Document YGBG7jdmDg5ZejgG1o16yk2NN

NO. 93-3625-1 HELEN GAMBRELL, INDIVIDUALLY AND AS THE SPECIAL ADMINISTRATRIX OF THE ESTATE OF ROBERT GAMBRELL, DECEASED VS. THE ABER COMPANY, ET AL. received OCT 3 o 1995 BARON & BUDD IN THE DISTRICT COURT OF DALLAS COUNTY, TEXAS 162ND JUDICIAL DISTRICT DEFENDANT THE ROCKBESTOS COMPANY'S (IMPROPERLY NAMED AS ROCKBESTOS PRODUCTS COMPANY) SUPPLEMENTAL OBJECTIONS AND ANSWERS TO PLAINTIFFS MASTER INTERROGATORIES TO: Plaintiff, Helen Gambrell, Individually and as tbe Special Administratrix of the Estate of Robert Gambrell, Deceased, by and through her attorney of record, Peter A. Kraus, Baron & Budd, P.C., The Centrum, 3102 Oak Lawn Avenue, Suite 1100, Dallas, Texas 75219-4281. Defendant The Rockbestos Company, incorrectly named in Plaintiffs petition as Rockbestos Products Company, a defunct corporation, files the following Supplemental Objections and Answers to Plaintiffs Master Interrogatories. Respectfully submitted, McFALL, SHERWOOD & SHEEHY, P.C. Joseph A. Garnett Statejkr No. 07680600 2500\Twp^touston Center 909 Fannin Street Houston, Texas 77010-1003 (713) 951-1000 (713) 951-1199 Telecopier Attorneys for Defendant, The Rockbestos Company CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing instrument was served upon all counsel of record pursuant to Rule 21a of the Texas Rules of Civil Procedure on this 25th day of October, 1995. UAG\GAMBRELIAROG^UP.03 2- - GENERAL OBJECTIONS The Rockbestos Company ("Rockbestos") incorrectly named in plaintiffs petition as Rockbestos Products Company, a Delaware Corporation with its principle place of business in Connecticut, adopts and restates the general and specific objections to plaintiffs interrogatories and requests for production which were made in its initial answers and responses to the plaintiffs master set of interrogatories and requests for production. Rockbestos specifically objects to the plaintiffs demand for supplemental answers and responses as overly burdensome and harassing insofar as plaintiff has had the opportunity to depose Rockbestos' corporate representative, Mr. George Littlehales, and to question Mr. Littlehales about all matters which might be the subject of these supplemental answers and responses. Further, Plaintiff was given the opportunity as of March 8, 1994 to review all documents in Rockbestos' possession which might conceivably be relevant to the subject matter of these interrogatories. Plaintiff chose, however, not to review the entirety of the documents offered for production but chose to review only a few select boxes of documents. In the context of the Plaintiffs opportunity to depose Mr. Littlehales and Rockbestos' offer to produce all potentially relevant documents, Plaintiffs present request for supplemental interrogatory answers, is clearly designed merely to harass and burden Rockbestos rather than gain additional information. Within the context of these general objections and specific objections, Rockbestos will attempt to provide supplemental answers to each interrogatory or parts thereof, to the extent the interrogatory or part thereof is not objectionable in terms of relevancy, scope, content, specificity or burdensomeness, whether or not such objection is again herein set forth, and on the basis of reasonable efforts to locate and/or compile responsive information. In so proceeding, Rockbestos does not waive its right to assert any objection to such interrogatory or 3- - request for production, including the general and specific objections made in Rockbestos initial answers and responses, to the totality and/or individual plaintiffs interrogatories or request for production, or any parts thereof, including those to which responses have been made. Rockbestos reserves the right to stand on such objections and to supplement or amend them at a later time if any effort is made by any party to obtain more specific answers and responses to these interrogatories or request for production other than as herein provided by Rockbestos. 