Document XRxE7xMQrOM0X6ONkG5adwVYx

IN THE COURT OF COMMON PLEAS CUYAHOGA COUNTY, OHIO ANTHONY M. GRECO, et aL, : Plaintiffs, : vs. : A-BEST PRODUCTS COMPANY, et aL, : CASE NOS.: 323629 - 323678 JUDGE HARRY HANNA IN RE: ALL BARON & BUDD ASBESTOS CASES UNIROYAL, INC.'S ANSWER TO PLAINTIFFS' FIRST MASTER SET OF INTERROGATORIES PROPOUNDED TO DEFENDANT. UNIROYAL. INC. Pursuant to the Ohio Rules of Civil Procedure, Uniroyal, Inc. ("Uniroyal"), supplements its response to these interrogatories propounded by Plaintiffs as follows: GENERAL OBJECTIONS 1. Uniroyal objects to the disclosure of lawyer-client privileged communications. 2. Uniroyal objects to the disclosure of work product. 3. Uniroyal objects to the Definitions section of Plaintiffs' Discovery on the grounds that it is overly broad and oppressive and exceeds the scope of discovery permissible under the Ohio Rules of Civil Procedure. 4. Uniroyal objects to any interrogatory which seeks information about any asbestos containing products it may have manufactured or sold because the plaintiffs have not produced any evidence of exposure to any Uniroyal or United States Rubber Company asbestos containing products. . PRELIMINARY STATEMENT Each of the requests responded to here refers to defendant Uniroyal as "Defendant," "you," or "your". Unless otherwise expressly stated in these responses or properly called for by a specific request, the responses to these requests are given with the understanding that the terms "Uniroyal," "defendant," "you," "your," "your business" aiid "predecessor" refer to the entity(ies) which operated under the following names: Uniroyal, Inc. and United States Rubber Company. Uniroyal filed a certificate of dissolution with the Secretary of State of New Jersey on December 2,1986. It has not engaged in any business since that time, it has no employees and it exists solely for the purpose of winding up its affairs. Consequently, much of the information > requested in these requests, if it ever was in the possession or control of Uniroyal, is no longer available. Despite these limitations, after reasonable search and inquiry, Uniroyal has made good faith responses to these interrogatories based upon what information is available-and in keeping with the nature of these interrogatories. However, the above-mentioned limitations on Uniroyal's information have required that each of the following answers is based only on the information and belief of the person verifying these answers. This preliminary statement is incorporated as a portion of each and every answer herein. 2 ANSWERS TO INTERROGATORIES INTERROGATORY NO. 1: For each Interrogatory below, please state the name and last known address of each person answering it, including whether he/she is employed by Defendant and if employed by Defendant included job title, length of time employed by Defendant and a year by year list of all other positions, titles, or jobs held when working for Defendant. ANSWER: Subject to, and without waiving the foregoing general objections, Uniroyal answers as follows: Uniroyal's answers are based on an ongoing review of Uniroyal's documents and information obtained from ongoing discussions with various Uniroyal personnel over a period of \ years. The information contained herein has been assembled by employees and counsel for Uniroyal over many years time. It is not possible to reconstruct each step taken to gather this information, to identify by name each person who could be said to have furnished the information upon which an answer is based in whole or in part, or to identify all documents that may have provided information upon which an answer is based in whole or in part. Uniroyal reserves the right to amend these answers on the basis of any further information that is obtained. INTERROGATORY NO. 1.1: Please identify all documents used, related to, or referred to in connection with the preparation of or answers to these Interrogatories and state the number of the Interrogatory and its subpart to each such document. ANSWER: See ANSWER to Interrogatory No. 1. 3 INTERROGATORY NO. 2: Please state whether or not Defendant is a corporation. If so, please state: (a) Your correct corporate name; (b) The state ofyour incorporation; (c) The address of your principal place of business; (d) Your registered agent for service in the State of Ohio; (e) For each Defendant claiming that this Court lacks person jurisdiction, list year by year the total amount of income received by the Defendant from entities in Ohio, any and all years that Defendant, as defined, has been licensed to do business in Ohio, and any real property owned at any time by Defendant or its present or past subsidiaries. ANSWER: In addition to die foregoing general objections, Uniroyal objects to this v interrogatory on the grounds that it is ambiguous, overly broad, unduly burdensome, and the information sought is beyond the scope of discovery permissible under the Ohio Rules of Civil Procedure. Subject to, and without waiving these objections, Uniroyal answers as follows: Uniroyal, organized as a New Jersey corporation in 1892 under the name of United'States Rubber Company, filed a certificate of dissolution with the Secretary of State of New Jersey on December 2,1986. Copies of each document granting authority are not readily available, but will be made available if and when discovered. INTERROGATORY NO. 3: State Defendant's complete corporate or business history, including dates of incorporation, mergers, consolidations, reincorporation, and the like. Also 4 provide historical information regarding all predecessors, prior names, asset purchases, acquisitions or spin-offs. In addition: a. If Defendant or any of its predecessors or subsidiaries at any time purchased or assumed any of the assets and/or liabilities of any corporation or entity which at any prior time engaged in the manufacturing or sale of asbestos-containing products, then please state the following as to each acquisition: b. The name or description of each corporation, entity or assets acquired by Defendant, that entity's state of incorporation and principal place of business, its date of incorporation, and the name of Defendant at the time of acquisition; c. The manner by which each such corporation, entity or interest therein, was acquired (e.g., merger, consolidation, change of name, stock sale, transfer or purchase of assets or product line); d. The date of each such acquisition; e. The state in which each such acquisition was effected; f. The state law governing each such acquisition if specified by contract; g. Whether Defendant;became legally responsible for the past torts of each such corporation or entity; h. Identify each document reflecting or related to the history and/or transaction(s) set forth in answer to this Interrogatory. ANSWER: See ANSWER to Interrogatory No. 2. INTERROGATORY NO. 4: Please state whether or not the Defendant has purchased, assumed, or in any other manner acquired any of the assets and/or liabilities of any corporation or entity (such corporations or entities being limited to those engaged in the mining, selling, manufacturing, marketing or distribution of asbestos-containing products.) If so, please state the following: a. The name or description of each corporation, entity or assets acquired by Defendant, its state of incorporation and principal place of business, its date of incorporation, and the name of Defendant at the time of acquisition; 5 b. The manner by which each such corporation, entity, or interest therein, was acquired (e.g. merger, consolidation, change of name, stock sale, transfer or purchase of assets or product line); c. The date of each such acquisition; d. The state in which each such acquisition was effected; e. The state law governing each such acquisition if specified by contract; f. Whether Defendant became legally responsible for the past torts of each such corporation or entity; ' g. Whether the acquisition concerned asbestos-containing products. ANSWER: In addition to the foregoing general objections, Uniroyal objects to this interrogatory on the grounds that it is beyond the scope of discovery permissible under the Ohio Rules of Civil Procedure in that it does not seek discovery of a matter relevant to the issues raised by the claims or defenses of any party and the information sought does not appear \ reasonably calculated to lead to the discovery of admissible evidence. Subject to, and without waiving these objections. Uniroyal answers as follows: Documents responsive to this inquiry, if any, may be made available for review pursuant to the Ohio Rules of Civil Procedure. INTERROGATORY NO. 4.1: For each corporation, other than the answering defendant ("the entity"), that has at any time in the past been involved in the placing of asbestos-containing products into the stream of commerce for which officers of the answering defendant's corporation have also served as officers, directors or served in any managerial position while employed by the answering defendant, state: a. The name ofthe entity involved in the placing of asbestos products into the stream of commerce; 6 b. The manner in which the entity was involved in the placing of asbestos-containing products into the stream of commerce (i.e., mining, milling, manufacturing, distributing, installing, rebranding, etc.); c. The specific products placed into the stream of commerce by the entity year by year and by brand or trade name; . d. The name, positions and a brief description of the responsibilities of the person or persons serving the answering defendant and the entity simultaneously including the positions held with the entity and with the answering defendant. ANSWER: In addition to the foregoing general objections, Uniroyal objects to this interrogatory on the grounds that it is beyond the scope of discovery permissible under the Ohio Rules of Civil Procedure in that it does not seek discovery of a matter relevant to the issues raised by the claims or defenses of any party and the information sought does not appear reasonably calculated to lead to th$ discovery of admissible evidence. INTERROGATORY NO. 5: Has Defendant ever engaged in the mining, manufacturing, selling, marketing, installation or distribution of asbestos-containing products? If so, please state the following: (a) The name of the company engaged in the activity (whether it is Defendant, Defendant's predecessor, or Defendant's subsidiary); (b) As to each product mined, manufactured, sold, marketed, installed or distributed, please state the following: 1. The trade or brand name. 2. Its identification number (model, serial number, etc.). 3. The time period it was manufactured, mined, marketed, distributed or sold. 4. Its physical description including color, general composition, and form. 5. A detailed description of its intended use and purpose. 6. A detailed description of the type package in which it was sold, listing the dates of each type of package used, a physical description of the package, and a description of any printed material or trademarks that appeared thereon. 7. The percent of asbestos which it contained. 