Document a484GGNQZyvLwKqwYEQ0Ob9aB

ELLIOTT, J. COURT OF COMMON PLEAS BUTLER COUNTY, OHIO PLAINTIFFS I EXHIBIT CCS- 3 4 ROGER DALE BLAKE, ET AL Plaintiffs VS. A-BEST PRODUCTS COMPANY, ET AL Defendants CASE NO. CV96 01 0191 DEFENDANT CROWN CORK & SEAL COMPANY'S ANSWERS TO PLAINTIFFS' MASTER SET OF INTERROGATORIES PROPOUNDED TO CROWN CORK AND SEAL COMPANY, INC. Answer 1: Crown Cork & Seal Company, Inc., a New York corporation, has never manufactured, processed, sold or distributed asbestos products. In November of 1963, Crown Cork & Seal purchased some stock of Mundet Cork Corporation. Mundet Cork Corporation continued to exist and at that time had two divisions: a Cork Products Division and a Thermal Insulation Contract Division. This purchase by Crown Cork & Seal Company, Inc. was done for the purpose of acquiring Mundet Cork Corporation's Cork Products Division, which fit into Crown Cork & Seal's line of business. Crown Cork & Seal Company, Inc. had no interest in acquiring or in having anything to do with the Thermal Insulation Contract Division. The Thermal Insulation Contract Division of Mundet Cork Corporation may have manufactured, processed, sold or distributed some asbestos products, but Crown Cork & Seal Company, inc. is not even sure that this is the case since Crown Cork & Seal Company, Inc. had no interest in that division. The Cork Products Division did not manufacture, process, sell or distribute any asbestos products. Immediately after the acquisition by Crown Cork & Seal Company, Inc. of some stock of Mundet Cork Corporation, the latter company halted the operation of the Thermal Insulation Contract Division and began looking for a purchaser of that division. Less than three months later, on February 8, 1964, Mundet Cork Corporation sold the entire Thermal Insulation Contract Division to Baldwin-Ehret-Hill, Inc. Pursuant to that sale, Baldwin-EhretHill, Inc. took over all of the equipment, inventory, contracts and all personal property, including all files and records of the Thermal Insulation Contract Division. As a consequence. Crown Cork & Seal Company, Inc. has no records or documents. Almost one and a half years later, in December of 1965, Mundet Cork Corporation, which at the time had only one division, i.e., Cork Products Division, ceased to exist and the assets of that division were transferred to Crown Cork & Seal Company, Inc. Answer .2: See answer to Interrogatory No. 1. Answer 3: See answer to Interrogatory No. 1. Answer A: See answer to Interrogatory No. 1. Answer 5: See answer to Interrogatory No. 1. Answer 6: See answer to Interrogatory No. 1. 7: See answer to Interrogatory No. 1. Answer 9: See answer to Interrogatory No. 1. Answer .2: See answer to Interrogatory No. 1. Answer _12__ thru 10,4: See answer to Interrogatory No. Answer .11: See answer to Interrogatory No. 1. Answer .12: See answer to Interrogatory No. 1. Answer .12: See answer to Interrogatory No. 1. Answer .14: See answer to Interrogatory No. 1. Answer .12: See answer to Interrogatory No. 1. Answer See answer to Interrogatory No. 1. Answer _U: See answer to Interrogatory No. 1. Answer JL2: See answer to Interrogatory No. 1. Answer 22: See answer to Interrogatory No. 1. Answer 22: See answer to Interrogatory No. 1. Answer _21: See answer to Interrogatory No. 1 Answer 22: See answer to Interrogatory No. 1 Answer._22: See answer to Interrogatory No. 1 Answer _Z4: See answer to Interrogatory No. 1 Answer 25: See answer to Interrogatory No. 1 Answer .23.' See answer to Interrogatory No. 1 Answer 27: See answer to Interrogatory No. 1 Answer 25: See answer to Interrogatory No. 1 Answer 29: See answer to Interrogatory No. 1 Answer 30: See answer to Interrogatory No. 1 Answer 31: See answer to Interrogatory No. 1 Answer _22: See answer to Interrogatory No. 1 Answer .22: See answer to Interrogatory