Document XzvyQ0w5bw1K5wK1OBMG47Gng

Nu. ho- 1 31:1 2-B LINDA THRAPP and VS. AMRSTRONG WORLD INDUSTRIES, INC . , FT AL & * <* Ac & FN THE DISTRICT lOCR f DALLAS i. OLVIA. T LaA S 4 4TH JCDKIAL DISTRICT defendant. aaBtLoec i^ s answers to PLAINTIFFS' FIRST SET OF INTERROGATORIES COMES NOW, OARLOCK LNC, one of the Defendants in the aoovereferenced cause (hereinafter referred to as Oarlock ) and files this its answers to Plaintiff's First Set of Interrogatories, pursuant to Rule 168 of the Texas Rules of Civil Procedure. Respectfully Submitted,- CONANT WHITTENBURG WHITTENBURG SCHACHTER A PROFESSIONAL CORPORATION & Raymond P. Harris, Jr. State Bar No. 09088050 3800 Texas Commerce Tower 2200 Ross Avenue Dallas, Texas 75201 Tel. No. (214) 978-3800 Fax. No. (214) 978-3838 ATTORNEYS FOR DEFENDANT GARLOCK INC DEFENDANT GARLOCK INC * S ANSWERS TO PLAINTIFFS' FIRST SET OF INTERROGATORIES-Page | PLAINTIFF'S i EXHIBIT I <$-*0 CERTIFICATE 0F_ SERVICE I hereby certify that a true and correct copy of the above and foregoing document was mailed via Certified Mail. Return Receipt Requester] to Plaintiffs' counsel and by regular mail to ail known counsel' of record on this =2day of February 1991. DEFENDANT GARLOCK INC'S ANSWERS TO PLAINTIFFS' FIRST SET OF INTERROGATORIBS-Page 2 GENERAL OBJECTIONS Garlock poses the following general objections to plaint t's * interrogatories and incorporates each of these objections by reference to every answer provided hereafter. 1. The interrogatories request information going back many years and Oarlock has found it difficu.li, if no-: impossible, to reconstruct or retrieve much of the information requested. The answers given are n.ased the present facts known or believed bv Uario-.'k nt the time of its answer. 2. The interrogatories are overiv broad, burdensome, ana in places, vague and ambiguous. In addition, the interrogatories are not sufficiently iimited in time and use terms which do not refer to products manufactured by Ga rioc k. 3. Gariock does not now manufacture or sell, and has never manufactured or sold, asbestos-containing insulation products as that term is commonly used and understood in this litigation. Therefore, Garlock objects to any interrogatory referring to or assuming that su'ch products are or have been manufactured by Gariock. Garlock presumes that questions referring to insulation products are thus not applicable to Garlock. 4. Garlock does not now manufacture or sell, and has never manufactured or sold, asbestos-containing building products as that term is commonly used and understood in this litigation. Therefore, Garlock objects to any interrogatory referring to or assuming that such products are or have been manufactured by Garlock. Garlock presumes that questions referring to building products are thus not applicable to Garlock. 5. The interrogatories themselves are overly broad in that they tend to bunch together ail of the defendants. There has never been any evidence or reason to believe that ' - Garlock products, upon reasonable use, release asbestos fibers in sufficient quantities, if any, to pose a health hazard, potential or otherwise, to persons using said products. Garlock denies that the use of, or exposure to, its asbestos-containing products poses any health hazard. Furthermore, the plaintiff's alleged problems are not related to Garlock products. DEFENDANT GARLOCK INC'S ANSWERS TO PLAINTIFFS * FIRST SET OF INTERROGATORIES-Page 3 INTERROGATORIES 1. Please state person who supplied interrogatories. -he name, address i 11 format ion used and m job title of eacn answering tne-ie ANSWER: I nforma ti o n used to answe r these inter rogatc) r i e s w a s ga t lie red -om an sw e rs to interrogaTories previ o u s i y filed i n this arid other j ur i sd ict i ons over the las51 sev eral y ears and in'- oi v e i obtaini ng and confirming information f rom many pre sent a rid former em P loyees . The naimes of the i ndiv id uals w no !.