7 8. The percent of asbestos by asbestos type (amosite, crocidolite, tremolite, anthophyllite). (c) The time period during which each of these product were on the market; (d) The material components/ingredients of each such product, giving specific or approximate percentage both by weight and by volume of each material component/ingredient (this interrogatory is not limited to the asbestos component ofthe product but seeks information as to the nature, weight and volume of non asbestos ingredients, as well) of each such product; (e) How each of these asbestos-containing products can be distinguished from those of competitors; (f) A description of the physical appearance of such product; (g) A detailed description of the intended uses. ANSWER: Subject to, and without waiving the foregoing general objections. Uniroyal answers as follows: Uniroyal manufactured asbestos yams, fabrics and tapes that contained asbestos from approximately 1941 until approximately 1976. Uniroyal manufactured various mechanical rubber goods containing asbestos from a date unknown until sometime prior to 1972. Uniroyal manufactured asbestos-containing rocket motor shields from 1959 to 1985. Documents responsive to this inquiry, if any, may be made available for review pursuant to the Ohio Rules of Civil Procedure. INTERROGATORY NO. 6: Does Defendant or any of its subsidiary companies claim that any patent would cover any product listed in answer to Interrogatory No. 5? If so, please state the following: (a) The date of each patent; (b) The date same was issued; (c) The number of each patent application that is pending. 8 ANSWER: In addition to the foregoing general objections, Uniroyal objects to this interrogatory on the grounds that it is vague and ambiguous, as well as beyond the scope of discovery permissible under the Ohio Rules of Civil Procedure. Subject to, and without waiving the foregoing general objections. Uniroyal answers as follows: Uniroyal's woven asbestos fabric - Patent No. 2,993,261L issued in July 1961. Uniroyal's asbestos yam - Patent No. 3,811,262 issued in May 1974. Uniroyal may have obtained other patents, however, it does not have documentation at this time regarding any patents other than the above described information. Documents further responsive to this inquiry, if any, may be made available for review pursuant to the Ohio Rules of Civil Procedure. INTERROGATORY NO. 7: Have any of the products listed above in answer to Interrogatory No. 5 been altered in chemical composition since first being marketed? If so, please state the following: .. (a) The trade name of each such product; (b) The date each such product was altered; (c) The nature of the alteration; (d) The reason for the alteration. ANSWER: Subject to, and without waiving the foregoing general objections, Uniroyal answers as follows: Documents responsive to this inquiry, if any, may be made available for review pursuant to the Ohio Rules of Civil Procedure. 9 INTERROGATORY NO. 8: Have any of the asbestos-containing products listed in ANSWER to Interrogatory No. 5 ever been marketed, distributed, packaged, labeled, and/or sold by any other company or business? If so, please state the Following: (a) The name and address of each such company; (b) The names and addresses of Defendant's distributors in Ohio and Illinois since 1940; (c) The date of each sale; (d) The name of the person at each location with whom you primarily dealt; (e) A list of all asbestos-containing products that you sold to each location from 1945 to 1980; (f) The amount of each; asbestos products sold to each location during this period; (g) Please identify all documents relating to this distributor for the particular location. ANSWER: In addition to the foregoing general objections. Uniroyal objects to this interrogatory on the grounds that it is overly broad and unduly burdensome. INTERROGATORY NO. 8.01: Has this defendant ever purchased asbestos-containing products from any other defendant? ANSWER: In addition to the foregoing general objections, Uniroyal objects to this request on the grounds that it is overly broad and unduly burdensome. Subject to, and without waiving these objections, Uniroyal states that documents responsive to this Interrogatory, if any, may be made available for review pursuant to the Ohio Rules of Civil Procedure. 10 INTERROGATORY NO. 8.02: If the Answer to the preceding Interrogatory is yes, please state the following: (a) Name each defendant from whom this defendant purchased any asbestoscontaining product; (b) List each product purchased from each co-defendant; (c) List the dates of each purchase of asbestos-containing products from each co defendant. ANSWER: See Answer to Interrogatory No. 8.01. INTERROGATORY NO. 8.03: Has this defendant ever sold asbestos-containing \ products to any other defendant? ANSWER: See Answer to Interrogatory No. 8.01. INTERROGATORY NO. 8.04: If the Answer to the preceding Interrogatory is yes, please state the following: (a) Name each defendant to whom this defendant sold any asbestos-containing product; (b) List each product sold to each co-defendant; (c) List the dates of each sale of asbestos-containing products to each co-defendant. ANSWER: See Answer to Interrogatory No. 8.01. 11 INTERROGATORY NO. 8.05: Has Defendant engaged in the manufacture and/or sale and/or distribution and/or marketing and/or supply and/or purchase and/or use of non-asbestos- containing products for use in connection with temperatures above 125 Fahrenheit since 1930. If so, please state: (a) The date such activity began; ' (b) The years during which such activity took place; (c) The date when such activity was terminated; (d) If such activity was terminated, the reason(s) why; (e) The geographical area into which you claim the product(s) were sold, purchased, or used; (f) Identify the organizational unit of defendant so engaged; (g) The site(s) at which each such product was manufactured; (h) The material components of each such product, giving specific or approximate percentage both by Weight and by volume of each material component of each such product; (i) The temperature ranges for which each product(s) was intended to be used; (j) The product's generic name; (k) The product's trade or brand name; (l) The container in which the product was shipped (i.e., paper bags, cardboard boxes) including the size and amount of the container; (m) A description of any logos, writing impressions or identifying markings which appeared on the product, as well as a description of the package used, the dates that type of package was used, and any logos, product names, trademarks, etc. which appeared on the package; (n) Whether the words "non-asbestos" or "asbestos free" were used on the package; (o) A detailed description of the intended method of preparation and application of the product; (p) A description of the physical appearance of the product, including size, shape, color and texture. ANSWER: In addition to the foregoing general objections, Uniroyal objects to this interrogatory on the grounds that it is beyond the scope of discovery permissible under the Ohio Rules of Civil Procedure in that it does not seek discovery of a matter relevant to the issues raised by the claims or defenses of any party and the information sought does not appear 12 reasonably calculated to lead to the discovery of admissible evidence. Without waiving those objections, we are aware that Uniroyal had some asbestos free product lines. Details, if any, concerning such product lines may be found in Uniroyal documents that may be made available for review pursuant to the Ohio Rules of Civil Procedure. INTERROGATORY NO. 8.06: Did Defendant ever market or distribute any asbestoscontaining product manufactured in whole or in part by someone else? If so, please state the following for each such product: ' (a) The name and address of the manufacturer; (b) The product's trade and brand name; (c) The organizational unit of Defendant who did so; (d) Date(s) beginning, ending and during which the marketing or distributing took place; (e) Whether the product was distributed through the same channels as those used for products manufactured by Defendant, and if not, please explain the exact channels , of distribution; (f) Identify all documents relating the marketing or distribution. ANSWER: See Answer to Interrogatory No. 8.01. INTERROGATORY NO. 8.1: Does Defendant have reason to believe that any of the asbestos-containing products listed in response to Interrogatory No. 5 were used at any of the sites listed on Exhibit A, attached hereto. If your answer is "yes", please state: (a) The basis of your answer; 13 (b) Please state which of Defendant's asbestos-containing products listed in Interrogatory No. 5 were used at each job site listed on Exhibit A. ANSWER: In addition to the foregoing general objections, Uniroyal objects to this interrogatory on the grounds that it is overly broad and unduly burdensome, as well as beyond the scope of discovery permissible under the Ohio Rules of Civil Procedure. Subject to, and without waiving these objections, Uniroyal answers as follows: Based on information and belief, no. Documents responsive to this inquiry, if any, may be made available for review pursuant to the Ohio Rules of Civil Procedure. INTERROGATORY NO. 8.2: For each company or business that Defendant knows may have marketed, distributed, installed, and/or sold, those products listed in response to Interrogatory No. 5, please state the following as to each job site on Exhibit A. (a) The name and address of each such company; (b) The dates of each sale from Defendant to such other company; (c) The name of the person at each other company with whom Defendant primarily dealt; (d) Names and quantities of the asbestos-containing products that you marketed, distributed, installed, and/or sold to each such company from 1950 to 1974; (e) Please identify all documents relating to the sales to each such company. ANSWER: In addition to the foregoing general objections, Uniroyal objects to this interrogatory on the grounds that it is overly broad and unduly burdensome, as well as beyond the scope of discovery permissible under the Ohio Rules of Civil Procedure. Subject to, and without waiving these objections, Uniroyal answers as follows: 14 Documents responsive to this inquiry, if any, may be made available for review pursuant to the Ohio Rules of Civil Procedure. INTERROGATORY NO. 8.3: If you do not know any business that may have marketed, distributed, installed, and/or sold the products listed in response to Interrogatory No. 5 to any of the jobsites listed on Exhibit A, please state the name and last known addresses of those companies who Defendant knows marketed, distributed, installed and/or sold their asbestos- containing products in Ohio from 1950 to 1974. For each of those companies, please state the following: ' (a) The name and address of each such company; (b) The dates of each sale from Defendant to such other company; (c) The name of the person at each other company with whom Defendant primarily dealt; (d) The names of the asbestos-containing products that Defendant marketed, distributed, and/or sold to each such company from 1950 to 1974. ANSWER: See Answer to Interrogatory No. 8.2. INTERROGATORY NO. 8.4: Does Defendant have records and/or any knowledge that reflects sales of their asbestos-containing products to any of the sites listed on Exhibit A, attached hereto? If so, please state the following as to each jobsite listed on Exhibit A: (a) The names and last known addresses of those people with such knowledge; (b) The location of such records. 