept, 140 New Montgomery S treet Suite 1015, San Frandsco, CA 94105, Attn: Gerard J. Donnellan r . Fax: Paetzold, W hite 4 Brodsky, 101 California S t, Suite 1875, San Francsco, CA 94104 415/392-1122 415/773-5759 415/362-4442 415/362-7332 510/602-0900. 510/602-0905 41S/542-2880, 415/882-4458 415/249-0966 415/249-0964 o T b S S io ftfa S S a Brands/American President Lines/EJ. Barteils. CoJPheips Dodge Industries/ Todd Shipyards ,, , - .. Pave, M cCord, Jaeobs 4 Berkes, 15303 Ventura Boulevard, Suite 1400, Sherman Oaks, CA 91403, Attn: Mark W . Lau 818/783-8820 Fax 818/78^-0959 On behalf of: California Portland Cement C o X a lM a t CoAndustnal Asphalt Perkins C o fe^i999 Avenue of the Stars, 9th Floor, Los Angeles, CA 90067-6109 -A ttn : Sibyl D . Marshall Fa3C 310/788-9900 . 310/788-3399 On behalf oft Custodts-Cottrell, Inc. -'-^PainllsFbruarny,^Mf Madri'sonC4 A 9 4 Sutro,225 Bushp S t,, S^an tF orand rscot94e10 B a s 4; Mailing: aP.O. iBoFxa738C80, 415/983-1000 - O nbehlf oft Bethlehem Steel Corp. ` - - - ; Pillsbury, Madison 4 Sutro. 400 Capitol Mall, Suite 1700, Sacramento, CA 95814 Attn: Benjamin Webster/Frank SiegRtz. ... . Far 916/441-0868 916/441-3583 _ On behalf oft Aerojet General Corp. ' ' - Pittsburgh Coming Corporation, 800 Presque Isle Dr., Pittsburgh, PA 15239 ' Attn: Gerald A. DeSimone -- , Far ' Pond, Shjeflo 4 W ohl, 1730 S. S Camino Reai, 6th Floor,San Mateo,CA 94402 . Attn; Michael A. Fox ............................................... ................... - - - - Far 412/733-3838 412/733-5849 415/341-2901 415/341-2258 = O n behalf oft Thorpe Insulation Co. -n====icrr - - .-- ----r rn r r r tr r r : Popefka, A llard, McGowan 4 Bondonno, 160 W . Santa Clara S t, 12th Floor, SanJose, CA 95113-1721, Attru John P.Cardosi 408/298-6611 Fax: 408/275-0814 On behalf oh Giampofini & Company Porter, S cott, W eiberg 4 Dalehard. 350 University Avenue, Suite 200, Sacramento, 916/929-1481 CA 95865, Attn: EBsa Ungerman . F3*: 916/927-3706 On behalf oh Economy Lumber Co./Minton's Lumber & Supply CoiANCO Insulations, Inc. Porter, S cott, W eiberg 4 Delehard, 350 University Avenue, Suite 200, Sacramento, 916/929-1481 CA 95865, Attn: Craig A. Caldwell Pax: 916/927-3706 On behalf oh Van Housen Auto Parts Pray, Price, W illiam s 4 Russell, 555 East Ocean Boulevard, Suite 810, Long Beach, CA 90802-5055, Attn: Bruce Bothwell 310/436-1231 Fax: 310/435-6384 On behalf oh Bay Cities Crane & Rigging, Inc. Preuss, W alker 4 Shanagher, 595 Market S t, 16th Floor, San Francisco, CA 94105 - .415/978-2600 Attn: Thomas W . Pulliam, Jr. F ^ 415/978-2513 On behalf oh American Honda Motor Co., InciMarsh & McLennan, InciLac rfAmiante du Quebec, U ee/ HolDngsowrth 4 Vose/Monsanto CoJHobart Corp./Federated Metals-ASARCO Prindte, D ecker 4 Amaro, 369 Pine Street, Suite 800, San Francisco, CA 94104 415/788-8354 Attn: Mary Kirk Hillyard Pax: 415/788-3625 On behalf oh Auburn Manufacturing CoiAJ3. Boyd CoiArgo International CorpJBode-Gravel C o i W heeler Protective Apparel/J.T. Thorpe, InciJ.T. Thorpe & Son, InciHajoca CorpiM.H. Detrick Coi Frederick Meiswinkel, InciD . Cummins CorpiGerber Products, InciSyd Carpenter Marine Contractors/ Pacific Bell/Lockheed Corp/Tri Valley Growers/Playboy Enterprises/Mervyn's/GUlon Lumber CoTFeuer C orpi Gangi Brothers-Packing CoiHenry Vogt Machine CoiGeysar Peak Winery/Famiiian CorpiSouthem Talc/ American Housing Guild/Bird CorpJBoise Cascade/Mayta & Jensen/Powerline Oil CoJEtemit In ci American Biltrite, InciDean's Material, Inc. d/b/a Construction Material Suppliers, IncJHayward Lumber Coi Kaiser Steel Resources/Champion Industrial Contractors/Singer Safety CoiPowerline Oil C o i Robertshaw Controls C aiSeal Methods, InciPillar Industries, InciD el Webb Corporation Prusik, Selby, Daley 4 Swan, 303 W. Madison S t, Suite 1600, Chicago, 1L 606C6 On behalf oh W heeler Protective Apparel . Pax: Raifman 4 Edwards, 131 Steuart Street Fourth Floor, San Francisco, CA 94105-1230 Attn: Jon Logan Edwards -- Fax: On behalf oh American Crane & Equipment Corporation : Rankin, Sproat 4 Pollack, 1800 Harrison S t, Suite 1616, Oakland, 94612, Mailing: P.O.Box28765, Oakland, CA 94604, Attn: Thomas A. Trapani Fax: 312/553-4700 312/553-0332 415/284-6700 415/284-6701 510/465-3922 510/465-3006 On behalf oh Peninsula Hospital/Caiifomia Pacific Medical Center/Ralph K. Davies Medical Center/ " S t Mary's Hospital/St Luke's Hospital/John Muir Hospital/Summit Medical Center/Alta Bates Hospital/ ML Zion H ospital/St Francis Hospftal/Sutter Health Padfic/Sutter Memorial Hospifal/Sutter General Hospital/ Reisinger 4 McAuley, 1050 Northgate Dr., Suite One, San Rafael, CA 94903 415/499-1033 Attn: Jerry L Williams P3^ 415/499-0329 On behalf oh San Pablo Plumbing CoVNoble Auto Parts/J.G. MacPhee Co. Rice, Fow ler, Booth 4 Banning, 275 Battery Street, 27th Floor, San Frandsco, CA 94111, Attn: M .F elid a Gay ...... On behalf oh Mobil Oil Corporatiorr/Dorr-Oliver, InciMatthew G . Norton Co. Rfvkin, R ad ler 4 Kram er, Post Office Box 14609, Santa Rosa, CA 95402 415/399*3191 Fax: 415/399-8192 ; ~ . ...... 707/576-8033 Attn: Christopher A. Crevasse . F a r 707/576-7955 On behalf oh Kimberly-Clark C o rp iD A R . Industrial Products, Inc. : - - : *: - Ropers, M ajeskI, Kohn 4 Bentley, 670 Howard Street, San Frandsco, CA 94105 - _415/543-4800 Attn: John Curran Ladd _ ..Pax: -.415/512-1574 - On behalf oh The Cannery/Cyprus Amax Minerals CoiCalfox, InciGeneraf American Transportation C orpi Porter W arner Industries, IncJEV. Roberts & Associates, InciThe Bank of Califomia/Grinnell C o rp i . _ Embarcadero Center Assodates/Wesfinghouse Electric Corp./Rome Cable CorpiOinwidcfia Constructioni ^ Genuine Parts CoiG las-C ol Apparatus CoiOakhiil Improvement CoiOahu Sugar CoiLucky Stores/Faideniial Insurance Company of Amgrica/Califomia Safety & Supply Mark H. R osenthal, Esrffito-fiatrfomta-St^-SQth-ffeor.San Frandsco, CA 94111 On behalf of. Crown Cork 4 Seal 4 2 5 35C& - - 415/986-1364 - Fax: __415/362*1945-- _ . Rust, Armenis, Schwartz, Lamb 4 B ills, Post