> J O V 1 i n format ion include: Clayton M. Jewett, formerly Manager of Marketing - Gasket Products, Garlock Inc, P.0. Box 3401, Incline Village, Nevada 89450, Roy L. Whittaker, Director, Engineering, Industrial Packing, Garlock Inc, 1666 Division Street, Palmyra, New York 14522 and Richard W. Watson, Paralegal and Patent Agent, 1666 Division Street, Palmyra, New York 14522. Garlock objects to the remainder of the interrogatory on the grounds that it is unduly burdensome, unnecessary and harassing. 2. Has Defendant, Defendant's predecessor or any of Defendant's subsidiary companies at any time engaged in the marketing, distribution, and/or sale of any commercial and/or industrial products containing asbestos fibers? If yes, please state as to each the following: a. The name of the company manufacturing, mining, marketing, distributing or selling such products. ANSWER: Garlock objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, vague, irrelevant to any issue in this case, not reasonably calculated to lead to discovery of admissible evidence and for the further reason that the only Garlock products at issue in this case are those to" which plaintiff alleges to have been exposed. Notwithstanding and without waiving the foregoing objections, Garlock has never mined, supplied, distributed, marketed and/or sold raw asbestos fibers to others. Garlock states that since at least as early as 1907, it has produced and sold asbestos-containing gasketing and packing products. Garlock is not, and has never been a manufacturer or seller of asbestos-containing thermal insulation materials as that term is commonly used and understood in this litigation. Ail of its products, both those containing asbestos and those DEFENDANT GARLOCK INC'S ANSWERS TO PLAINTIFFS' FIRST SET OF INTERROGATOR!ES-Page 4 containing 'no asbestos, have always been sold under . hGARLOCK name. In addition, the Laiipers and Scale i r.-idema rn was used with all of its products from about 1900 anti, approximately LyK8. a number ot secondary trademarks nave also been used over the years. Principal marks which have been used in connection with asbestos-containing products, as well as non-asbestcs-contamins products, have been BELMONT, ARDI-XN. CHEVRON, LATTICE BRAIL1, PALMYRA and PAPERPAk. Oarlock states that the specific products which Oarlock has and does manufacture are asbestos sheet (from which the purchaser cuts gaskets), asbestos gaskets and asbestos packing, Gariock asbestos sheet is a mixture <*f asbestos fibers, curing agents, reinforcing fillers ana elastomers (natural rubber or synthetic poiymers having the eiasi u: qualities of rubber!. Asbestos fibers are machine blended with the rest of the mixture until they are thoroughly coated. The entire compound is then heated and rolled into sheets and is continually compressed to form a tough, impermeable, homogeneous material that Looks like linoleum. Other gasket materials are made from woven. Long fiber, asbestos yarn impregnated and encased in a rubberized coating. Other gaskets have had asbestos encased by layers of metal or encapsulated with a P.T.F.E. ( polytetrafluoroethyiene) resin envelope. Gariock asbestos packing materials consisted of woven asbestos encapsulated in either elastomeric compounds or metal foils and/or impregnated with lubricants. Gariock gaskets materials are primarily used for static sealing of steam line fLanges, cylinder heads of engines, compressors and refrigeration equipment, fluid conduits, etc. Gariock packing materials are primarily used for dynamic sealing of machinery. Finished compressed asbestos sheet is either cut into gaskets bv Gariock or sold for used by others in cutting gaskets. Oarlock's flexible and durable gasketing material is handled, installed and removed in ail intended applications without releasing meaningful quantities, if any, of asbestos fibers into the air. Oarlock's compressed asbestos sheets and gaskets are treated with an anti-stick releasing, agent which reduces any tendency of the gaskets to adhere to pipe flanges during removal and replacement. This anti-stick agent facilitates the removal of old gaskets without generating dust. Other Gariock products come in specific sizes for application and do not generally require modification before or during application or use. Gariock objects to portions of this interrogatory until such time as proper orders are entered concerning the production of proprietary information. Notwithstanding and without waiving the foregoing objections, Gariock states that from 95% to 98% of its asbestos-containing products have been made only with DEFENDANT GARLOCK INC'S ANSWERS TO ' PLAINTIFFS * FIRST SET OF INTERROGATORIES-Page 5 chrysotile asbestos fibers and that the remaining -% to * :-o : such products were made with crocidoiite asbestos Depending upon the tvpe of product involved, the percent.