15 ANSWER: In addition to the foregoing general objections, Uniroyal objects to this interrogatory on the grounds that it is overly broad and unduly burdensome, as well as beyond the scope of discovery permissible under the Ohio Rules of Civil Procedure. Subject to, and without waiving these objections. Uniroyal answers as follows: Based on information and belief, none. Documents responsive to this inquiry, if any, may be made available for review pursuant to the Ohio Rules of Civil Procedure. INTERROGATORY NO. 9: Did Defendant or any of Defendant's distributors, as listed in response to Interrogatory Nos. 8.1, 8.2, and/or 8.3 have sales representatives who specifically called on the sites listed on Exhibit A, attached hereto, from 1945 to 1975? If your response is yes, as to each site listed on Exhibit A, please state the following: (a) (b) (c) . (d) (e) The name and last known address of each such representative and whether they are still employed by Defendant; The period of time they acted as your representative; Their general responsibility as to each facility; Whether that person is still alive; and Any documents relating, referring or pertaining thereto. ANSWER: See Answer to Interrogatory Nos. 8.1, 8.2 and 8.3. 16 INTERROGATORY NO. 9.1: Identify all managers and sales personnel responsible for your sales or installation of any asbestos-containing products in Ohio from 1930 to the present and state their position, last known address and the local or regional office through which they were employed. ANSWER: In addition to the foregoing general objections, Uniroyal objects to this interrogatory on the grounds that it is beyond the scope of discovery permissible under the Ohio Rules of Civil Procedure. Subject to and without waiving these objections, Uniroyal answers as follows: The following were supervisors in the Industrial Textiles Sales Division: Stanton J. Peele (1959-1967); Richard P. Clark (1967 - ?); Edward A. Morris (Succeeded Clark); Clarence H. Sigler, Jr. (Succeeded Morris).' INTERROGATORY NO. 10: Did Defendant ever have any division or subsidiary engaged in the contract business of applying or removing asbestos-containing products? If so, please state: (a) The name of each subdivision; (b) The full address of the home office and the date such subdivision or subsidiary was engaged in this contracting business; (c) Whether said division or subsidiary conducted such business at any of the sites listed on Exhibit A, from 1940 to 1975? If so, please state the following as to each jobsite listed on Exhibit A: (1) The dates of such contracts; (2) The specific asbestos-containing products that were used or removed in each contract. 17 ANSWER: In addition to the foregoing general objections. Uniroyal objects to this interrogatory on the grounds that it is beyond the scope of discovery permissible under the Ohio Rules of Civil Procedure in that it does not seek discovery of a matter relevant to the issues raised by the claims or defenses of any party and the information sought does not appear reasonably calculated to lead to the discovery of admissible evidence. Subject to, and without waiving these objections. Uniroyal answers as follows: Based upon information and belief, no. INTERROGATORY NO. 11: Did Defendant ever have any division or subsidiary engaged in the contract business of applying or removing asbestos-containing refractory? If so, please give the name of each subdivision, the full address of the home office and the date such subdivision or subsidiary was engaged in this contracting business.. ANSWER: In addition to the foregoing general objections, Uniroyal objects to this interrogatory on the grounds that it is beyond the scope of discovery permissible under the Ohio Rules of Civil Procedure in that it does not seek discovery of a matter relevant to the issues raised by the claims or defenses of any party and the information sought does not appear reasonably calculated to lead to the discovery of admissible evidence. Subject to, and without waiving these objections. Uniroyal answers as follows: Based upon information and belief, no. 18 INTERROGATORY NO. 12: Please identify by location and product produced, each plant in which products listed in your answers to Interrogatory No. 5 have been manufactured and/or assembled and the dates said plants have been in operation. ANSWER: In addition to the foregoing general objections, Uniroyal objects to this interrogatory on the grounds that it is beyond the scope of discovery permissible under the Ohio Rules of Civil Procedure in that it does not seek discovery of a matter relevant to the issues raised by the claims or defenses of any party and the information sought does not appear reasonably calculated to lead to the discovery of admissible evidence. Subject to, and without waiving these objections, Uniroyal answers as follows: Uniroyal's plants included:' Hogansville Plant, Hogansville, Georgia (1942-1976); Passaic Plant, Passaic, New Jersey (7-1972); Mishawaka Plant, Mishawaka, Indiana (1959-1985). Documents responsive to this inquiry, if any, may be made available for review pursuant to the Ohio Rules of Civil Procedure. INTERROGATORY NO. 13: Has Defendant, at any time, entered into a "rebranding" agreement with any other company, either as a buyer or a seller, concerning any asbestoscontaining products and/or materials? If so, please state: (a) The name of the company manufacturing the asbestos products under such agreement; (b) The trade name affixed to such products; (c) The periods of time covered by each such agreement; (d) The volume (in dollars amounts) of each such transaction; (e) The purchaser of such products; 19 (f) Does Defendant currently have in its possession any of the writings or contracts concerning such rebranding agreement? ANSWER: In addition to the foregoing general objections. Uniroyal objects to this interrogatory on the grounds that it is beyond the scope of discovery permissible under the Ohio Rules of Civil Procedure in that it does not seek discovery of a matter relevant to the issues raised by the claims or defenses of any party and the information sought does not appear reasonably calculated to lead to the discovery of admissible evidence. Subject to, and without waiving these objections, Uniroyal answers as follows: Based upon information and belief, no. INTERROGATORY NO. 13.1: Have you ever owned or operated a business or portion thereof which engaged in construction, erection or tear out of furnaces, pipes, boilers, turbines, lehrs, ovens, kilns, etc.? If so, please state: (a) The same of said business; (b) The date of commencing business and cessation of business, if applicable; (c) Type of construction or tear out performed; (d) State whether said business installed or supplied asbestos-containing products on the furnaces, pipes, boilers, turbines, lehrs, etc., i.e., gaskets, pipecovering, block, cement, rope, cloth, clothes, etc., containing asbestos, asbestos pipe, board, etc.; (e) State the trade name and/or manufacturer of any asbestos-containing product which you installed or supplied to any site on Exhibit A; (f) Provide the dates for the applicable construction, installation or tear-out project. ANSWER: See Answer to Interrogatory No. 13. 20 i INTERROGATORY NO. 13.2: Do you have within your custody, possession, or control any packages that presently or formerly packaged asbestos-containing products or were produced for the purpose of packaging asbestos-containing products contemporaneous with your manufacture sale or distribution of such asbestos-containing products? If so, provide the following: . (a) A description of each such package; (b) The present location and custodian of each such package; . (c) The date or approximate date on which each such package was produced. ANSWER: In addition to the foregoing general objections, Uniroyal objects to this interrogatory on the grounds that it is overly broad and unduly burdensome. Subject to the foregoing objections, Uniroyal answers as follows: Such information is unknown except to the extent that it may be contained in Uniroyal's documents, which may be made available for review pursuant to the Ohio Rules of Civil Procedure. INTERROGATORY NO. 14: What is the name, address and job title of each individual who participated in the design and preparation of manufacturing specifications for each such product listed above in answer to Interrogatory No. 5? ANSWER: In addition to the foregoing general objections, Uniroyal objects to this interrogatory on the grounds that it is overly broad and unduly burdensome. Subject to the foregoing objections. Uniroyal answers as follows: 21 Such information is unknown except to the extent that it may be contained in Uniroyal's documents, which may be made available for review pursuant to the Ohio Rules of Civil Procedure. INTERROGATORY NO. 15: As to each product listed in response to Interrogatory No. 5, please describe how each product was to be cut, shaped, scribed, mixed and applied on the job. (In answering this question, give particular reference as to whether or not the materials were to be sawed or cut on the job, blown into confined areas, mixed with water in a cement or paste.) ANSWER: In addition to fhe foregoing general objections, Uniroyal objects to this interrogatory on the grounds that it is overly broad and unduly burdensome. Subject to, and without waiving these objections. Uniroyal answers as follows: Documents responsive to this inquiry, if any, maybe made available for review pursuant to the Ohio Rules of Civil Procedure. INTERROGATORY NO. 16: Based upon the material contents of the asbestoscontaining products, the method of manufacturing, and the method of application, please state which products listed in Interrogatory No. 5, 8.02 or 8.04 could be applied by a worker without creating dust. 22 ANSWER: In addition to the foregoing general objections, Uniroyal objects to this interrogatory on the grounds that it is overly broad and unduly burdensome. Subject to, and without waiving these objections, Uniroyal answers as follows: Based upon information and belief. Uniroyal's products could be generally applied without liberating asbestos fibers in excess of the then existing threshold limit value, or comparable OSHA standard. Based upon information and belief, during the 1970's, Avondale Shipyard caused dust counts to be taken during operations involving asbestos cloth believed to be manufactured by Uniroyal. All fiber counts were well below the then recognized threshold limit value, or comparable OSHA standard. Uniroyal does not believe that the results would have significantly differed had the tests been conducted at any other time or location. INTERROGATORY NO. 17: Do any documents, including but not limited to, written memoranda, specifications, recommendations, blueprints or other written materials of any kind or character now exist relating to the