4- - SUPPLEMENTAL ANSWERS TO ROTATORIES 4. Identify by name each product containing asbestos fibers that Defendant or any of its predecessor or subsidiary companies at any time manufactured or sold. ANSWER: See Rockbestos' general and specific objections incorporated into its initial answers to plaintiffs interrogatories as well as the general objections made pan of this supplemental answer. Within the context of these objections and by way of supplemental answer, Rockbestos states that it manufactured and sold only wire and cable products. Some of these wire and cable products contained bonded, saturated and encapsulated chrysotile asbestos; if they contained asbestos at all. The types of wire and cable manufactured by Rockbestos varied over time; however, at various times Rockbestos manufactured and marketed some types of wire and cable which contained bonded, saturated and encapsulated chrysotile asbestos including, but not necessarily limited to: Apparatus wire, motor lead wire, appliance and fixture wire, control cable, power cable, switchboard wire, high temperature wire, furnace and mud gun cable, shipboard cable and instrument cable. Attached to these supplemental answers as Exhibit A is a more detailed listing of some of the wire and cable products manufactured by Rockbestos, many of which were manufactured in various sizes. 5. Identify by name each product containing asbestos fibers that Defendant or any of its predecessor or subsidiary companies at any time marketed or sold. ANSWER: See supplemental objections and answer to interrogatory 4. 6. If the response to one or more of the last three interrogatories is in the affirmative or lists any products, state as to each named product the following: . A. As to each product, state whether such product was mined, manufactured, marketed, and/or sold. B. The names of the companies mining, manufacturing, marketing, and/or selling each product mined, manufactured, marketed, and/or sold. C. The trade or brand name of each of those products mined, manufactured, marketed and/or sold. D. The date each of the named products was placed on the market. 5- - E. A description of the physical (chemical) composition of each of the named products, including the type of asbestos contained in the product and the percentage of asbestos put in each product. F. The date each of the products was removed from the market and no longer sold or distributed and the reason or reasons therefor. G. The date asbestos was removed from such products, if ever, and the reasons therefor. H. A description of the physical appearance of each of the named products. I. A detailed description of the intended uses of the named products. J. Identify the last year that you sold each asbestos-containing product. ANSWER: See Rockbestos' general and specific objections incorporated into its initial answers to plaintiffs interrogatories as well as the general objections made part of this supplemental answer. Within the context of these objections and by way of supplemental answer, Rockbestos states that it manufactured the wire and cable products identified in its supplemental answer to interrogatory #4 during the following time periods: Wire/Cable Products Approximate Dates of Manufacture apparatus wire motor lead wire appliance and fixture wire control cable power cable switchboard wire high temperature wire furnace and mud gun cable shipboard cable instrument cable 1936-1985 1930-1985 1930-1985 1930-1985 1930-1985 1930-1985 1938-1985 1974-1980 1930-1979 1930-1977 Rockbestos utilized various brand names and trademarks during the period which it manufactured wire and cable which contained bonded, saturated and encapsulated chrysotile asbestos. These brand names and trade names included Firestone, Firewall, Rockthenn, Pyrotrol, Pbosroc, Ciyozone and H-zone. It would be unduly burdensome, if not impossible, for Rockbestos to provide the chemical composition of each and every wire and cable product which it manufactured 6- - because it manufactured many different wire and cable products and the chemical composition of those products varied over time and with the type and size of the wire as well as the specifications of various customers. Rockbestos has previously made its records available to plaintiff, some of which may contain this information. One component which never varied, however, was that Rockbestos incorporated only bonded, saturated and encapsulated chrysotile asbestos in its wire and cable products which contained asbestos. 