Office Box 41958, Sacramento, CA 95841, Attn: Duane Skelton Fax On behalf of. Melrose Lumber Suppiy/Tynan Lumber C o., lncJnton's Lumber & Supply S&P Company, 100 Shoreline Highway, Building B, Suite 315, M3I Valley, CA 94941 Attn: W iliam M. Bitting Fa3C 916/972-8300 916/972-7878 415/332-0550 415/332-9023 On behalf o f General Brewing Co./Lucky Lager Brewing Co. . . S t Clair, McFetridge 4 G riffin, One Montgomery S I, Suite 1400, San Francisco, CA 94104, Attn: Anthony Griffin FaJC 415/421-2462 415/421-2462 On behalf o f Bank of America NT & SA S t Peter 4 Cooper, Three Embarcadre Center, Suite 2900, San Francisco, CA 94111 Attn: Michael S t Peter Fax: 415/955-0700 415/955-0711 On behalf o f ACandS, Inc. S ack and Associates, 1433 Webster S treet Suita 200, Oakland, CA 94612 Attn: William S. Miller Fax On behalf o f Ralph M. Parsons Go./Chicago Bridge 4 Iron Co. Sainick 4 C ote', 190 Newport Center Drive, Suite 100, Newport Beach, CA 92660 Attn: Frederick B. Sainick Fax 510/444-6453 510/444-3753 714/644-9400 714/644-1142 On behalf o f San Joaquin Refining * Samaha, Grogin, Stuiberg, 35 North Lake Avenue, Suite 810, Pasadena, CA . 91101-1856, Attn^Thomas J. Samaha . Fax: On behalf o f Hood Corporation ` _, . Sarrail, Lynch & Hal!, 44 Montgomery Street 34th Floor, San Francsco, CA 94104 Attn: Brian D. Harrison Fa!C 818/584-1388 818/584-6664 415/398-2404 415/391-9076 On behalf o f Safeway, inc. . Scadden, Hamilton & Ryan, 580 California S t. Suite 1400, San Francsco, CA 94104 Attn: Greg Mitchell 415/362-5116 415/364-4214 . On behalf o f Supra. Inc/Trans-European Motois/EHiott Co/Exceisior, Inc/Bank of California/ Dover Resources/EG&G Sealol, Inc/Alfred Conhagen, Inc/Foster Wheeler Corp/Riley Stoker Corp/ Uberty Mutual Insurance Co/Vattey Nitrogen Producers/Greene Tweed Co/Southem California Jobbers/ National Auto Parts/HJ . Heinz Corp/Nestie Food Co/Durametallic CorpTColgate-Palmolive/ United Technologies Corp/Robertson-Ceco Corp/Clayton Industries Schaffer & Lax, 5757 Wilshlre Blvd., Suite 600, Los Angeles, CA 90036 Attn: Kevin J. McNaughton 213/934-4300. Fax: 213/931-5680 On behalf of: U.S. Mineral Products Co. Schofield & Schiller, 100 Pringle Ave., Suite 510, Walnut Creek, CA 94596 Attn: Carol Meyer . .. 57510/934-3600 0 - - -- On behalf o f Kelly-Moore Paint Co/Regents of the University of Califomia/Airport Auto Parts, Inc/Farm ers Underwriters Assocsation/Peck Jones Construction C o/C .L. Peck Contractor Schuler & Kessel, 3435 Wilshire Boulevard, Suite 1970, Los Angeles, CA 90010-1901 213/365-0924 Attn: Elizabeth M. Kessel ' Fax 213/365-0938 On behalf o f Aluma Systems Schwabe, WilHamson & W yatt. 1211 SW Fifth Ave., Suites 1600-1950, Portland, ^ . S03 g-9981 O R 97204-3795, Attn: M argaret Hoffman _ ` : " r - F ax 501/796-2900 On behalf of. Oregon Steer Milts ~ Sedgwick, D etert, Moran 4 A rnold. One Embarcadre Center, 16th Floor, -,nnn 415^81-7900 San Francsco, CA 94111, Attn: Holly A. Hams . ^ On behalf o f Scandura, IncjHennessy Industries, Inc/lngalis