-lue >: asbestos contained in these products has ranged from aboui i-% to about 85%. b. The trade or brand name of each such proouct :n / manufactured, and/or marketed. , ANSWER: See answer to Interrogatory No. Z'ai. c. The dates each of such products was placed on and removed f rom the market.. ANSWER: See answer to Interrogatory No. 2(a). d. A description of the physical (chemical) composition of each such product or material including the type of asbestos- contained in each product (e.g. amosite, chrysotile, or croc idilite ) , and the quantitative percentage of asbestos in each product. ` ANSWER: See answer to Interrogatory No. 2(a). 3. Has Defendant. Defendant's processors, and/or Defendant's subsidiary companies,. at any time, entered into a "rebranding" agreement with any other company, either as a buyer or seller, concerning asbestos materials. If so, please describe the agreement. ANSWER: Garlock objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, vague, irrelevant to any issue in this case, not reasonably calculated to lead to discovery of admissible evidence and for the further reason that the only Garlock products at issue in this case are those to which plaintiff alleges to have been exposed. Notwithstanding and without waiving the foregoing objections, Garlock has no record, knowledge or recollection of any such agreement. DEFENDANT GARLOCK INC'S ANSWERS TO PLAINTIFFS* FIRST SET OF INTERROGATOR!ES-Page 6 4. Identify by name -Hid intend to call at the trial of witness state: address evet'v expef this case. For each n snots i exnerf a. testify,' The subject matter on which the expert is expec.eu ?o ANSWER: A list of expert witnesses which uarLotk expects > trial will be supplied when that determination is made. a;: u b. The substance of the facts and opinions to whn/ii ' h expert is expected to testify: ANSWER: See answer to Interrogator'.' No. 4ia). c. A summary of the grounds for each opinion. ANSWER: See answer to Interrogatory No. 4(a). 5. Identify bv name, address and telephone number every factual witness that Defendant may call to testify in the trial of this case. ANSWER: - A list of witnesses which Garlock expects to call at trial will be supplied when that determination is made. 6. Before placing your .cstestos-contaming products or materials or substances on the market, did you make or cause to oe made, any studies to determine whether your products would be hazardous to people? If so, please state the date of said studies and what studies were done. ANSWER: Garlock objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, vague, irrelevant to any issue in this case, not reasonably calculated to lead to discovery of admissible evidence and for the further reason that the only Garlock products at issue in this case are those to which plaintiff alleges to have been exposed. Notwithstanding and without waiving the foregoing objections, Gariock states that during the course of continuous investigation, observation, experience and study of its DEFENDANT GARLOCK INC * S ANSWERS TO ' PLAINTIFFS1 - FIRST SET OF INTERROGATORIES-Page 7 products and their use, there has never been any evidence r reason to believe that Gariock products pose any n^ain hazard, potential or otherwise, to persons iisin* s-ti.