7. Do any documents, including but not limited to written memoranda, specifications, recommendations, blueprints, or other written materials of any land or character, relating to the design, preparation, or introduction into the market of the products listed in Interrogatory No. 6 still exist? If so, state: A. A description of each such document. B. The name, address, and job title of each person who currently has possession of each document, and where the documents are currently located. ANSWER: See Rockbestos' general and specific objections incorporated into its initial answers to plaintiffs interrogatories as well as the general objections made part of these supplemental answer. By way of supplemental answer and within the context of these objections, Rockbestos states that, to the extent that they exist, documents of the type requested in this interrogatory would be stored at Rockbestos' document retention facility in Windsor Locks, Connecticut. Rockbestos made the documents at its document retention facility available for inspection by the plaintiff starting on March 8, 1994 and continues to make those documents available for inspection. 9. Do 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 referred to in Interrogatory No. 6 now exist? If so, state: A. A description of each such document. B. The name, address, and job title of each person who currently has possession of each document, and where it is presently located. ANSWER: See supplemental objections and answer to interrogatory no. 7. 11. After releasing the products listed in Interrogatory No. 6 to the public, were any tests conducted on them to determine potential health hazards results from the use of or 7- - exposure to the materials, such as asbestos, contained in those products? If the response is affirmative, stale: A. The names of the products tested and the dates of such tests. B. The name, address, and job title of each person who conducted those tests. C. The results of those tests. D. Whether, as a result of the tests, any products were removed from the market. . The names of all products removed from the market as a result of these tests. ANSWER: See Rockbestos' general and specific objections incorporated into its initial answers to plaintiffs interrogatories as well as the general objections made part of this supplemental answer. Rockbestos specifically objects to this interrogatory insofar as it assumes or implies that Rockbestos' wire and cable products posed a potential health hazard to persons using them or exposed to them. Within the context of these objections and by way of supplemental answer, Rockbestos states that it never engaged in or supported any medical research to determine potential health hazards which might result from the use of or exposure to materials contained in its wire and cable products. Rockbestos' wire and cable products, some of which contained bonded, saturated and encapsulated chrysotile asbestos were at all times safe when properly used for their intended purpose. All of the wire and cable manufactured by Rockbestos met the specifications of the National Electrical Code, government specifications regarding asbestos, and all applicable and controlling guidelines promulgated by OSHA. 12. Do any documents, including written memoranda, specifications, recommendations, blueprints, or other written materials of any kind or character, relating to the potential health hazards of the products listed in Interrogatory No. 6 now exist? If so, state: A. The name of each product. B. A description of each document and how it relates to each product. C. The name, address, and job title of each person who currently has possession of each document, and where it is presently located. ANSWER: See Rockbestos' general and specific objections incorporated into its initial answers to plaintiff's interrogatories as well as the general objections made part of this supplemental answer. Rockbestos specifically objects to this interrogatory insofar as it assumes or 8- - implies that Rockbestos' wire and cable products posed a potential health hazard to persons using them or exposed to them. Rockbestos' wire and cable products, some of which contained bonded, saturated and encapsulated chiysotile asbestos were at ail times safe when properly used for their intended purpose. Within this context and subject to these objections, Rockbestos states that, to the extent that any documents might exist which might be deemed potentially responsive to this interrogatory, they have previously been made available and are available for inspection at reasonable times and upon reasonable notice at Rockbestos' document storage facility in Windsor Locks, Connecticut. See also objections and answers to interrogatories 7 and 9. 