design and preparation of the products listed in answer to Interrogatory No. 5? If so, please: (a) List each such written material or document; (b) Identify the person or person presently in possession of each such document; (c) State where each such document is located. ANSWER: In addition to the foregoing general objections, Uniroyal objects to this interrogatory on the grounds that it is overly broad and unduly burdensome. Subject to, and without waiving these objections. Uniroyal answers as follows: 23 Documents responsive to this inquiry, if any, may be made available for review pursuant to the Ohio Rules of Civil Procedure. INTERROGATORY NO. 18: Prior to releasing the products listed in Interrogatory No. 5 for sale and usage, were any tests (either animal or human) conducted on said products to determine potential health hazards involved in the use of, or exposure to, the materials and/or products? If so, please state: (a) The name of the products tested and the date of each test; (b) The name, address, .and job classification of each individual who conducted such tests; ' (c) The results of such tests. ANSWER: In addition to the foregoing general objections, Uniroyal objects to this interrogatory on the grounds that it is overly broad and unduly burdensome. Subject to, and without waiving these objections. Uniroyal answers as follows: Based on information and belief, Uniroyal's products did not emit fibers in excess of the then existing threshold limit value, or comparable OSHA standard. Uniroyal does not know at this time if the products were tested by the United States government, military, or the War Production Board, prior to its directive that Uniroyal increase the manufacture of asbestos textiles. Based upon information and belief, during the 1970's, Avondale Shipyard caused dust counts to be taken during operations involving asbestos cloth believed to be manufactured by Uniroyal. All fiber counts were well below the then recognized threshold limit value, or comparable OSHA standard. Uniroyal does not believe that the results would have significantly 24 differed had the tests been conducted at any other time or location. Uniroyal was generally aware that prolonged high exposure of its textile worker employees to certain asbestos fibers could pose a potential health hazard. The work done by Uniroyal's consultant, Dr. John G. Wells, was related to textile workers. Uniroyal manufactured textiles containing asbestos from 1941 to 1976, and did not believe that the use of its finished products posed an unreasonable health hazard. Further information, if any, may be contained in Uniroyal's documents which may be reviewed pursuant to the Ohio Rules of Civil Procedure. INTERROGATORY NO. 18.1: Prior to releasing any products for sale and usage (whether asbestos-containing or not), were any tests (either animal or human) conducted on said products to determine potential health hazards involved in the use of, or exposure to, the materials and/or products? If so, please state: (a) The name of the products tested and the date of each test; (b) The name, address, and job classification of each individual who conducted such tests; (c) The results of such tests. ANSWER: See Answer to Interrogatory No. 18. 25 INTERROGATORY NO. 19: Does Defendant have or control any documents, including but not limited to, written memoranda, specifications, recommendations, blueprints or other written materials of any kind or character relating to the testing of the products listed in Interrogatory No. 5 hereinabove? (a) The name of the products tested and the date of each test; (b) The name, address, and job classification of each individual who conducted such tests; (c) The results of such tests. ANSWER: In addition to the foregoing general objections. Uniroyal objects to this interrogatory on the grounds that it is overly broad and unduly burdensome. Subject to the foregoing objections, Uniroyal answers as follows: % Such information is unknown except to the extent that it may be contained in Uniroyal's documents, which may be made available for review pursuant to the Ohio Rules of Civil Procedure. INTERROGATORY NO. 20: Were any design changes or modifications made as a result of such tests listed in answer to Interrogatory No. 18 hereinabove? If so, please state: (a) The trade name of the product changed or modified; (b) The nature of the change made and the date of such changes or modifications; (c) The name, address, and job classification of each person in charge of making a change. ANSWER: See Answer to Interrogatory No. 18. 26 INTERROGATORY NO. 21: After releasing for sale, distribution or marketing the products listed in answer to Interrogatories No. 5 or 8.02, did Defendant conduct any tests (either on animals or humans) to determine potential health hazards involved in the use of said materials and/or products? (a) (b) . (c) (d) . (e) The names ofthe products tested and the dates of said tests; The name, address, and job classification of each person and/or agency conducting said tests; The results of said tests; Whether, as a result of any tests conducted, any products were removed from the market; The names of all products removed from the market as a result of said tests. ANSWER: In addition to the foregoing general objections, Uniroyal objects to this interrogatory on the grounds that it is overly broad and unduly burdensome. Subject to, and without waiving these objections, Uniroyal answers as follows: Such information is unknown except to the extent that it may be contained in Uniroyal's documents, which may be made available for review pursuant to the Ohio Rules of Civil Procedure. INTERROGATORY NO. 22: Has Defendant ever conducted or caused to be conducted any studies concerning the effects of the inhalation of asbestos dust and/or fibers on workers or other persons applying, using and/or working around any of the asbestos products manufactured, sold, distributed and/or relabelled for distribution by you or your predecessor? If so, please state: (a) The dates and nature of such studies; (b) The names and addresses of persons conducting such studies; 27 (c) The purpose of such studies; (d) Identify and list those persons to whom such reports were given and the date of such dissemination; (e) State any publication or other written dissemination of the results of such studies; (f) State the nature of any action to eliminate or minimize the inhalation of asbestos dust fibers; and (g) Attach a copy of reports based upon such studies. ANSWER: In addition to the foregoing general objections, Uniroyal objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, unlimited in scope, as well as beyond the scope of discovery permissible under the Ohio Rules of Civil Procedure in that it does not seek discovery of a matter relevant to the issues raised by the claims or defenses of any party and the information sought does not appear reasonably calculated to lead to the discovery of admissible evidence. 'In addition, please see Answer to Interrogatory No. 18. INTERROGATORY NO. 23: Before placing in the market the asbestos-containing products that Defendant, mined, manufactured, sold, marketed, installed or distributed on the market, did Defendant make or cause to be made, any studies to determine whether their asbestos-containing products would be hazardous to people? If so, please state: (a) The date of said studies; (b) What studies were done; and (c) The titles of each study. ANSWER: See Answer to Interrogatory No. 18. 28 INTERROGATORY NO. 24: Please state whether or not Defendant ever conducted or caused to be conducted any tests in the field (where asbestos-containing products were applied, removed or utilized) to determine the nature and extent of asbestos dust and/or fiber exposure to insulators, applicators, fellow employees, or other workers removing and/or tearing out asbestos- containing products, and/or other workers in the vicinity thereof? If so, please identify: (a) The date, place and nature of each and every test; (b) The particular asbestos-containing products to which each test applied; (c) The results of each test with particular reference to the number of asbestos fibers per cubic centimeter of air found at each site; and (d) The persons to whom the results said tests were given and the date of such dissemination. ANSWER: See Answer to Interrogatory Nos. 18 and 27. INTERROGATORY NO. 25: Please state whether or not Defendant ever obtained any. knowledge concerning the likelihood of asbestos being hazardous to human health. If so, please state: (a) When Defendant first became aware of the hazardous potential of asbestos dust and asbestos fibers; (b) The manner in which the Defendant, Defendant's predecessor, or Defendant's subsidiary companies first obtained this knowledge and became aware of said hazards and from what source this information was obtained; (c) What information was disseminated within Defendant's company, or its subsidiary or predecessor regarding such adverse consequences or effects; (d) Whether any such information is still maintained by Defendant or its subsidiary or predecessor in any written form; (e) The name, address and job classification of the custodian of such information. 29 ANSWER: In addition to the foregoing general objections. Uniroyal objects to this interrogatory on the grounds that it is overly broad and unduly burdensome. Subject to, and without waiving these objections. Uniroyal answers as follows: Because Uniroyal is a dissolved corporation and has no employees, it is impossible to ascertain exactly when or what it learned about potential hazard of excessive asbestos exposure or the conditions under which a potential hazard would exist. Moreover, to the extent that such information is available in the medical literature, it is equally available to Plaintiffs as Uniroyal. Uniroyal was generally aware that prolonged high exposure of its textile worker employees to certain asbestos fibers could pose a potential health hazard. The work done by Uniroyal's consultant. Dr. John G. Wells, was related to textile workers. Documents responsive to this inquiry, if any, may be made available for review pursuant to the Ohio Rules of Civil Procedure. INTERROGATORY NO. 26: Please state when Defendant first became aware of the possible association between inhalation of asbestos dust and/or fibers and the contraction of asbestosis and cancers including, but not limited to gastrointestinal cancer, laryngeal cancer, renal cancer, lymphoma, lung cancer and mesothelioma. As to each disease or condition, please state the source of that information, including a description of all tests conducted relative to the possibility of such a relationship. ANSWER: See Answer to Interrogatory No. 25. 