--; products. Gariock products pose no health hazard, poieni;.u or otherwise, to persons using such products. Gariock has iiud the following studies conducted for it bs industrial hygienists: "The Actual Occupational Exposure to Airnorr.e Asbestos Released by oarlock Spiral Wound, braided jim Encapsulated Gaskets" by Carl A. Marigold, CIH {December 198^;; "The Actual Contribution of Gariock Asbestos Gasket Maieriii.s to the (occupational Exposure to .Asbestos Workers" by carl A. .Mangoid, CIH (October 1982 )"Asbestos Fibers in toe Ambir-nt Air in the Greater San Francisco Area": by Carl A. Mangojd, CIH (March 1982); "Ambient Asbestos Fiber Levels :n Metropolitan Areas of Norfolk-Portsmouth-Newport \ev,s, Virginia" by Joseph b. Wendlick, CIH (December 1983 *; t: e Actual Contribution of Asbestos Fiber Exposure During Gasket - Removal from Pipe Flanges Aboard Ship" by Carl a. Mangold, c. 1H (November 1983); "The Actual Release of Asbestos Fibers from New, I'sed and Flanged Gariock tnc Asbestos Gasket Materials" by Carl A, Marigold, CIH (September 1985); "Occupational Exposures During Processing, Handling, Installation and Removal of Gariock Asbestos-Containing Gaskets" by Martin R. Bennett and Richard L. Hatfield (June 1985); "Gariock Inc Gasket Materials - A Comparison of the Tyndall Phenomena to the Actual Concentration of Asbestos Fibers in the Breathing Zone of Workers" by Carl A. Mangold, CIH (July 1986); "The Actual Contribution of Airborne Asbestos Fibers to the Occupational Exposure of By-Standers During Selected Processing of Encapsulated Asbestos Gaskets" by Carl A. Mangold, CIH (January 1989) - Eight separate sub-divisions titled as follows: Cutting Gaskets with a Circular Cutter: Gasket Cutting with Hand Shears; Gasket Cutting with Bali Pien (sic) Hammer; Scribing of Gasket Materials; Opening of Old Flanges and Removal of Asbestos Gaskets; Flange Face Scraping with Putty Knife; Hand Wire Brushing of Asbestos Gasket Residual from Flanges; Power Wire Brushing of Flange Faces. 7. Based upon the material contents of your products, the method of manufacturing, and the method of application for the purpose of which it was intended, can your asbestos products or material*- be generally applied or used without creating dust? ANSWER; Yes 8. Please list any written memoranda, s. recommendations or any other written materials of any kind character existing which relate to the potential health hazards said asbestos-containing Products or materials. or of DEFENDANT GARLOCK INC'S ANSWERS TO PLAINTIFFS * FIRST SET OF INTERROGATORIES-Page 8 ANSWER: Garlock objects to this i :ir e rrr.aa to on the grout', -nr . is overly broad, .jnduiy burdensome, irrelevant to any issue it: this case, not reasonably- raicuialed to lead to a lsec:vera - t admissible evidence and l'or the further reason that It assume? the truth of matters in dispute in this iitigati- r:, ^tecifi"al1y that there are dangers associated with the use of Garlovk products. No i vi t hs r and ing and without w\i'. mg "tie foregoing objections, this defendant is aware of literature 'ncerning asbestos fiber and opinions that excessive exposure to asbestos dust may be hazardous to one's health. This defendant does not know of or have in its possession mv books, pamphlets, memoranda or other written materials of an', kind or character which present any evidence or which would otherwise indicate that Garioek asbestos-containing products, upon reasonable use, release asbestos fibers in sufficient quantities, if any, to pose a health hazard, potential or otherwise, to persons using such products. Garlock denies that use of, or exposure to, its asbestos-containing products pose any health hazard or any significant possibility of inhalation of asbestos fiber. Garlock objects to making a general review of literature having no relevance to Garlock asbestos-containing products on the grounds that to do so would put defendant in the position of doing the plaintiff's work. ' 9. Has Defendant, Defendant's predecessors or any of Defendant's subsidiary companies at any time, published and/or distributed any brochures, pamphlets, packaging or any other written materials of any kind or character that contained warnings, cautions, caveats or directions concerning the possibility of injury resulting from the use of products listed in your answer to Interrogatory No. 3? If so, please state: a. The wording of such warnings. ANSWER: Garlock objects to this interrogatory on the grounds that x t, is overly broad, unduly burdensome