13. Did Defendant or any of its subsidiary companies make any design changes as a result of the tests discussed in your response to Interrogatories No. 10 or 13? If the response is affirmative, state: A. The names of the products changed or modified. B. The name, address, and job title of each person responsible for having made a change or modification. C. The nature of the hazard or defect which resulted in such change or modification. ANSWER: See Rockbestos' general and specific objections incorporated into its initial answers to plaintiffs interrogatories as well as the general objections made part of this supplemental answer. By way of supplemental answer and within the context of these objections, Rockbestos refers the plaintiff to its objections and answer to interrogatory 8. 16. Were your asbestos products distributed, marketed, packaged, labeled and/or sold by companies other than your own? If the response is affirmative, list the names and addresses of each of those companies, and the products in question. ANSWER: See Rockbestos' general and specific objections incorporated into its initial answers to plaintiffs interrogatories as well as the general objections made part of this supplemental answer. Rockbestos states that, to the best of its knowledge, its wire and cable products containing bonded, saturated and encapsulated chrysotile asbestos were not sold to any other company which repackaged or relabeled its wire and cable products. 17. Did you or any of your predecessors, successors, or subsidiaries have any distributors or sales representatives of asbestos products in the States of Alabama, Florida, Mississippi, Oregon, Washington, Georgia, Tennessee, Texas and Virginia? If so, state: A. The name and address of each such distributor or sales representatives. 9- - B. The years in which such company or person distributed, marketed, or sold your products. C. What products were distributed, marketed, or sold and in what years. ANSWER: See Rockbestos' general and specific objections incorporated into its initial answers to plaintiffs interrogatories as well as the general objections made part of this supplemental answer. Rockbestos specifically objects to this interrogatory as irrelevant, overly broad, and not reasonably calculated to lead to the discovery of evidence which is in any way relevant to the present case because it does not seek information regarding the sale of Rockbestos' wire and cable products in the plaintiffs home state of Arkansas, where the injury is alleged to have occurred. It is also objectionable as vague in its use of the undefined term "distributor." 31. Describe in detail the types of packages or packaging which Defendant or any of its subsidiary or predecessor companies used for asbestos material or products, listing the dates each type of package was used, a physical description of each type of package, and providing a description of any printed material or trademarks that appeared thereon. ANSWER: See Rockbestos' general and specific objections incorporated into its initial answers to plaintiffs interrogatories as well as the general objections made part of this supplemental answer. Rockbestos further objects to this interrogatory as overly burdensome. The plaintiff has taken the deposition of Rockbestos' corporate representative, Mr. George Littlehales, and inquired in detail as to the packaging of its products; e.g. pages 67*94 of Mr. Littlehales' deposition taken on September 15, 1995. 35. Prior to 1968, did any person file a claim against a Worker's Compensation carrier covering Defendant or any of its subsidiaries or predecessors alleging that he/she contracted a disease from inhaling asbestos fibers? If so, provide: A. A list of the claims, including each claimant's name, address and the date each claim was filed, and including the caption and jurisdiction of the claim. B. The disease alleged in each such claim. C. A brief summary of the disposition of each such claim. D. The name, address and title of the person having custody of the records pertaining to each such claim. -10* See Rockbestos' general and specific objections incorporated into its initial answers to plaintiff's interrogatories as well as the general objections made part of this supplemental answer. By way of supplemental answer and within the context of these objections, Rockbestos states that, to the best of its knowledge, the answer is no. 36. Did Defendant or any of