Shipbuilding/Standard Od of Cafifornia/ .. Shell Oil Ca/Soco-Lynch Carp/G eneral Hectric Co/Phillips Petroleum Co/Pacific Gas S Electric C o / Chevron, U.S A , Inc/Glass Containera Corp/ConsoHdated Irsulation/HawaBan ElectridSierra Pacific/ CPCtntemational/GuifOil / r - - . . - ; " . : , 2 .' S edgw ick, D etert, M oran 4 A rnold, 801 South Figueroa S treet 18th Floor, Los Angeles, 213/426-6900 CA 90017-5556, Attn: John R . Burge Fax 213/426-6921 On behalf oft Caterpillar, Inc. - ; - - - ......................... .vj; .... ' L Seyfarth, Shaw, Fairw eather i Geraldsen, 101 California Street Suite 2900, - - _ - ~ 415 97-2823 San Francisco,CA94111,AttmPeter_EJRomo ^ .... . . . . _ _ v. _ 7 :Fai - -.415/?9.7"8549. On behalf o f Mam'otrCorp/NewportNews Shipbuilding & Dry Dock Co/Bay Decking Co.,-inc. ... - -j n -- ~ r ." * . _ w1 -- Daniel M. Shapiro, Attorney at Law, 333 South Grand Ave., Suite 2850, Los Angeles, CA 90071 Par On behalf o f Calmar Distributing Co., Inc. Shea & Gardner, 1800 Massachusetts Avenue N.W ., Washington. D.C. 20036 Attn: Laura Quinn Fax: On behalf of: Rockwell International . Sheppard, Muffin, Richter & Hampton; Four Embarcadero Center, 17th Floor, San Francisco, CA 94111, Attn: Gary J. Nevolo . Fax: On behalf-ot American Optical Co. Sheppard, Muffin, Richter & Ham pton, Four Embarcadero Center. 17th Floor, San Francisco, CA 94111, Attn: John F . Runkei, Jr. Fax: On behalf o f American National Can Co. Sidley & Austin, 555 West Fifth Street, Los Angeles, CA 90013-1010 Attn: Alan Au On behalf of. Midwest Power Systems S inclair & H ill, Post Office Box 992710, Redding, CA 96099-2710 Attn: Craig A. Sinclair (100 e. Cypress Ave., Suite 200) On behalf o f Mercy Medical Center/Mercy Hospital of Redding Skeet, Henke, Evenson & Roberts, 900 Fourth Avenue, Suite 3801, Seattle, WA 98164. Attn: Eric Richter Fax Fax Fax On behalf o f Olympic Steamship C o. ' Sorem & Pastore, 2565 Camino del Rio South, Suite 101, San Diego, CA 92108 Attn: Joseph A Pastore Fax: On behalf of. Fryer-Knowles, Inc. Southern Pacific Transportation Co, Law Departm ent, 10860 Gold Center Dr.. Suite 410, Rancho Cordova, CA 95570, Attn: Mfchaef L Johnson Stark, W ells, Rahl, Schwartz & Schieffer, 1999 Harrison Street, Suite 1300, O akland, CA 94612, Attn: May Lee Tong Fax Fax: 213/625-7400 213/625-0303 202/828-2000 202/828-2195 415/434-4914 415/434-3947 415/434-4914 415/434-3947 213/896-6000 213/896-6600 916/226-9700 916/226-9481 206/823-1031 206/628-2033 619/574-1545 619/574-1200 916/789-5824 916/789-5827 510/834-2200 510/763-5121 On behalf o f Cassiar Mining Corp. Steele & Sales, P.C., 700 5th Avenue, Suite 5511, Seattle, WA 98104 Attn: Katherine M. Steele ' Fax_ 206/682-2202 206/682-1224 On behalf o f E.J. Bartells Co. . Steefel, Levitt & Weiss, One Embarcadero Center, Suite 2900, San Francsco, ' CA 94111, Attn: Barry W . Lee , t ,, . Fax: On behalf o f Cal-Steam/Westbume Supply, IncJMoran Supply/Plumbers Supply 415/788-0900 415/788-2019 - Sterling & Clack, 101 Howard Street. Suite 400, San Francisco, CA 94105 415/54^-5300 ' Attn: Rex M. Clack Fax: On behalf o f Olympic Steamship CoTPope & Talbot Inc. Stevens, Drummond & Gifford, 1910 Olympic Boulevard, Suite 250, Walnut Creek, 415^43-3335 . - _____ '5 10^44-5350 _ " CA 94596, Attn:'David A Gifford F a r S1 ^ f '9669 On behalf o f North American Refractories CoJAetna Rubber & Suppiy/Asbestos Corporation, LtdJ . ~ Wagrxer Electric CorpJBell Asbestos/Azrock Indushies/Cooper industries, Inc. . - - - F ran cis J;StiH m an, Attorney at Law , 1601 8ayishore Highway, Suite 301. . - - ' ^B uiifrlg irn efC A 94010 ------- ~ - -- Fax ^ 4 15 /6 92 -9 14 4 - ... On behalf o f Montgomery, Ward & Co. __ _ _ ................ ^ S tu n S o s lfM a s o n , 2151 River Plaza D r., Suite 100, Sacramento, CA 95833 -- --9 1 6 /5 6 7 -8 2 1 1 - z=^Maifing:P.O;- Box 868.Sa(sram eriftn.CA95804.Attn: Br ad' Tbomas. . ^-- '' r-.-O rT b eh aif o f Fruehauf Cor pJKel wi Hayes' Co; ^^. - -- --- ~ Sturgeon, Keller, Phillips & Gee, 388 Market S treet Suite 670, San Franosco, -:r I 415^53-0800 C A 94111, Attn:BrockD.Phillips c* _ * f j * -415/955-0810 ~ On behalf o f Atchison, Topeka & Santa Fe Railway CoJBurlington Northern RaHroad Co. Tarkington, O'Connor & O'N eill, One Market Plaza. Spear Street Tower, 41st Floor, 415^77-5301 SwaalnirFlrfalnlicUi5sKc<oy|, WCAn94105, nAuttnn.: Deborah Lmdblom _ * . Fax 415/546-4962 V- ;OThnabyeehraHlf oarf.vWeye,sHteornd dBerra&keG/Frrefcgfieorns,eIhnc.1J1im0p0eFrioaul rHteoellnythCoSrtpre. (eHtoSlluyitSeuFg.aMr)odesto, - ,, nn T ~ ~ 209/523-3300 T C ^ 9 5 3 5 3 ^ a ifc R i.rBor3465,M od0sto7CA 95353), AttnrJanet B. Hodder -- Fex: ^ 2 0 3 /5 Z W 3 9 9 _O n behalf o f Roseville Teiephone Com pany__________ ___ - wrrat:;-*.. v->. ~13 -_ i Thelen, M artin, Johnson 4. Bridges, Two Embarcadero Center, San Francisco, 415/392-6320 GA 94111. Attn: Jennifer A. Kuenster Fax: 415/421-1068 On behalf oft Kaiser Aerotech/Kaiser Aluminum & Chemical Corp/Bechtel Corp./Sequoia Ventures, IncJ Robert E. McKee, Ino/Kaiser Center, Inc/M ack Trucks, Inc/Frem ont Group, Inc. Thelen, M arrin, Johnson & Bridges, 333 South Grand Avenue, 34th Floor, 213/621-9800 lo s Angeles, CA 90071, Attn: Paul Lax Fax: 213/623-4742 On behalf oft M.W. Kellogg/Dresser Industries,. Inc. Thom pson 4 Heller, 400 Capitol Mall, 26th Floor, Sacramento, CA 95814 916/498-7300 Attn: Phfitip Bonotto Fax: 916/498-7350 On behalf oft Vailumoid, IncJHopeman Brothers/Great Lakes Carbon Corp/Hcor Title Insurance C o / Dravo Corporation/Federated Department Stores ' Tffly 4 Graves, 500 Washington S t, Suite 86 , San Francisco, CA 94111 Attn: Patrick O'Keefe 900 415/955-3925 Fax: 415/955-8933 On behalf oft Owens-Coming Fiberglas Corp. Tim e Oil Company, P.O. Box 2447, Seattle, W A 98124 Attn: Ron Kokesh Far TIM EC Company, 155 Corporate Place, Vallejo,. CA 94590, Attn: Brent A. Babow (The Industrial Maintenance Engineering Co.) Far T itchell, Maftzman, Mark, Bass, Ohleyer & M ishel, 650 California S t, 29th Floor, San Frandsco.CA 94108, Attn: Philip B. Bass/Richard C . Insaiaco Far 206/285-2400 206/286-4488 707/642-2222 707/648-2719 415/392-5600 415/981-5027 On behalf oft M ierican Brass & Iron Foundry Vogl 4 M eredith, 456 Montgomery SL, 20th Floor, San Francisco, CA 94104 415/398-0200 Attn: Jean Yeh 4-1--5--/-3--9--8-2820 On behalf oft American Asbestos Co./Pacific Pipe/ San Mateo Lumber CoJAvocet Enterprises, IncJ Pacific Supply CoJW.E. Mushet Co. W alsw orth, Franklin, Bevins & McCall, 580 California Street, Suite 1335, 415/781-7072 San Francisco, CA 94104, Attn: Robert M. Channel Fax: 415/391-6258 On behalf oft Bishop Wholesale, InciFriction Materials, Jnc/Califomia Builders Hardware/Dowman Product/ Pacific Holiday Towers, lidVHamilton Materials/Selby, Battersby & Co./Daniel Smith Plastering, In c / Western W ater Works/Southem California Edison Co/Thom as Dee Engineering CoJQuintec Industries/ Rite Engineering Manufaciuring/Stanley Folb,4nc/K.R. Anderson/American Chemet Corp/Supreme Auto Parts/Saberhagen Holdings, Inc. (The Brower Co.)/Carter CoJSan Diego Gas & Eiectric/Sondex . . Intemational/Custom Building Produds/Martin Madsen Co-/Baltimore Ennis Land CoJMacAulay Foundry, IncJW .W . Henry Co. W alsw orth, Franklin, Bevins 4 McCall, 1 City Boulevard W est Suite 308, Orange, CA 92668-3604, Attn: Michael T. McCall 714/634-2522 F ar 714/634-0686 On behalf oft Gibson-Homans W hite, Gorman 4 Baker, One Market Plaza, Spear Street Tower, 8th Floor, San Frandsco.C A 94105, Attn: M argaretT. Gorman - 415/541-3720 F a r 415/541-3738 On behalf oft 870 Market Street Associates/Anchor Brewing Co/Diana Fruit Co./American Energy Products/Kaies & Symons/Haskell Corp./Big B Lumberteria/Lindsay International, IncJStructural ^ - Coating J n c/B lio tt Glove CoJG eorgeP-ReinUesCo.. Inc. " 'W illiam s,R om anskf,P ofverari4 Skelton, 152 North Third S t,S u ite 600,...... 408/275-8262 ~S an'Jbsb C A 9 5 1 1 2 , Attn:Alan J.Zapala -- F a r 408/294-6707 " AlliecTPaSting'SSupply : - - On behalfoft Epoxyfite CorpJBay Rubber CoJYrueta Drywall 4^Pain1lng/Basco Drywall & Painting C o / --W ils o n E lser Moskowitz, Edelm an4 D ic k e r,650 Cafifamia S treet 14th Floor, _ L 415/433-0990 ~_san Francsca.C A 94108, Attn: Colleen A. Peck . ; 3 - 415/434-1370 " On behalf oft Kubota CorpJDurabla Mfg. Co., Inc/Asbestos Products Mfg. CorpJH&A Construction C o rp / -Asbestospray - : . - ;r .'.j. 1 .._ . _ ta w Offices o f Robert K. W right 301 N. Lake Ave., Suite 700, Pasadena, CA 91101 ' On behalf of: The Budd Company _ 40^ Fax: W right, Robinson, McCammon, Osthim er 4 Tatum , 44 Montgomery S t, 18th Floor, "-S anFrancfeco.C A 94104,Attn:MarkP.Krinsfcy - Far r --:wOrirtobeenhaaulf 0o1f:. SanuFrancisco GVrav-el CoAK-S._G uer_in, C o- -- ---------------------- -- - -- W ngfii.R obinsorti McCammon, O sthim er & T a tu n v ^ Montgomery St*Jpth Floor, * San Frandsco, C A 94104. Attn: Myles E. Fladager ' Far 818/796-2664 818/796-1601 415/391-7111 415/391-8766 : 415/391-7111 415/391-8766 : On behalf oftJFreightiiner Corp. -3 - t -V-- ~ - .