Document YjVxj3B59xKzYN6JYK8RMXRaK

11-17-1993 12:04 IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF NORTH CAROLINA IN R: ASBESTOS-RELATED ) LITIGATION ) MDCP-82-1 THE FLZNTROTE COMPANY'S RESPONSES TO PLAINTIFFS' INTERROGATORIES COMES NOW the Defendant^ The Flintkote Company by and through ita uncersigned agent# Arthur R. Hooker# Jr. aa evidenced by the evorn atatement attached to "The Flintkote Company'a Responaea to Plaintiff'a Standard Interrogatoriea to All Defendants* and states the following with reapect to the attached. 1. Each reaponae separately and fully answers each Interrogatory except thoae to which objections are made and a separate document is filed herewith containing the numbers of .those Interrogatoriea to which objections are made. 2. That these answers are given on behalf of The Flintkote Company by Arthur R. Booker# Jr. in the capacity of ManagerPurchasing aa set out on his signed and verified statement attached to the document entitled "The Flintkote Company's Responses to Plaintiff's Standard Interrogatories to All Defendants". This the jP* day of April# 1883. T OF COUNSEL Richmond W. Rucker "wr H. Lee Davis# Jr. Attorneys for The Flintkote Company P.0. Drawer 814 Winston Salem# NC 27102 Telephone: (919) 72S-838S HUTCHINS# TYNDALL# DOUGBTON MOORE P.O. Drawer 814 Winston Salem# NC 27102 (919) 71S-838S APS 12 133 1i-17-1993 12:04 P.04 ADDITIONAL PRODUCTS ONCE MANUFACTURED BY FLINTXOTZ .Product Period of Manufacture Approximate Asbestos Content Asbestos Cement Board 1950-197.0 10-15% Asbestos Cement Pipe 1992-1977 19% Asbestos Cement Siding end Roofing Shiagles Approx, early 1950s to early 1990s 10-15% *Asphalt Saturated. Asbestos Felt (Built-up Roofing) Approx. 1959-1979 95% Flooring-Asbestos Vinyl Floor Tile Approx. 1940-19B1 -14% Fiber Pipe 1959-1972 1--1/2% Van Packer Chimneys 1994-1971 (a) Commercial chimneys for those products that used asbestos .fiber - (only jackets whieh are a small part of overall product) 22% (b) Residential chimneys 20% * * Flintkote purchased the asbestos felt from other manufacturers and merely saturated it with asphalt in their own facilities. PRODUCTS MANUFACTURED BY OTHERS BUT SOLD BY FLINTKOTE f Period of Sale Joint Treatment Compound Through 1979 5% Spray Texture Paint 1974-1979 . 4-5% Ceiling Tile 1999-1974 2% Asphalt Saturated Asbestos Felt (Built-up Roofing) Intermittently from approx. 1941-1992 95% In addition, the products denoted by a double asterisk (*#) on the preceding pages of this exhibit are products presently manufactured by others but sold by Flintkote. 11-17-1993 12:05. > P.05 STATE or TEXAS ) ) COUNTY or DALLAS ) IIIIatiom M- AJtTHUK H. HOOKEA/ JK., being duly sworn / dsposss and says that ha is Manager-Purchasing for defendant THE PLZNTXOTS COMPANY# a corporation; that ha has raad tha foregoing Inter rogatories; that said responses are based on documents in the files of THE FLXNTX6tE COMPANY# and on the knowledge and memory of various employees of THE FLXNTKOTE COMPANY; and that such responses are true and correct to the best of his knowledge# information and belief/ EXECUTED THIS day of 1983# at Irving Texas. Sworn to and Subscribed before me this */^*"day. of 1983. ___ tfOTAKY 9uEtld iN AND FOR &Alfl COUNTY AND STATE FORMER EMPLOYEES OF THE FLINTKOTE COMPANY WHO HAVE TESTIFIED IN CASES WHEREIN PLAINTIFFS ALLEGED BODILY INJURY FROM THE USE OF FLINTKOTE'S ASBESTOS-CONTAINING PRODUCTS ON JOBSITES - Frank c. Dresman - Purchasing Agent for Flintkote's Pioneer Division Deposition: November 29, 1984 In Re: Dorothy St. Jacques v. Johns-Manvilie Coro.. et al. Superior court of the state of California For the County of Los Angeles Case No. C437165 Court Reporter: Norman Schall 6 Associates 2001 W. Olympic Boulevard, Los Angeles, CA 90006 Arthur R. Hooker, Jr. - Manager of Purchasing, Genstar Building Materials Co. Deposition: December 4, 1984 In Re: Pearline Wilburn, etc, vs. The Celotex Corporation, et al*. United States District Court for the Eastern District of Tennessee, Northern Division Case No. 3-84-492 Court Reporter: Thomas Crites & Associates, International, Inc. P.O. Box 9438, Savannah, Georgia 33412 Deposition: April 12 and 13, 1984 In Re: Sterns. Brown & Finney Consolidated,for Discovery Related Shipyard and Applicator Asbestos Cases Superior Court of the State of California In and for the County of Alameda Case Nos. 573686-9 and 805555 Court Reporter: Patricia Callahan & Associates . 337 17th Street, Oakland, California James L. Houser - National Product Manager, Genstar Building Materials Division Deposition: March 6, 1986 In Re: Helen Volpe. etc, vs. P.S. Gypsum. Inc.. Superior Court of the State of New Jersey, Middlesex County Docket No. L-034310-84 Court Reporter: Seymour Schulman k Associates EXHIBIT J James A. Main - Vice President of The Flintkote Company Deposition: September 20, 1984 In Re: Dorothy St. Jaccrue. et al. vs. JohnsManville Sales Corporation, et al. Superior Court of the State of California For the County of Los Angeles case No. C137 465 Court Reporter: Sanders, Crate & Russell Hartford, Connecticut John C. Schmitt - Flintkote Product and Plant Safety Manager Deposition: January 11, 1985 In Re: Sterns. Brown & Finnev Consolidated for Discovery Related Shipyard and Applicator Asbestos Cases Superior Court of the State of California For the County of Alameda Case Nos. 805 555 and 573687-9 Court Reporter: Esquire Reporting Co., Inc. 41 E. 42 Street, New York, New York 10017 ' Deposition: June 5, 1985 In Re: Primavera vs. Ravmark Industries. Inc.. et-SLt. United States District Court for the Eastern District of Pennsylvania Case-No. 83-4975 Court Reporter: McKinley Wise & Associates Inc. 1211 Chestnut Street, Philadelphia, Pennsylvania 19107 Deposition: January 8, 1987 In Re: William F. Conkwricht. Inc., AC&S. Inc.. at al. United States District Court District of Arizona Court Reporter: Driver & Reeves 2025 N. Third St., Ste. 175 Phqenix, Arizona 85004 et al. vs. Trial testimony: July 12, 1993 In Re: Vincent. Tabolt. et al. vs. Armstrong_World Industries. Inc., et al. United States District Court, Southern District of New York, New York Division case No. 92CIV0763 Court Reporter: Southern District Reporters New York New York AAA0650E 09/30/93