its subsidiaries or predecessors maintain written minutes of corporate meetings, either board of directors, departmental, or otherwise, which reflect discussions pertaining to any subject matter related to asbestos, asbestos health hazards or asbestos products? If so, for each such set of minutes, state: A. The dates of each such meeting. B. The general subject mater discussed at each meeting. C. Who was in attendance at each meeting. D. Where and by whom the written minutes are presently maintained. E. By whom the minutes were taken and put into final format. F. Whether the minutes were abstracted and reports disseminated to other individuals, and if so, the names and job titles of those individuals. ANSWER: See Rockbestos' general and specific objections incorporated into its initial answers to plaintiffs interrogatories as well as the general objections made part of this supplemental answer. By way of supplemental response and within the context of these objections, Rockbestos states that, to the best of its knowledge it has no documents such as those called for in this interrogatory in its possession. 38. State whether you or any of your predecessors and/or subsidiaries maintain, from 1940 through the present or for any portion thereof, copies of invoices, shipping documents, bills of lading, purchase orders, or other documents of a similar nature relating to the mining, manufacture, marketing, sale or distribution of asbestos products. If so, state: A. The location of such documents. B. The name and address of the custodian of the documents. C. The format in which the documents are kept, i.e.. hard copy, microfilm, microfiche, etc. -11- D. In what form the documents can be accessed, i.e.. by state, by product, etc., and if by product, whether kept according to asbestos or non-asbestos. ANSWER: See Rockbestos' general and specific objections incorporated into its initial answers to plaintiffs interrogatories as well as the general objections made part of this supplemental answer. By way of supplemental answer and within the context of these objections, Rockbestos states that, to the extent that such documents exist, they have previously been made available and are available for inspection at reasonable times and upon reasonable notice, at Rockbestos' document retention facility in Windsor Locks, Connecticut. 41. Was each of your asbestos products generally expected to reach, or packaged to reach, the consumer or user, without substantial change in the condition in which it was sold? If not, with respect to any such product, explain in what way the Defendant claims its products were altered or substantially changed after sale or distribution and before reaching the user. ANSWER: See Rockbestos' general and specific objections incorporated into its initial answers to plaintiffs interrogatories as well as the general objections made part of this supplemental answer. By way of supplemental answer and within the context of these objections, Rockbestos states that, as it understands the term "substantial change", that its wire and cable products were expected to reach the consumer without substantial change in their condition. 42. For each asbestos-containing product identified in answer to Interrogatory No. 6, identify all foreseeable users such as insulators, helpers, pipe fitters, welders, machinists, plasterers, diywall finishers, carpenters, boilermakers, shipwrights and riggers, etc. of any of Defendant's asbestos-containing products. ANSWER: ~ See Rockbestos' general and specific objections incorporated into its initial answers to plaintiffs interrogatories as well as the general objections made part of this supplemental answer. Rockbestos specifically objects to this interrogatory as vague and calling for a legal conclusion in its use of the term "foreseeable user". By way of supplemental answer and within the context of these objections, Rockbestos states that, as it understands the term "foreseeable user," it would not expect that insulators, pipe fitters, welders, machinists, plasterers, drywall finishers, carpenters, boilermakers, shipwrights or riggers, or persons assisting those trades, would use their wire and cable products in the course of their work. 52. Has your company, or your predecessors) or subsidiaries, ever devised a research plan to develop, or actually developed or had developed, a product which did not contain asbestos and which could be