No. 1 Answer 34: See answer to Interrogatory No. 1 Answer 35: See answer to Interrogatory No. 1 Answer 3$: See answer to Interrogatory No. 1 Answer 37: See answer to Interrogatory No. 1 Answer 38: See answer to Interrogatory No. 1 Answer .29: See answer to Interrogatory No. 1 Answer 40: See answer to Interrogatory No. 1 Answer Ali See answer to Interrogatory No. 1 Answer AZ: See answer to Interrogatory No. 1 Answer Al: See answer to Interrogatory No. 1 Answer AAi See answer to Interrogatory No. 1 Answer 15: See answer to Interrogatory No. 1 Answer 4$: See answer to Interrogatory No. 1. Answer 47: See answer to Interrogatory No. 1. Answer 48: See answer to Interrogatory No. 1. Answer 49: See answer to Interrogatory No. 1. Answer. 50: Answer _51: See answer to Interrogatory No. 1. See answer to Interrogatory No. 1. Answer _52: Answer 53: See answer to Interrogatory No. .1. See answer to Interrogatory No. 1. Answer 54: Answer. 55: See answer to Interrogatory No. 1. See answer to Interrogatory No. 1. Answer _56: Answer 57: See answer to Interrogatory No. 1. See answer to Interrogatory No. 1. Answer 58: See answer to Interrogatory No. 1. Dated: CROWN CORK & SEAL COMPANY, INC. : Ix-'U BY Richard L. Krzyzarfo)tfski Its Vice President 9300 Ashton Road Philadelphia, PA 19136 ___, 1997. STATE OF PENNSYLVANIA COUNTY OF PHILADELPHIA ) ) ss: ) Richard L. Krzyzanowski, being first duly sworn, deposes and says that he is Vice President of Crown Cork & Seal Company, Inc., that he has read the foregoing Answers of Crown Cork & Seal Company, Inc. to Plaintiffs' Master Set of Interrogatories Propounded to Crown Cork and Seal Company Inc. by him subscribed and knows the contents thereof/ and that the foregoing answers are true to the best of his knowledge and belief. JUU) I" Cu/ Richard L. Krzyzanpwfek Subscribed and sworn to before me, a notary public, by Richard L. Krzyzanowski, thig^*7-^''" jiay o-f 1997. NOTARIAL SEAL THERESA RAUSCH. Notwy PuWc Otty of Philadelphia, Phta. County My Cormtasion Expires May 9.2000 ____ Notary Public, Philadelphia County, Pennsylvania My commission expires $ r2c>oo PROOF OF SERVICE I hereby certify that I have this date mailed a copy of the foregoing Answers of Crown Cork & Seal Company, Inc. to Plaintiffs' Master Set of Interrogatories Propounded to Crown Cork and Seal Company Inc. to Steven D. Wolens, Esq., Baron & Budd, The Centrum, Suite 1100, 3102 Oak Lawn Avenue, Dallas, Texas 75219 and Andrew S. Lipton, Esq., Manley, Burke, Lipton & Cook, 225 West Court Street, Cincinnati, Ohio 45202, Attorneys for Plaintiffs; and notice of filing of these Answers was given to all other defendants and/or their counsel by copy of the Distribution List attached. ROBERT L. DAVIS (SCT #0014831) Counsel for Defendant, Crown Cork and Seal Company, Inc. dr:2/5/97 Date Robert L. Davis ATTORNEY AT LAW 3800 CAREW TOWER CINCINNATI. OHIO 45202 February 28, 1997 TELEPHONE (AREA CODE S13 341*3500 RE: Asbestos Litigation Court of Common Pleas, Butler County, Ohio Roger Dale Blake, et al v. AC&S, INC., et al Case No. CV96 01 0191 TO DEFENDANTS and/or DEFENSE COUNSEL OF RECORD: Please be advised that I am filing Defendant Crown Cork & Seal Company's Answers to Plaintiffs' Master Set of Interrogatories Propounded to Crown Cork and Seal Company, Inc., a defendant in the case listed above. No copy of said answers to interrogatories is enclosed; however, if you desire a copy, please advise. Very truly yours ROBERT L. DAVIS RLD:dr cc: Steven D. Wolens, Esq. Andrew S. Lipton, Esq. COURT OF COMMON PLEAS BUTLER COUNTY, OHIO DISTRIBUTION LIST Ruth A. Antinone, Esq. Suite 705-708 700 McKnight Park Drive Pittsburgh, PA. 15237 Regina M. Massetti, Esq. Suite #530 113 St. Clair Avenue Cleveland, Ohio 44114 Maria A. Kortan, Esq. Harry Sigmier, Esq. 2500 Terminal Tower 150 Public Square Cleveland, Ohio 44113-2241 