30 INTERROGATORY NO. 27: Please identify all physicians, industrial hygienists, and other employees (including their names and addresses) who were employed, retained or otherwise engaged by Defendant for research, investigation or study concerning asbestos or asbestos-related diseases. . ANSWER: In addition to the foregoing general objections, Uniroyal objects to this interrogatory on the grounds that it is overly broad and unduly burdensome. Subject to, and without waiving these objections, Uniroyal answers as follows: During the years that Uniroyal commercially produced textiles containing asbestos, Uniroyal retained the services of a number of consultants, including, but not limited to, W.L.C. Hemeon, Dr. Anthony J. Lanza, Dr. Kenneth Lynch, Dr. Eugene Pendergrass, Dr. H.W. Grady, Dr. John Knox, and Dr. John G. Wells, for the purpose of studying and improving the dust control and medical program at Uniroyal's Hogansville facility. The results and findings of their work are contained in Uniroyal's documents. In addition, the documents show, among other things, that Uniroyal hired Dr. J.F. Wolfsie as its first medical director in 1964. He served in that capacity until 1971. Dr. Dexter Forbes served from 1971 to 1985. The medical directors' duties were varied, but included the coordination of a comprehensive company-wide health promotional program. Documents responsive to this inquiry, if any, may be made available for review pursuant to the Ohio Rules of Civil Procedure. 31 INTERROGATORY NO. 28: As to each person who acted in a medical advisory capacity (as it relates in any way to asbestos to Defendant, please list their name, the date individual acted in this capacity, and that person's current address and job title. ANSWER: See Answer to Interrogatory No. 27. INTERROGATORY NO. 29: Please state if any medical officer or industrial hygienist or medical consultant ever made at any time any recommendations and/or suggestions to Defendant pertaining to the risks or hazards to persons involved in the manufacture or use of asbestos products and, if so, please state when, by whom or to whom such recommendations and/or suggestions were made and the substance of each recommendation. ANSWER: See Answer to Interrogatory No. 27. INTERROGATORY NO. 30: Please state the scientific and/or medical periodicals to which Defendant, its medical department, research department, industrial hygiene divisions, engineering department or consulting physicians subscribed between 1945 and 1975. ANSWER: In addition to the foregoing general objections, Uniroyal objects to this interrogatory on the grounds that it is ambiguous, overly broad and unduly burdensome. Subject to and without waiving these objections, Uniroyal answers as follows: 32 Uniroyal has no record or information which would enable it answer this interrogatory other then to state that upon information and belief, Uniroyal subscribed at one time to National Safety Council News. Journal of Industrial Hygiene, and the British Journal of Industrial Medicine and Environmental Research. Of course, Uniroyal may have received other articles from either various consultants retained by Uniroyal or trade organizations. INTERROGATORY NO. 30,1: Please state whether Defendant, its medical officer or industrial hygienist or medical consultant or physicians were ever involved in testing or received literature or correspondence from the Mellon Institute. ANSWER: Based on information and belief, no. See also Answer to Interrogatory No. 30. . INTERROGATORY NO. 30.2: Has any engineer, industrial hygienist or.physician in your employ been a member in any professional group, trade group or any of the following groups: Asbestos Textile Institute National Insulation Manufacturers Association Thermal Insulation Manufacturers Association Quebec Asbestos Mining Association Asbestos Information Association Industrial Health Foundation Industrial Hygiene Foundation Iron and Steel Institute 33 National Safely Counsel Refractories Institute Air Hygiene Foundation of America, Inc. Sprayed Mineral Fiber Association If the answer is yes, state the following: (a) The name of the group or groups in which the individual(s) were members; (b) The name and position individual(s) within the Defendant, as defined, who were members; (c) The years the individual(s) were members of the groups; (d) Whether the Defendant paid the individual(s) dues or membership fees or reimbursed the individual(s) for dues or membership fees in the group. ANSWER: Subject to and without waiving the foregoing general objections, Uniroyal was a member of the ATI from 1960 - 1975. Employees who were members of ATI include B.E. Carden, a Superintendent, and Ed Morris, a Marketing Manager. INTERROGATORY NO. 31: State in detail what test, if any, Defendant ever made with regard to the quantity, quality, or threshold limit values of asbestos dust, fibers or particles to which workers were exposed while using, working with and/or around, installing and/or applying your asbestos-containing products. ANSWER: See Answer to Interrogatory No. 18. 34 INTERROGATORY NO. 32: For each test described in Interrogatory No. 31, please give the name of the person conducting the tests, the date of the test, and attach true copies of any documents, including but not limited to, reports, findings or memoranda concerning such tests or studies. ANSWER: See Answer to Interrogatory No. 18. . INTERROGATORY NO. 33: Please state the year that Defendant was first advised of either threshold limit values or maximum allowable concentrations of both asbestos dust and total dust by the American Conference of Governmental Industrial Hygienists and state the name of the employee/official of the company receiving such advice. ANSWER: In addition to the foregoing general objections. Uniroyal objects to this interrogatory on the grounds that it is overly broad and unduly burdensome. Subject to, and without waiving these objections. Uniroyal answers as follows: At some point in time, Uniroyal was aware that the State of Georgia and others recommend a TLV of 5 mppcf for asbestos. 35 INTERROGATORY NO. 33.1: State whether this defendant at any time caused to be conducted on any jobsite, any air sampling, dust counts, tests or other activities to determine air quality or worker safety. If your answer is in the affirmative, please indicate: (a) The date of any such air samples, tests, or activities; (b) By whom such activities were performed; (c) Where such activities were performed; (d) The results of any such activities. ANSWER: See Answer to Interrogatory No. 18. INTERROGATORY NO. 34: Does Defendant maintain a library dealing with industrial \ hygiene, medicine, safety and engineering and/or research? If so, state: (a) The date each such library was established; (b) The location of each library; (c) The name(s) of the librarian(s) since 1930; (d) List all journals subscribed to by you concerning asbestos, industrial hygiene, medicine, safety, and/or engineering; (e) List all books and articles dealing with asbestos and asbestos-related diseases and the date acquired. ANSWER: See Answer to Interrogatory Nos. 27 and 30. INTERROGATORY NO. 35: Did Defendant in the 1920's or 1930's commission, or participate in the arrangements with Metropolitan Life Insurance Company for studies at the Trudeau Foundation at Saranac Lake, New York, concerning the effect of inhalation or ingestion of asbestos fibers upon human and/or animal bodies. 36 ANSWER: In addition to the foregoing general objections, Uniroyal objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, unlimited in scope, as well as beyond the scope of discovery permissible under the Ohio Rules of Civil Procedure in that it does not seek discovery of a matter relevant to the issues raised by the claims or defenses of any party and the information sought does not appear reasonably calculated to lead to the discovery of admissible evidence. Subject to, and without waiving these objections, Uniroyal answers as follows: Based upon information and belief, no. v INTERROGATORY NO. 36: When was Defendant first aware of reports of studies of the Trudeau Foundation at Saranac Lake, New York, entitled "Effects of the Inhalation of Asbestos Dust in the Lungs of Asbestos Workers" by A.J. Lanza, Assistant Medical Director published in the J. Public Health Report, Vol. 50, No. 1, dated January 4, 1935 ("Lanza Report")? ANSWER: In addition to the foregoing general objections, Uniroyal objects to this interrogatory on the grounds that it is overly broad and unduly burdensome. Subject to the foregoing objections, Uniroyal answers as follows: . Such information is unknown except to the extent that it may be contained in Uniroyal's documents, which may be made available for review pursuant to the Ohio Rules of Civil Procedure. 37 INTERROGATORY NO. 36.1: Did you ever contract with Saranac Laboratories to study the hazards of any dust producing product manufactured by you (whether asbestos-containing or not)? If so, identify by date and author all documents concerning or any way related to such study. ANSWER: Based on information and believe, -no. INTERROGATORY NO, 36.2: Did you ever contract with Saranac Laboratories to analyze dust or products? If so, identify by date and author all documents concerning or any way related to such analysis. ' ANSWER: See Answer to Interrogatory No. 36.1. INTERROGATORY NO. 37: Please state whether the Defendant at any time has been a member of any "trade organization" or "trade association" composed by other manufacturers, miners, distributors, and/or sellers of asbestos-containing products and, if so, please identify the name and address of each such association or organization, the dates of membership, and the names of any publications issued or written by such association or organization. ANSWER: In addition to the foregoing general objections, Uniroyal objects to this interrogatory on the grounds that it is overly broad and unduly burdensome, as well as beyond the 38 scope of discovery permitted under the Ohio Rules of Civil Procedure. Subject to, and without waiving this objection, Uniroyal responds as follows: Uniroyal was a member of the ATI from 1960 to 1975. Uniroyal has not discovery in review of its files, any documents or other information that would indicate that Uniroyal was ever a member ofthe Industrial Hygiene Foundation (IHF). Plaintiffs' attorneys in other asbestos litigation have provided to Uniroyal a document which purports to reflect that United States Rubber Company (Uniroyal) was a member of the IHF in 1959. However, the document also contains lists ofIHF membership from 1936 to 1981. Uniroyal is not found on any annual membership list from 1936 to 1981 except for the 1959 list. This document was a photocopy and no original has been found in the Uniroyal files. Uniroyal has not discovered in review of its files, any documents or other information that would indicate that Uniroyal was ever a member of the American Standards Association (ASA). Plaintiffs' attorneys in other asbestos litigation have provided to Uniroyal a document which purports to reflect that United States Rubber Company (Uniroyal) was a member of the ASA from 1945 to 1946. This document was a photocopy and no original document or photocopy has been found in the Uniroyal files. Uniroyal has not discovered in review of its files, any documents or other information that would indicate that Uniroyal was ever a member of the National Safety Council (NSC). Plaintiffs' attorneys in other asbestos litigation have provided to Uniroyal a document which purports to reflect that Uniroyal, or an employee of Uniroyal, was at one time a member of 39 the NSC. This document was a