and assumes the truth of matters in dispute in this litigation, specifically that there art- dangers associated with the use of Garioek products. Notwithstanding and without waiving the foregoing objections, Garlock states that there has never been any evidence or reason to believe that its asbestos-containing products, upon reasonable use, release asbestos fibers in sufficient, quantities, if any, to pose a health hazard, potential or otherwise, to persons using such products. Garlock denies that use of, or exposure to, its asbestos-containing products poses any health hazard, or any significant possibility of DEFENDANT GARLOCK INC'S ANSWERS TO PLAINTIFFS1 FIRST SET OF INTERRQGATORIES-Page 9 inhalation of asbestos fibers. I'he asbestos 'iters l:i -..j. products are encapsulated or otherwise retained. on /. therefore, fail within tne exception provided in trie s.: \ regulations requiring warnings on asbestos products trio materials. Neverthe L ?s -. Uario.-k places the warning set r'o '!n i n sec t ion 1910.1001, paragraph- t i i ) of the OS HA regulations on its asbes tos-con t a i n i ng products. The warring reads: "CAUTION: Contains Asbestos fibers. Avoid jreaiins dust. Breathing Asbestos dust may cause serious bodily 'i.unn. ' In.-; warning has been present on ali Oarlock asbestos-containing products and/or product, packaging since late 1J 17 . ^ sunii.-ii- warning notice has been contained in product literature published since 197" that describes one or more as:-est os.- containing products. See attached Exhibit A. b. The date sucn warning was issued. V'SWER: ' See .answer to interrogat ory (a) c. Whether any such warning accompanied any of your asbestos-containing products or materials, sales literature, handouts or pamphlets. ANSWER: See answer to Interrogatory 9{a) 10. Did Defendant, Defendant's predecessors, or any of Defendant's subsidiary companies receive notice before i.ybb 'hat any person was claiming an injury as a result of using asbestoscontaining products, manufactured, and/or sold or marketed by Defendant, Defendant's predecessors or any of Defendant's subsidiary companies? If so, please state: a. The name and address of each claimant. ANSWER: Garlock objects to this interrogatory on the grounds chat it is.overly broad, unduly burdensome and that the information sought is irrelevant in this case and is not reasonable calculated to lead to the discovery of admissible evidence. Without waiving the foregoing objections, Garlock slates that it had no such personal injury claims alleging asbestosrelated disease or injury based on product handling or use. b. The date or notice of each claim. DEFENDANT GARLOCK INC'S ANSWERS TO PLAINTIFFS' FIRST SET OF INTERROGATORIES-Page 10 ANSWER: See answer to Interrogatory 10(a). LI. Please state whetner or not Defendant, Defendant's predecessors, or Defendant's subsidiary companies, ever condo- i < : inv rest in the field : L.e., where the asbestos-containing products o f Def end ant, Defendant's predecessors, or Defendant's r s ; u -i r-> companies, were being appLied, removed or used) to determine the nature and extent of asbestos [doer exposure to nsuxa;ors, ipp; icntors or fellow employees working in the vicmitv t. nereot'. AN S w y R : \ot app1 icabie. See General Objection No. 3 . i 2. Please state whet.her or not Defendant, Defendant's predecessors, or Defendant's subsidiary companies ever obtained any Knowledge concerning the LikeLihcod of asbestos being hazardous to human health. If so, please state: a. When Defendant, Defendant's predecessors, or Defendant's subsidiary companies first became aware of the hazardous potential of asbestos dust and asbestos fibers. ANSWER: Garlock objects to this interrogatory on the grounds that, it seeks an expert medical opinion which Garlock is not qualified to give. Notwithstanding and without waiving the foregoing objections, some Garlock personnel have been.aware for a number of years that excessive exposure to asbestos dust may be hazardous fo one's health. Garlock is unable to pinpoint when or how such personnel first became uvare of the possible health hazard. However, there has never been any evidence or reason to believe that Garlock products, through normal use, have caused or contributed to any hazardous condition, potential or otherwise, since they are bonded and/or encapsulated. b. The manner in which the Defendant, Defendant's predeceuors, or Defendant's subsidiary companies first obtained this knowledge and became aware of said hazards and from what source this information was obtained. ANSWER: See answer to Interroga.t o r\v 1 2 : a ) . 