substituted for one or more of your asbestos-containing products?. If so, state the date that such research plan was begun and when such asbestos-free product was first placed on the market. ANSWER: See Rockbestos' general and specific objections incorporated into its initial answers to plaintiffs interrogatories as well as the general objections made part of this supplemental answer. By way of supplemental answer and within the context of these objections, Rockbestos states that its wire was specifically designed for use in applications requiring resistance to extreme conditions such as high temperatures. The materials which were incorporated in a particular wire and cable, including bonded, saturated, and encapsulated chrysotile asbestos, depended upon a number of factors including the conditions to which the wire or cable was to be exposed and, most importantly, the customer's specifications. See also Rockbestos' initial objections and answers to plaintiffs interrogatory 54. UAC\GAMBRELL\ROC-SUP.03 -13- WIRE AND CABLE PRODUCTS National Electrical Code Type AIA AVB AVB AVB AVA AFPD AFPD AVPD AVDP Wire Type Description Apparatus Wire Rheostat wire 600 volt Apparatus Wire Rheostat and Stove wire 300 volt solid Apparatus Wire Rheostat tod Stove wire 300 volt stranded Power Cable Lighting Wire 600 volt Switchboard Cable Switchboard wire 600 volt AVC Switchboard Cable Switchboard binge cable 600 volt AVC Switchboard Cable Switchboard cable 600 volt AVC Power Cable Boiler Room Wire 600 volt AVC Appliance and Fixture Wire Duplex flexible cord 300 volt Appliance and Fixture Wire Triplex flexible cord 300 volt Appliance and Fixture Wire Duplex flexible cord 300 volt AVC type Appliance and Fixture Wire Triplex flexible cord 300 volt VC Type Control Cable - Control wire angle conductor 600 V AVC Appliance and Fixture Wire Duplex flexible cord 600 volt AVC Appliance and Fixture Wire Triplex flexible cord 600 volt Motor Lead Wire AVC Locomotive CAB cord 300 volt duplex Motor Lead Wire Locomotive CAB cord 300 volt triplex . Motor Lead Wirt Locomotive CAB 600 volt duplex Motor Lead Wire Locomotive CAB 600 volt Power Cable Triplex Lighting wire 600 volt AVC 1OOM50I0U101 EXHIBIT A AVA AVA AVA AVL AVA AVA AFC AFPD AFPD AF AVA AVA Switchboard Cable Power Cable Power Cable Power Cable Power Cable Power Cable Power Cable Motor Lead Wire Power Cable Power Cable Power Cable Power Cable Appliance and fixture wire Appliance and Fixture Wire Appliance and Fixture Wire Appliance and Fixture Wire Power Cable Appliance and Fixture Wire Power Cable Power Cable Power Cable Power Cable Power Cable Power Cable Power Cable - Switchboard wire 600 volt AVC Lighting wire 600 volt lead sheathed Power cable and switchboard bus cable 600 volt AVC Power cable 600 volt AVC Multi-cord Power cable 600 volt AVC lead sheathed Power cable 1000 volt AVC Power cable 600 volt lead sheaAnd Lead wire 1000 volt 90C Power cable 1000 volt 3 conductor Power cable 1000 volt 3 conductor lead sheathed Power cable 1000 volt lead sheathed Power cable 2000 volt AVC Twisted pair beat resisting flexible cord Triplex heat resisting flexible cotd Duplex beat resisting flexible cord Fixture wire beat resisting Power cable 2000 v 3 conductor ' Flexible cord - triplex Power cable 2000 volt 3 conductor lead sheathed 2000 volt cable-1 conductor lead sheathed Power cable 3000 volt AVC Power cable 3000 volt 3 conductor Power cable 3000 volt conductor lead sheathed Power cable 3000 volt 1 conductor lead sheathed Power cable 5000 volt AVC HPD HPD HPD HPD AVA ClassB ClassB Class B AVB AIA AIA AIA AIA Miscellaneous Miscellaneous Miscellaneous Miscellaneous Power Cable Power Cable Power Cable Power Cable Motor Lead Wire * Miscellaneous Miscellaneous Miscellaneous Control Cable Mining Cables Miscellaneous Miscellaneous Miscellaneous Control Cable Control Cable Switchboard Cable Power Cable Apparatus Wire Motor Lead Wire Motor Lead Wire Apparatus Wire Heater cord, heavy duty 300 cycle Heater cord 3000 cycle, red label Heater cord 10,000 cycle, gold label Heater cord, heavy duty, 10,000 cycle 5000-4000 volt power cable 1 conductor 5000-4000 volt power cables 3 conductor 5000-4000 volt power cables 3 conductor, lead sheathed 5000-4000 volt power cables 1 conductor lead sheathed ' Motor lead and apparatus cable 600 volt AVC Heating cable lead sheathed industrial type Sorce heating cables Industrial heating cable Multi-conductor control cable ML mining