photocopy and no original or photocopy has been found in the Uniroyal files. INTERROGATORY NO. 38: With respect to each trade organization or association listed in answer to Interrogatory No. 37, please state whether the minutes of the group's meetings and any correspondence between the members of such groups concerning the hazards of asbestos exposure are available. ANSWER: See Answer to Interrogatory No. 37. INTERROGATORY NO. 39: Please identify by name the technical and trade association periodicals to which the Defendant subscribed, and state whether Defendant had knowledge of any articles being printed, or withheld from printing, in said periodicals pertaining to the potential hazards of asbestos. If so, please state the following: . (a) The title of each such article; (b) The periodical in which each such article was published; (c) The date each such article was published; (d) A detailed explanation of the reason for withholding any such article for printing; (e) Produce documentation which refers, alludes or mentions articles which were withheld for publication. ANSWER: In addition to the foregoing general objections, Uniroyal objects to this interrogatory on the grounds that it is overly broad and unduly burdensome. Subject to, and without waiving these objections, Uniroyal answers as follows: 40 See answer to Interrogatory No. 30. INTERROGATORY NO. 40: Please state whether, prior to 1975, the Defendant sponsored, or attended any meeting, seminar, conference,-convention or legislative hearing where the subject of occupational health and exposure to asbestos was discussed and, if so, please state the date and place of such meeting and the name and address of any speakers or participants. ANSWER: In addition to the foregoing general objections. Uniroyal objects to this interrogatory on the grounds that it is overly broad and unduly burdensome. In addition, Uniroyal objects to this interrogatory on the grounds that it invades Uniroyal's constitutionally protected right to free speech under the First Amendment, and is accordingly, privileged and not subject to discovery. Subject to, and without waiving these objections, Uniroyal answers as follows: Documents responsive to this inquiry, if any, may be made available for review pursuant to the Ohio Rules of Civil Procedure. INTERROGATORY NO. 41: As to each product listed in response to Interrogatory No. 5, please state whether Defendant, at any time, published and/or distributed any printed materials, including but not limited to brochures, pamphlets, catalogs, packagings or other written materials 41 of any kind or character that contain any warnings, cautions, caveats or directions concerning the possible health effects of the products on a person. If so, please state as to each product: (a) The name of each relevant product; (b) The wording of each such warning; (c) A description of each such printed material; (d) The method used to distribute the warning to persons who are likely to use the products; . (e) The date each such warning was issued; (f) Whether any warning accompanied any ofyour asbestos-containing products' sales literature, handout or pamphlets; (g) Please attach a copy of the warning and date said warning was issued; (h) The name, address, and job classification of each person who presently has possession of the above-described documents; (i) The name or names and addresses of the company who provided, produced, or manufactured the boxes or containers on which the warning appeared and dates these boxes with the warnings appeared. ANSWER: In addition to the foregoing general objections. Uniroyal objects to this interrogatory on the grounds that it is overly broad and unduly burdensome. Subject to, and without waiving these objections. Uniroyal supplements this answer as follows: Upon information and belief, beginning in approximately 1972 until the discontinuance of its asbestos textile business in 1976, Uniroyal placed a warning label on those asbestos textile products requiring such a label. Upon information and belief, the wording of such label followed the language of the applicable OSHA regulation and was never amended. It is presently not known whether any such labels were contained on mechanical rubber goods. Documents responsive to this inquiry, if any, may be made available for review pursuant to the Ohio Rules of Civil Procedure. 42 INTERROGATORY NO. 42: Has sales material been prepared by Defendant or its agents for purposes of marketing or advertising the asbestos products listed in answer to Interrogatory No. 5? If so, please state: (a) The name and address of each person or entity who prepared same; (b) The name, address and job title of each person who presently has possession of same; . (c) The date same was prepared; (d) The media used to disseminate the sales material. . ANSWER: In addition to the foregoing general objections. Uniroyal objects to this interrogatory on the grounds that it is overly broad and unduly burdensome, as well as beyond the scope of discovery permissible under the Ohio Rules of Civil Procedure. Subject to, and without waiving these objections, Uniroyal'answers as follows: Documents responsive to this inquiry, if any, may be made available for review pursuant to the Ohio Rules of Civil Procedure. INTERROGATORY NO. 43: Has any written material of any kind or character been prepared by Defendant, Defendant's predecessor or any of Defendant's subsidiary companies or their agents indicating how the products listed in answer to Interrogatory No. 5 should be used or maintained by the ultimate user or those working in facilities or at jobsites where the products was used, installed or removed, including, but not limited to, those sites listed on the jobsite list attached as Exhibit A. If so, please state the following: (a) The name, address and job classification of each person who prepared same; 43 (b) The name, address and job classification of each person who presently has possession of same; (c) The dates and manner in which said material was distributed to purchasers of the products in answer to Interrogatory No. 5. ANSWER: In addition to the foregoing general objections, Uniroyal objects to this interrogatory on the grounds that it is overly broad and unduly burdensome, as well as beyond the scope of discovery permissible under the Ohio Rules of Civil Procedure. Subject to, and without waiving these objections, Uniroyal answers as follows: Documents responsive to this inquiry, if any, may be made available for review pursuant to the Ohio Rules of Civil Procedure. INTERROGATORY NO. 44: Was any written material of any kind prepared by Defendant and distributed to those individuals listed in response to Interrogatory No. 9? If so, please state the following: (a) Identify the written material by content and date; (b) To whom was it delivered. ANSWER: See Answer to Interrogatory No. 43. INTERROGATORY NO. 45: Does Defendant contend that asbestos-containing products can be manufactured so as to eliminate all potential health hazards to persons working with or around, installing or applying same? If so, please state the following: 44 (a) The date that Defendant first determined that another product could be used in place of asbestos; (b) The chemical of the substitute; (c) Whether the substitute is suitable for the purpose for which they are to be used; (d) Whether Defendant used the substitute for asbestos to 1971; (e) Whether Defendant ever used the substitute for asbestos for high or low heat insulation. ANSWER: In addition to the foregoing general objections, Uniroyal objects to this interrogatory on the grounds that it is overly broad and unduly burdensome, vague and ambiguous. Subject to, and without waiving these objections, Uniroyal answers as follows: Because Uniroyal is a dissolved corporation and has no employees, it is impossible to ascertain exactly when or what it learned about potential hazard of excessive asbestos exposure or the conditions under which a potential hazard would exist. Uniroyal was generally aware that prolonged high exposure of its textile worker employees to certain asbestos fibers could pose a potential health hazard. The work done by Uniroyal's consultant. Dr. John G. Wells, was related to textile workers. Uniroyal manufactured textiles containing asbestos from 1941 to 1976, and did not believe that the use of its finished products posed an unreasonable health hazard. Documents responsive to this inquiry, if any, may be made available for review pursuant to the Ohio Rules of Civil Procedure. 45 INTERROGATORY NO. 46: Did Defendant give any warnings to any individuals at the sites listed on Exhibit A, including any individuals who owned, operated, or managed the facilities at the sites listed on Exhibit A, regarding the potential health hazards of any product listed in response to Interrogatory No. 5 and 8.02. Ifyes, please state: (a) Name ofthe person most knowledgeable about this communication; ' (b) Name of person at the sites listed on Exhibit 1, attached hereto most knowledgeable about this communication; (c) Dates of each communication; (d) Contents of each communication. ANSWER: In addition to the foregoing general objections, Uniroyal objects to this interrogatory on the grounds that it is overly broad and unduly burdensome, vague and ambiguous, as well as beyond the scope of discovery permissible under the Ohio Rules of Civil Procedure in that it does not seek discovery of a matter relevant to the issues raised by the claims or defenses of any party and the information sought does not appear reasonably calculated to lead to the discovery of admissible evidence. Subject to, and without waiving these objections, Uniroyal answers as follows: . See Answer to Interrogatory No. 41. INTERROGATORY NO. 47: Did any person prior to 1970, file a claim against any Workers' Compensation carrier covering Defendant alleging that he or she contracted a disease as a result of exposure to asbestos? If so, please state the following: 46 (a) A list of each such claim by claimant's name, date filed, the caption and jurisdiction involved; (b) The disease alleged in each such claim; (c) A brief summary of the disposition of each such claim; and (d) The name, address and job classification of the person or person having custody ofthe records pertaining to each such claim. ANSWER: In addition to the foregoing general objections, Uniroyal objects to this interrogatory on the grounds that it is overly broad and unduly burdensome, as well as beyond the scope of discovery permissible under the Ohio Rules of Civil Procedure. Uniroyal also objects to producing confidential documents. Furthermore, Uniroyal ceased the manufacture of the products to which plaintiffs claim exposure by 1976. Accordingly, Uniroyal objects to the extent this interrogatory seeks information related to claims of the type described in this interrogatory v filed subsequent to 1976. Subject to and without waiving these objections, Uniroyal supplements its answer as follows: A worker's compensation claim was made against Uniroyal in 1955 by one of its employees engaged in the manufacture of asbestos-containing textile products. Two claims were made in 1959. One claim was made in 1961. Two claims were made in 1964. One claim each in 1966, 1968,1972, and 1974-1976. Based upon current information, all of these claims were for asbestosis; Uniroyal is unaware that claims for lung cancer, mesothelioma, or other cancers were made. INTERROGATORY NO. 47.1: Please identify all documents concerning or in any way related to any decisions made by you to cease manufacturing asbestos-containing products. 