13. Please state if any medical officer or industrial hygienist or medical consultant ever made at any time any DEFENDANT GARLOCK INC'S ANSWERS TO * PLAINTIFFS * FIRST SET OF INTERROGATOR!ES-Page 11 recoramendat ions and/or suggestions to the Defendant, i'enua:. - predecessors, or Defendant's subsidiary companies pertaining to risk or hazards to persons Involved in the manufacture or us? ./ asbestos products and, if so, please state when, by whom a no to such recommendations and/or suggestions were made and the subst-uu- of each recommendation. ANSWER: Oarlock objects to this interrogatory on the grounds `ha- : r. is overly broad, unduly burdensome, irrelevant to ary issue r ri this case and not reasonably oh leu Lated t. o lead to u i of admissible evidence. Further, Garlock objec ts to r j- t n te r rogato r*y on the grounds that the oni.% relevant w: this action pertain to finished asbestos-containing i.'rodv*. after they have left trie Garlock facilities. No t w i rt s l ;u.<i l and without waiving the foregoing objections, Garlock has no record, knowledge, or recollection of any such recommendat ions or suggestions reLative to any of its asbestos-containing product s. 14. Hlease state whether the Defendant, Defendant's predecessors, or Defendant's subsidiary companies at any time have been members of any trade organizations or trade associations composed of other manufacturers, miners, sellers, or distributors of asbestos 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 listed or written bv such association or organization. ANSWER: Garlock objects to this interrogatory on the grounds that it is overly broad. Notwithstanding and without waiving the foregoing objection, Gariot ;. si aces that it has been a member of five organizations which may have dealt with asbestos- containing products: I. The Fluid Sealing Association (formerly Mechanical Packing Association) (member from 1933 to present }. 2* ... . Asbestos Textile institute, Inc. (member from approximately 1966 to 1979 - Garlock acknowledges that a review of ATI minutes discloses an earlier membership period during the 1940's, but Garlock has no other record or information as i:o such period. ) J. Asbestos Information Association of North America (member from approximately 1974 to 1980). DEFENDANT GARLOCK INC'S ANSWERS TO PLAINTIFFS'-FIRST SET OF INTERROGATORIES-Page 12 4. American Sociery for lest in Hid l-lte I'll: s :>*a : >rfrom 1 945 to present-}. 5. National -Safety Council (member from present). 15. Does Defendant's p rc-duc t s whu-h pre . i :-u* i . - on r-i ;-h^-; :isrostos new perform satisfactorily' wlibout asbestos ANSWER; oarlock objects to *.fu.s interro^Htory on rh.e ground* "ion : is over! v broad, unduly burdensome, irrelevant to mv issue i : this case, not reasonably calculated to Lead t.o u L si o r ry admissible evidence and for the further reason trial the only darlock products ar. issue in ; rus case are those `o iwuo plaintiff alleges to have been exposed. Notwithstanding and witnowt waiving S. he foregoing object ions, introduction, distribution, improvement, modification and discontinuance of styles of all kinds has been a continuing process at Oarlock. Over the years, Oarlock has discontinued the manufacture and sale of numerous styles of asbestos-contaLning products. The reasons were basically economic in that the market for the particular product was such that the manufacture and sale was not profitable. Also, as new and better products have been introduced, older products have become obsolete and unprofitable. 