cable 600 volt AVC Magnet wire rectangular Magnet wire, round Magnet wire, square Control cable 600 volt lead sheath Control cable 600 volt lead sheath Switchboard bus cable 600 vohAVC Rheostat and power cable Apparatus cable, flexible Automotive bus engine compartment cable Jumper cable, 600 volt, flexible Rheostat wire 300 volt, standard 3- - AA AAAI AAAI AAAI AAAI AAAI A^AI AAAI AAAI Apparatus Wire Rheostat wire 300 volt, flexible Control Cable Signal wire Control Cable Control and signal, wire, conductor 600 voh AVC Apparatus Wire Control Cable Thermostat control wire Controllable Control wire, mufti- conductor, armored Control Cable Thermostat control wire Power Cable Secondary network cable 125 volts Power Cable Fireproofvault cable Control CaMe Elevator oontrol cable Power Cable Elevator lighting cable Apparatus Wire Apparatus and motionpicture cable, extra flexible Appliance and Fixture Wise Appliance and Fixture Wire Apparatus grounding wire Appliance lead wire 300 voh Appliance and Fixture Wire Appliance lead wire 300 volt Appliance and Fixture Wire Appliance lead wire 300 volt triplex Appliance and Fixture Wire Appliance lead wire 300 volt triplex Appliance and Fixture Wire Appliance lead wire 300 voh HI Dielectric Appliance and Fixture Wire Appliance lead wire 300 volt HI Dielectric Appliance and Fixture Wire Appliance lead wire 300 volt Canadian type Appliance and Fixture Wire Appliance lead wire 300 voh Canadian type AVC Appliance and Fixture Wire Range wire 300 volt Appliance and Fixture Wire Range wire 300 volt Appliance and Fixture Wire Range wire 300 volt triplex Appliance and Fixture Wire Range wire 300 volt triplex Appliance and Fixture Wire Range Wire 300 volt Hi Appliance and Fixture Wire Dielectric Range wire 300 voh HI Dielectric Appliance and Fixture Wire Range wire 300 volt Canadian type TA TA TA - Appliance and Fixture Wire Appliance and Fixture Wire Switchboard Cable Switchboard Cable Switchboard Cable Instrumentation Cable Instrumentation Cable Instrumentation Cable Instrumentation Cable Instrumentation Cable High Temperature Wire Apparatus Wire High Temperature.Wire High Temperature Wire Appliance and Fixture Wire Appliance and Fixture Wire Apparatus Wire Motor Lead Wire Instrumentation Cable Power Cable Power Cable High Temperature Wire High Temperature Wire Apparatus Wire Control Cable Range wire 300 volt Canadiantype AVC Stove and appliance lead wires 300 volt Canadian type Switchboard wire 600 volt Switchboard hinge cable 600 volt Switchboard cable 600 volt Pyrometer wire AVC type Pyrometer wire Thermocouple wire Thermocouple wire AVC Pyrometer and Thermocouple wires Aircraft wire 1000 volt Apparatus wire 3000volt Hookup wire 1000 volt 125*C Hookup wire 3000 volt Stove wire 300 voh Canadian type solid Stove wire 300 volt Canadian type stranded Rheostat wire 300 yoh high temperature Motor lead cable 1000 voh moll Permanent weave lead wires, extra flexible Power cable multi-conductor armored AVC Power cable multi-conductor lead sheathed AVC Aircraft wire aluminum conductor Aircraft wire high temperature 400* F and 650 P Apparatus cable 1000 volt small diameter Control cable 600 voh armored AVC 5- * AVA Control Cable Control cable 600 volt led sheathed AVC ............ Control Cable Control wire color coded small diameter Motor Lead Wire Rocktberm, Class 180 Motor Appliance and Fixture Wire Lead Appliance and fixture wire 300 volt 200 C Control Cable Rocktberm Control Cable 600 volt 125* C Control Cable Rockthcrm Control Cable 600 vo!tl2S*C Control Cable Rockthcrm Control cable 600 volt 125 C Control Cable Rocktberm Control cable 600 Control Cable volt 125* C Control cable AVA conductors Power Cable Power Cable Power Cable Power cable AVA conductors, armored Power Cable Power cable AVA High Temperature Wire conductors, armored Firezone 101 nigh temperature wire Furnace and Mud Gun Cable Furnace,and mud gun cables 600 voh 49*C Power Cable Power Cable Miscellaneous Power cable, Rockthcrm Power cable, Rockthcrm Capillary tubing, asbestos covered Miscellaneous Mining Cables Nichrome heating cable Mining machine cable . Shipboard Cable Instrumentation Cable IEEE Shipboard cables Firewall IQ instrumentation cables | a m - Power Cable Control Cable Firewall JQ control cables Instrumentation Cablet Power Cable Pyrotrol IQ Instrumentation cables Pyrotrol m power cables Control Cable High temperature Cable Pyrotrol IQ Control Cables ri-zooe 350