47 ANSWER: See Answer to Interrogatory No. 8.01. INTERROGATORY NO. 47.2: Has any person or company from which you purchased asbestos-containing products ever issued a recall of their products or taking any action to take those products off the market after said products were in your possession? If so, provide: (a) The date of said recall; (b) The name of the company which issued the recall; (c) A copy of the recall. ANSWER: See Answer to Interrogatory No. 8.01. INTERROGATORY NO. 47.3: State what action, if any, you have ever taken since 1930 to minimize or eliminate any risk of occupational disease or pneumoconiosis to .those at any time engaged in the manufacture or production of asbestos-containing products. ANSWER: Since the early 1940s, Uniroyal encouraged, and in some instances required, the use of respirators in certain operations of asbestos textile production at its Hogansville, Georgia facility; moreover, extensive ventilation equipment and dust reducing methods were continuously introduced and replaced as more efficient technological advances became known to reduce and/or control the dust associated with textile production. See also Answer to Interrogatory No. 27. 48 INTERROGATORY NO. 47.4: State what action, if any, you have ever taken since 1930 to minimize or eliminate any risk of occupational disease or pneumoconiosis to those at any time engaged in the use, as distinguished from the manufacture, or exposed to the use of asbestos- containing or industrial insulation products or who were otherwise exposed to asbestos- containing or industrial insulation products: . (a) (b) (c) (d) Describe such action; State when such action was taken; State what written material exists related to such action; State the names, job titles and last known address of the individuals who undertook such actions. ANSWER: See Answer to' Interrogatory Nos. 45 and 47.3. INTERROGATORY NO. 48: Did Defendant receive notice prior to 1968 that any person was claiming injury as a result of using asbestos products manufacturing, sold, installed, and/or distributed by Defendant? If so, please state: (a) The name and address of each claimant; (b) The date of notice of each claim; (c) A description of the claim; . (d) The type of injuries allegedly sustained; (e) The name and address of each attorney representing the individuals making such claims; (f) The style and court number of each such claim; (g) The resolution of each claim. 49 ANSWER: In addition to the foregoing general objections, Uniroyal objects to this interrogatory on the grounds that it is overly broad and unduly burdensome as well as beyond the scope of discovery permissible under the Ohio Rules of Civil Procedure. INTERROGATORY NO. 48.1: Describe the method by which you have maintained records concerning the manufacturer, sale, supply, distribution, use, advertising, delivery and/or installation or tear-out of each of die asbestos-containing products. For each description provide the following: (a) Each present and former company or corporate department, division or subdivision responsible for maintaining such records; (b) The manner in which the records are kept (e.g., boxes, computer tape, microfilm, etc.); (c) The inclusive dates of any such manufacturer, sale, supply, distribution, use, advertising, delivery, and/or installation or tear-out which such record keeping system covers; (d) The present location at which all such records are maintained; (e) The identity of each person employed by you at any time from 1930 to the present who is or was responsible for the collection and maintenance of such records. ANSWER: In addition to the foregoing general objections, Uniroyal objects to this interrogatory on the grounds that it is vague and ambiguous, as well as overly broad and unduly burdensome, and the information sought is beyond the scope of discovery permissible under the Ohio Rules of Civil Procedure. Subject to the foregoing objections, Uniroyal answers as follows: Records were kept at the local plants and corporate headquarters. They were maintained essentially in file cabinets. Eventually, all existing records were sent to UniroyaTs attorneys in New York and to U.S. corporate headquarters. Additionally, Uniroyal has a record retention 50 manual that is available for inspection and copying. All documents have been maintained since the onset of asbestos litigation became known to attorneys for Uniroyal. The current custodian of records is Donald A. Ware. INTERROGATORY NO. 48.2: State whether any records the manufacture, sale, supply, distribution, advertising, delivery, use or installation or tear-out of asbestos-containing products have been destroyed or discarded and if so, indicate: (a) The date and locatipn of such destruction or discard; (b) The custodian and location of such records prior to their destruction or discard and the identity of each employee, representative, official or agent who ordered, authorized or supervised such destruction or discard. ANSWER: See Answer to Interrogatory No. 48.1. INTERROGATORY NO. 48.3: For all documents, other than invoices, work orders and/or purchase orders, which relate to matters relevant to the all the preceding interrogatories: (a) Is there any kind of index for the documents? (b) How many pages is the index of documents? (c) How many documents are referred to in the index? (d) Is the index maintained in electronic format (i.e. database, word processing or other computerized format)? (e) What manner of electronic format is used? ANSWER: See Answer to Interrogatory No. 48.1. 51 INTERROGATORY NO. 48.4: For all invoices, work orders and/or purchase orders. which relate to matters relevant to the all the preceding interrogatories: (a) Is there any kind of index for the documents? (b) How many pages is the index of documents? - __ (c) How many documents are referred to in the index? (d) Is the index maintained in electronic format (i.e. database, word processing or other computerized format)? (e) What manner of electronic format is used? ANSWER: See Answer to Interrogatory No. 48.1. INTERROGATORY NO. 49: Has Defendant obtained statement from any witnesses including the Plaintiffs? If so, please: (a) List each witness who has given a statement and the name, address, and job title of each person having custody of any such statement. ANSWER: Subject to, and without waiving the foregoing general objections. Uniroyal answers as follows: Uniroyal will provide information regarding witnesses in accordance with the Court's scheduling order and the Ohio Rules of Civil Procedure. 52 INTERROGATORY NO. 50; Do you contend that the Plaintiff/Decedent improperly used those products listed in response to Interrogatory No. 5? If so, please set out in detail in what respect the product was improperly used. ANSWER: Subject to, and without waiving these objections, Uniroyal answers as follows: Discovery is ongoing. As the facts are developed, Uniroyal will supplement this response to address an individual plaintiffs' case. INTERROGATORY NO. 51: As to the sites listed on Exhibit A, and as to each PlaintiffTDecedent, please state whether Defendant contends that there was any substance other than asbestos which contributed or caused Plaintiff/Decedent's injuries. If your answer is yes, please state the following: (a) The facts upon which you rely; (b) The identity of the sources upon which you rely which substantiate these facts. ANSWER: Subject to, and without waiving these objections, Uniroyal answers as follows: Discovery is ongoing. As the facts are developed. Uniroyal will supplement this response to address an individual plaintiffs' case. 53 INTERROGATORY NO. 52: Would any respirator, mask or other breathing devices prevent inhalation ofthe asbestos dust and fibers contained in products listed in answer to Interrogatory No. 5? If so, state: (a) When the respirator was sold; (b) A detailed description of such respirator or other breathing devices, including name of manufacturer and model number; (c) The basis ofyour claim that such respirators or other breathing devices will prevent the inhalation of such dust and fibers; (d) Identify any tests performed regarding the efficaciousness of such respirators and other breathing devices in preventing the inhalation of asbestos dust and fibers including date, title, author and number; (e) List all documents which mention, allude or refer to tests performed on breathing devices which prevented the inhalation of asbestos dust and/or fibers. ANSWER: In addition to the foregoing general objections, Uniroyal objects to this interrogatory on the grounds that it is overly broad and unduly burdensome, vague and ambiguous. INTERROGATORY NO. 53: Does Defendant expect to call expert witnesses at the trial of this case? If so, please state the following: (a) Their identity, last known address; (b) The subject matter on which the expert is expected to testify; (c) The expert's specific conclusion and specific opinions and the specific basis therefore; (d) The expert's qualifications to render the opinions set forth above; (e) Whether any person identified in sub-paragraph (a) above has provided a report or other documentation to you, and if so, identify such document or report; (f) Identify all documents that you have provided to each person identified in response to sub-paragraph (a) above; and (g) Describe in detail the education and work history of, and identify any books, treaties, article, published and unpublished reports, studies or other scholarly 54 % works authored by any individual identified in response to sub-paragraph (a) above. Alternatively, in lieu, of said response, attach a copy of a resume or curriculum vitae and a list ofpublications to your answer. ANSWER: Subject to, and without waiving the foregoing general objections, Uniroyal answers as follows: Uniroyal will provide information regarding expert witnesses in accordance with the Court's scheduling order and the applicable Ohio Rules of Civil Procedure. INTERROGATORY NO. 54: Please state the name and last known address of each expert witness who is not retained or employed for that purpose who is an employee of Defendant and will render an opinion within his expertise at the time of trial. ANSWER: See Answer to Interrogatory No. 53. INTERROGATORY NO. 55: Does Defendant admit that service of process was properly had on it in these cases? If not, please state why. ANSWER: Subject to, and without waiving these objections, Uniroyal answers as follows: Discoveiy is ongoing. As the facts are developed, Uniroyal will supplement their Answer to address an individual Plaintiffs case. 55 INTERROGATORY NO. 55.1: For each and every affirmative defense asserted in the answering Defendant's Answer to Plaintiffs' Complaint, the Cross-Claims or Counter-Claims of any party against this answering Defendant state: (a) (b) (c) . (d) The facts upon which the answering Defendant relies for each and every affirmative defense; Each and every document which will be offered to prove each and every affirmative defense; Each and every witness who will testify in support of each and every affirmative defense; and The substance and subject matter of the anticipated testimony of each witness identified in the preceding response. ANSWER: In addition to the foregoing general objections, Uniroyal objects to this ' \ interrogatory on the grounds that calls for legal conclusions and information protected by the attorney work product doctrine. INTERROGATORY NO. 56: Does Defendant have policies of insurance that might cover the claims that have been made by the Plaintiffs herein? (a) If so, please list the name of each insurance carrier who may have coverage, the amount of such coverage, and the dates of each such policy. ANSWER: In addition to the foregoing general objections. Uniroyal objects to this interrogatory on the grounds that it is beyond the scope of discovery permissible under the Ohio Rules of Civil Procedure in that it does not seek discovery of a matter relevant to the issues raised by the claims or defenses of any party and the information sought does not appear reasonably calculated to lead to the discovery of admissible evidence. 