Charles R. Janes, Esq. 155 E. Broad Street, 16th Floor Columbus, Ohio 43215-3617 James P. Conroy, Esq. Walter & Haverfield 1300 Terminal Tower Cleveland, Ohio 44113-2253 Thomas L. Czechowski, Esq. Porter, Wright One South Main Street P.O. Box 1805 Dayton, Ohio 45202-2028 Joni Mangino, Esq. Zimmer Kunz 3300 USX Tower Pittsburgh, PA. 15219-2702 A-Best Products Ferro Engineering Division of Oglebay Norton Clark Industrial U.S. Mineral General Refractories Rock Wool Manufacturing Company Georgia-Pacific Corporation Insul Company, Inc. Michael D. Eagen, Esq. Dinsmore & Shohl 1900 Chemed Center 255 East Fifth Street Cincinnati, Ohio 45202-4797 Mary Ellen Fairfield, Esq. Richard Schuster, Esq. Vorys, Sater, Seymour & Pease 52 E. Gay Street P.O. Box 1008 Columbus, Ohio 43216-1008 Edward J. Cass, Esq. Gallagher, Sharp, Fulton & Norman Bulkley Building, 7th FI. 1501 Euclid Avenue Cleveland, Ohio 44115-2108 Stephen K. Shaw, Esq. Dinsmore & Shohl 1900 Chemed Center 255 East Fifth Street Cincinnati, Ohio 45202-4797 R. Gary Winters, Esq. McCaslin, Imbus & McCaslin 632 Vine Street, Suite 900 Cincinnati, Ohio 45202-2442 Thomas P. Erven, Esq. Young & Alexander Co., LPA 110 Boggs Lane, Suite 350 Cincinnati, Ohio 45246 Mark A. Ropchock, Esq. Roetzel & Andress 75 E. Market Street Akron, Ohio 44308 W. Andrew Hoffman, III, Esq. Friedman & Hoffman 23200 Chagrin Blvd., Suite 720 Three Commerce Park Square Cleveland, Ohio 44122 David C. Patterson, Esq. Arter & Hadden 10 West Broad Street Columbus, Ohio 43215 O.K.I. Supply Company ACandS, Inc. Harbison Walker Refractories INDRESCO Janos Industrial Insulation CSR Limited Minnesota Mining and Manufacturing Company, aka 3M Anchor Packing Foster wheeler Garlock Babcock & Wilcox Beazer East Ohio Valley Insulating Combustion Engineering Barbara J. Arison, Esq. Thompson, Hine & Flory 3900 Society Center 127 Public Square Cleveland, Ohio 44114-1216 Flintkote Kathleen A. Pettingill, Esq. Baker & Hostetler 3200 National City Center 1900 East Ninth Street Cleveland, Ohio 44114-3485 Foseco Reginald S. Kramer, Esq. Buckingham, Doolittle & Burroughs P.O. Box 1500 50 South Main Street Akron, Ohio 44309 General Electric PPG Industries William A. Viscomi, Esq. Gallagher, Sharp, Fulton & Norman Bulkley Building, 7th Floor 1501 Euclid Avenue Cleveland, Ohio 44115 M.H. Detrick Mark R. Chilson, Esq. Young & Alexander Co., LPA 367 West Second Street Suite 100 Dayton, Ohio 45402 Metropolitan Life David Wade Peck, Esq. Barron, Peck & Bennie 1420 PNC Tower One West Fourth Street Cincinnati, Ohio 45202 North American Refractories Thomas Green, Esq. Green & Green 1 Citizens Federal Center 110 N. Main Street Suite 950 Dayton, Ohio 45402 Owens-Corning Fiberglas Gary Hermann, Esq. Kerry S. Volsky, Esq. Herman, Cahn & Schneider Suite 500, 1301 E. 9th Street Cleveland, Ohio 44114 Pittsburgh Corning David A. Schaefer, Esq. McCarthy, Lebit, Crystal & Haiman 1800 Midland Building . 101 Prospect Avenue West Cleveland, Ohio 44115 John Repcheck, Esq. Sharlock, Repcheck & Mahler 3280 USX Tower 600 Grant Street Pittsburgh, PA. 15219 Eric Zalud, Esq. Benesch, Friedlander 1100 Citizens Building Cleveland, Ohio 44114 Percy Squire, Esq. Asbestos Litigation Department Bricker & Eckler 100 South Third Street Columbus, Ohio 43215-4291 Robin L. Canowitz, Esq. Kenneth Harris, Esq. Harris, Carter, Mahota & Mazza 500 S. Front Street, Suite 1010 Columbus, Ohio 43215 Donald A. Powell, Esq. Buckingham, Doolittle 50 South Main Street Akron Center Plaza Akron, Ohio 44309-1500 Thomas F. Dougall, Esq. Bowers Orr & Robertson, LLP 1401 Main Street, Suite 1100 Post Office Box 7307 Columbia, South Carolina 29202 and Steven R. Bartram, Esq. Suite 700, River Tower 1108 Third Avenue P.O. Box 2488 Akron, Ohio 25725 Rapid American Union Boiler Uniroyal - Westinghouse Electric W.R. Grace Synkoloid Company Proko Industries