Document X7MaZ7OyNB6M0rGLqoZomMbx

PLAINTIFF'S EXHIBIT CAUSE NO A-134,614 FRENCH HICKS, ET AL. VS . BETHLEHEM STEEL CORPORATION, ET AL. S S IN THE DISTRICT COURT OF JEFFERSON COUNTY, TEXAS 58TH JUDICIAL DISTRICT DEFENDANT'S ANSWERS TO PLAINTIFFS' NOVEMBER, 1990 INTERROGATORIES To: Plaintiffs, and their attorney of record, JOSEPH C. BLANKS, of Reaud, Morgan & Quinn, 909 Laurel Street, Beaumont, Texas, 77701: COMES NOW ETHYL CORPORATION, Defendant in the above- entitled and numbered cause of. action, and would make and file this its Answers to Plaintiffs' Interrogatories as follows: --o SEE ATTACHED. Respectfully submitted, HAYS, McCONN, PRICE & PICKERING t** B. V<5tate STEPHEN Bar No. RfCE _ 16838000 <50*1 400 Citicorp Center Houston, Texas 77002 (713) 654-1111 Telecopier: 655-9212 ORGAIN, BELL & TUCKER* Texas Bar No. 10868500 470 Orleans Street Beaumont, Texas 77701 (409) 838-6412 Attorneys for Defendant, ETHYL CORPORATION CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the above and foregoing instrument has been sent certified mail, return receipt requested and/or hand delivery to Joseph C. Blanks, of Reaud, Morgan & Quinn, 909 Laurel Street, ^Signed by permission 082L/97 GENERAL OBJECTION Defendant objects to these interrogatories on the basis that they are overly broad and not limited in geographic scope to the plants located along the Texas Gulf Coast in which the Plaintiffs claim to have been exposed to asbestos. INTERROGATORIES NOTE: Pursuant to the agreement of the parties, these interrogatories are construed to apply only to the original construction of the subject premises and to the general contractor and insulation contractor for the original construction. 1. State in which years the subject premises owned or ever owned by you were constructed. ANSWER: 1951-1952. 2. Identify the general contractor for the construction of your subject premises. ANSWER: C.F. Brown. 3. Identify the insulation contractor for the initial construction of your subject premises. ANSWER: Unknown. 082L/92 STATE OF LOUISIANA PARISH OF EAST BATON ROUGE BEFORE ME, the undersigned authority, on this day there personally appeared David C Bach, who, after first being duly sworn by me, did depose and state that he is the Assistant Counsel for Ethyl Corporation, a Defendant in the above styled and numbered cause, that based upon information and beliefj the above and foregoing Answers to Plaintiffs' Interrogatories are true and correct. SWORN TO and SUBSCRIBED, before me, this 7th day of December. 1990. Stary Public in ana fqj State of Louisiana My commission is for life. EENA M- LANGLOIS PI1BUC