56 INTERROGATORY NO. 56.1: Have you ever been involved in any litigation concerning potential insurance coverage for asbestos products liability matters? If so, please state: (a) The case caption, court and ate of filing of each case in which you have been involved; (b) Whether you were plaintiff or defendant; (c) A brief statement of the issues; (d). Identify by date, author and recipient(s), (including recipients of carbon copies) all documents listed as exhibits by either party in this litigation; (e) Identify by deponent and date all individuals who were deposed in these cases; (f) Identify by date, author and recipient(s) all documents that have been placed on a protective order in such litigation; (g) Identify all expert witnesses retained for use at trial in any of the above litigation by name, address and telephone number. ANSWER: In addition to the foregoing general objections. Uniroyal objects to this interrogatory on the grounds that it seeks information beyond the scope permissible under the Ohio Rule of Civil Procedure. Further, this seeks information protected by the attorney-client privilege and attorney work product doctrine. INTERROGATORY NO. 57: Please state the name and address of each person who has knowledge of relevant facts regarding claims and defenses of this lawsuit. ANSWER: In addition to the foregoing general objections, Uniroyal objects to this interrogatory on the grounds that it is overly broad and unduly burdensome. 57 INTERROGATORY NO. 58: State the last date that this Defendant sold, distributed, manufactured, installed, and/or otherwise placed asbestos-containing products into the stream of commerce. ANSWER: See Answer to Interrogatory No. 5. INTERROGATORY NO. 59: Please state the geographical limits, if any, by state in which you conducted business for the manufacture, sale, distribution, use or installation of asbestos or asbestos-containing products. If you had discrete geographical limits within a state, please state the county or counties in which you conducted business for that particular state or states. If there were time limitations for such geographical limitations, please state the time period for each geographical location. , ANSWER: See Answer to Interrogatory No. 8.01. VCIBDOgroupsIAsbestoslcuyihoga countytonroyanptMdv)g$V3RECO RESPONSES TO ROGS doc Robin E. Harvey (0014183) Christie N. Reilly (0064102) BAKER & HOSTETLER LLP 312 Walnut Street Suite 2650 Cincinnati, Ohio 45202-4038 (513) 929-3400 / (513) 929-0303 FAX Counsel for Defendant Uniroyal, Inc. 58 CERTIFICATE OF SERVICE The undersigned hereby certifies that a copy of the foregoing document was sent via ordinary U.S. Mail upon Plaiptiffs' counsel and notice of filing of the same was sent to all counsel listed below this 7,[3&ay ofApril, 1998. Stephen D. Wolens, Esq. BARON & BUDD The Centrum Suite 1100 Dallas, TX 75219-4281 and Bruce Carter, Esq. BARON & BUDD 43-B New Garver Road Monroe, OH 45050 Counsel for Plaintiffs Andrew S. Lipton, Esq. MANLEY, BURKE, LIPTON & COOK 225 West Court Street Cincinnati, Ohio 45202 Co-Counsel for Plaintiffs Mary Ellen Fairfield, Esq. VORYS, SATER, SEYMOUR & PEASE 52 East Gay Street P.O. Box 1008 Columbus, OH 43216-1008 Counsel for ACandS, Inc., Harbison-Walker Refractories Co., Indresco, Inc. and Dresser Industries Mathew C. O'Connell, Esq. REMINGER & REMINGER The 113 St. Clair Building Cleveland, Ohio 44114-1273 Counsel for Anchor Packing & Garlock, Inc. Ruth Antinone, Esq. WILLMAN & ARNOLD 705 McKnight Park Drive Pittsburgh, PA 15237 Counsel for A-Best Products Co., Combustion Engineering & George V. Hamilton, Inc. Robert L. Davis, Esq. 3600 Carew Tower Cincinnati, OH 45202 Counsel for Crown Cork & Seal Co. C. James Zeszutek, Esq. THORP, REED & ARMSTRONG One Riverfront Center Pittsburgh, PA 15222-4895 Counsel for Minnesota Mining & Manufacturing Co. Wade Mitchell, Esq. Kathleen A. Pettingill, Esq. BAKER & HOSTETLER 3200 National City Center 1900 East 9th Street Cleveland, OH 44114-3485 Counsel for Beazer East, Inc., Foseco, McGraw Construction & CCR Mark Ropchock, Esq. ROETZEL ANDRESS 75 East Market Street Akron, Ohio 44308-2098 Counsel for Chicago Fire Brick Company Robert J. Fogarty, Esq. HAHN, LOESER & PARKS 3300 BP America Building 200 Public Square Cleveland, Ohio 44114-2301 Counsel for W.R. Grace Co. Regina M. Massetti, Esq. 113 St. Clair Avenue Suite 530 Cleveland, OH 44114 Counsel for Oglebay Norton Co. Joni Mangino, Esq. ZIMMER KUNZ,P.C. 3300 USX-Tower Pittsburgh, PA 15219-2702 Counsel for Insul Co. . W. Andrew Hoffman, III, Esq. FRIEDMAN & HOFFMAN 23200 Chagrin Blvd., Suite 720 Three Commerce Park Square Cleveland, OH 44122 Counsel for Ohio Valley Insulating Co. Barbara J. Arison, Esq. THOMPSON, HINE & FLORY 3900 Society Center 127 Public Square Cleveland, OH 44114-1216 Counsel for Flintkote . Reginald S. Kramer, Esq. BUCKINGHAM, DOOLITTLE & BURROUGHS P.O. Box 150050 South Main Street Akron, OH 44309 Counsel for General Electric, PPG Industries and Synkoloid Co. Mark R. Chilson, Esq: YOUNG & ALEXANDER CO., L.P.A. 367 West Second Street Suite 100 Dayton, OH 45402 Counsel for Metropolitan Life Insurance David A. Schaefer, Esq. MCCARTHY, LEBIT, CRYSTAL &HAIMAN 1800 Midland Building 101 Prospect Avenue, West Cleveland, OH 44115 Counsel for Rapid American Corp. Eric Mann, Esq. BENOS, CUMMINGS, MANN & VALENTI Eighth Floor Bulkley Building 1501 Euclid Avenue Cleveland, Ohio 44115 Counsel for North American Refractories Dennis Fogarty, Esq. DAVIS & YOUNG 1700 Midland Building 101 Prospect Avenue, West Cleveland, Ohio 44115-1027 Counsel for Owens-Corning Fiberglas Corporation Dennis P. Zapka, Esq. ZAPKA & LEUCHTAG 308 Bank One Building 106 East Market Street Warren, OH 44481 Counsel for R.E. Kramig ! Kevin O. Kadlec, Esq. Bonezzi, Switzer, Murphy & Polido 1400 Leader Building 526 Superior Avenue Cleveland, Ohio 44114-1192 Counsel for ICF Kaiser Engineers, Inc., Plibrico Company, Plibrico Sales & Service Joseph J. Bosick, Esq. PIETRAGALLO, BOSICK & GORDON The Thirty-Eighth Floor One Oxford Centre Pittsburgh, Pennsylvania 15219 Counsel for International Minerals and Chemical Corp. Mark E. Liabo, Esq. . Tom Riley Law Firm, P.L.C, Esq. 4040 First Avenue, N.E. P.O. Box 998 Cedar Rapids, Iowa 52406-0998 Counsel for Raymark Industries, Inc. William A. Viscomi, Esq. Virginia L. HeidlofF, Esq. GALLAGHER, SHARP, FULTON & NORMAN ' Bulkley Building - 7th Floor 1501 Euclid Avenue Cleveland, OH 44114 Counsel for Janos Industrial Insulation, Bigelow Liptak/A.P. Green Services, Inc. & The George Preintjes Company Gary Hermann, Esq. HERMANN, CAHN & SCHNEIDER Suite 500 1301 E. 9th Street Cleveland, OH 44114 Counsel for Pittsburgh Corning Stephen Merriam, Esq. . WILLIAMS & SENNETT 2241 Pinnacle Parkway Twinsburg, OH 44087-2367 Counsel for Edward R. Hart Michael Robic, Esq. DICKIE, MCCAMEY & CHILCOTE Two PPG Place, Suite 400 Pittsburgh, PA 15222-5402 Counsel for Frank W. Schaefer, Inc. James F. Israel, Esq. Christopher A. Beck, Esq. ISRAEL, WOOD & PUNTIL 501 Grant Building 310 Grant Street Pittsburgh, PA 15219 Counsel for General Refractories EXHIBIT A BARON & RTTDP SITE LIST Anchor Hocking Glass, Lancaster, OH Anchor Hocking Glass, Plant One, Lancaster, OH Anchor Hocking Glass, Plant Two, Lancaster, OH Armco Steel, Ashland, KY Armco Steel, Hamilton, OH Annco Steel, Houston, TX Armco Steel, Middletown, OH Armco Steel, Muskingham County, OH Annco Steel, Washington Courthouse, OH Babcock & Wilcox, Canton, OH BlawKnox Coip., Wheeling, WV Buckeye Steel, Columbus, OH Cardinal PS/Brilliant PS/Tidd PS, Brilliant, OH Centre Foundry, Wheeling, WV Champion Paper, Hamilton, OH ' Contours, Inc., Orrville, OH Cooper Tire, Findley, OH Dayton Walther, Portsmouth, OH Harrison PS, Shinnston, WV Ideal Foundry, Newton Falls, OH Jones & Laughlin Steel, Youngstown, OH Jones & Tnughlin Steel, Cleveland, OH LTV Steel, Cleveland, OH ' LTV Steel, Jennings Road, Cleveland, OH LTV Steel, East 45th Street, Cleveland, OH LTV Steel, Campbell Road, Cleveland, OH LTV Steel, West third Street, Cleveland, OH LTV Steel, Massillon, OH LTV Steel, Warren, OH LTV Steel, Youngstown, OH LTV Steel Briar Hill Works, Youngstown, OH LTV Steel Campbell Works, Youngstown, OH Lucans Steel, Massillon, OH Martin Marietta, Woodville, OH McComber Steel, Canton, OH Meade Paper, Chilicothe, OH Republic Engineered Steel Inc. (RESI), Canton, OH Republic Steel, Canton, OH rtAPmFFS- MASTER SET OF INTERROGATORIES - PAGE S3 N:\OHIO\BUTLER\MCG8AWKJlOG Republic Steel, Eighth Street Plant, Canton, OH Republic Steel, Plant A, Canton, OH Republic Steel, Plant B, Canton, OH Republic Steel, 3 Shop, Canton, OH Republic Steel, 4 Shop, Canton, OH Republic Steel, Berger Plant, Canton, OH Republic Steel, Culvert Division, Canton, OH Republic Steel, Stark Divsion, Canton, OH ` Republic Steel, Cleveland, OH Republic Steel, Massillon, OH Republic Steel, Union Drawn Steel, Massillon, OH Republic Steel, South Division, Massillon, OH Republic Steel, Warren, OH Republic Steel, Youngstown, OH The Timken Company, a.k.a. Timken Roller Bearing, Canton, OH The Timken Company, aJca. Timken Roller Bearing, Navarre Road SW, Canton, OH The Timken Company, sl3c.il Timken Roller Bearing, Duebcr Avenue, Canton, OH U.S. Rubber, Clinton, OH ' U.S. Steel, Canton, OH U.S. Steel, Clairton, PA U.S. Steel, McDonald Works, Youngstown, OH U.S. Steel, Ohio Works, Youngstown, OH U.S. Steel, Homestead, PA Washington Steel, Massillon, OH . Weirton Steel, Weirton, WV Wheeling-Pitt Steel, Allenport, PA . Wheeling-Pitt Steel, Beechbottom, WV Wheeling-Pitt Steel, Benwood, WV Wheeling-Pitt Steel, Yorkville, OH Wheeling-Pitt Steel, Martins Ferry, OH Wheeling-Pitt Steel, South Plant (Mingo Junction) Wheeling-Pitt Steel, East Plant (Follansbee, WV) Wheeling-Pitt Steel, North Plant (Steubenville) Wheeling-Pitt Steel, Monessen, PA Youngstown Sheet & Tube, Youngstown, OH PLAINTIFFS' MASTER SET OP INTERROGATORIES . PAGE S4 N:\OHIOVBUTLER\MCGRAW1CJIOG