16. Prior to 1972, were Defendants or any of Defendants' predecessors, subsidiaries or contracting divisions, a party to any claim for compensation for injuries allegedly caused by inhalation of asbestos dust or fibers. A "claim" includes, but is not limited to, personally injury lawsuits, worker's compensation claims, or other administrative claims, brought under any theory whatsoever. If "yes", please state: a. a description of the claim; ANSWER: Garlock objects to this interrogatory insofar as it pertains to^Jforkmen' s Compensation claims on the grounds that it is ovtsrly broad, unduly burdensome anil that the information sought is irrelevant in this case and is not reasonably calculated to leac to discovery of admissible evidence. The plaintiff has never been a Oarlock employee and does not allege ever visiting any Oarlock facility. The only relevant issues in this action pertain to finished asbestos-containing products after they have left Gariock facilities. Further, Garlock objects to this interrogatory insofar as it relates to DEFENDANT GARLOCK INC'S ANSWERS TO " PLAINTIFFS1 FIRST SET OF INTERROGATORIES-Page 13 personal injury claims on the grounds that it. is unduly burdensome and that the information sought is irrelevant in this case and is not reasonably calculated r lead to the discovery of admissible evidence. Without waiving the foregoing objections, darlock states that it had no su-h personal injury claims alleging asbestos-related disease or in.jurv based on product handling or use. daric-ck h>is n*\er owned or operated a "contract unit". h.' the name and address of eacn claimant ; . 4NS WE.-.: See answer to interrogatory 16(a). ANSWER: " See answer to interrogatory 16{a). c. the date Defendant received notice of each claim; ANSWER: See answer to Interrogatory 16(a). d. the nature of the injuries alleged in each claim; ANSWER: See answer to Interrogatory 16(a). e. the name and address of the attorneys representing each claimant; ANSWER: See answer to Interrogatory 16(a). f. the style and case number of each claim; ANSWER: Sefc answer to Interrogatory 16(a). i. g. the resolution of each claim; . ANSWER: See answer to Interrogatory 16(a). DEFENDANT GARLOCK INC'S ANSWERS TO PLAINTIFFS * FIRST SET OF INTERROGATORIES-Page 14 h. the name and address of the attornevg, .>.r employed by or retained by befendnn* h- defend or otherwise kh: : each claim; ANSWER: See answer to I nte r rc A -i r > v1 d ! a 5 . Please attach, a copy of each claim. ANSWER: See answer to Interrcsitorv 1 (S ( a > . 17. Has defendant ever shown Or*. Corwin Hinshaw any i nt*- rn.i i memoranda or corpora' e documents that, mention or discus;- : Defendant's knowledge of the hazards of asbestos before 1983* ANSWER: Garlock has no record, knowledge or recollection of any such occurrence. 18. At any time prior to 1983, has Dr. Corwin Hinshaw ever spoken with any corporate official or employee of Defendants regarding the hazards of asbestos? If your, answer to this Interrogatory is yes, please state when such conversation occurred, state who was present or spoke with Dr. Hinshaw and describe what was discussed. ANSWER: Garlock has no record, knowledge or recoilection of any such conversation. DEFENDANT GARLOCK INC'S ANSWERS T0_ PLAINTIFFS * FIRST SET OF INTERROGATORIES-Page 15 EXH r BXT "I* t " ,, ` Avt k 7 V-' v.. Ssl t ' W % %>-' ' US* H~y C3ti& vH < ( MU Sarlock Garlock Garlock Garlock .< Oarlock 3ar!ock CAUTION: Contains Asbestos fibers. Avokl. ^ creating dusL :} Breathing Asbestos dust may cause V C j Garlock ( CAUTION: TOTAL P.03 AFFIDAVIT STATE OF NEW YORK COUNTY OF NEW YORK S s ss. S Donald E. O'Keefe, being first duly sworn, deposes and says that he is Assistant Secretary of Garlock Inc, that he has personal knowledge of the information contained in these Answers, that he is authorized to make this Affidavit on behalf of Garlock Inc, and that the foregoing answers are true to the best of his knowledge, information and belief. , 1991, to which witness my hand and seal of office. CHPISTINg M. GANAVAN Notary Public. Stato of Now York NO. 90>4996S34 Qualified in Naaaau County .n Now York County lExpiroo Saptembor 2S 19P1 1 a.aava Notary Public in and for the State of New Yc 1QhPi eAn\Jf A iVj A-0 Printed Name of Notary 1^ My Commission Expires: