Document b586Q2LOE1aRjq24o9LMpaKb0

DOCUMENT NUMBER: 2l35SOOl Pulled for Attorney-Client Privilege/Work Product DOCUMENT NUMBER: 2I3&5QO/ Pulled for Attorney-Client Privilege / Work Product 4 UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OHIO WESTERN DIVISION Mary A. Dendinger, et al., ) Case No. C87-7117 ) Plaintiffs, ) [Hon. Nicholas J. Walinski] vs. ) ) Chrysler Plastic Products ) DEFENDANT THE BFGOODRICH CO. ) RESPONSES TO PLAINTIFFS' Corporation, et al., ) REQUEST FOR PRODUCTION ) OF DOCUMENTS 101-110 Defendants. ) ) [Louis E. Tosi (0019756) ) Robert A. Bunda (0019775) ) Peggy A. Whipple (0029589) ) One SeaGate ) 17th Floor ) P.O. Box .2088 ) Toledo, Ohio 43603 ) Telephone: (419) 247-2500 ) Attorneys for Defendants: ) The BFGoodrich Co., The ) Firestone Tire & Rubber ) Company, Conoco, Inc., ) Uniroyal, Inc., Tenneco, Inc., ) Tenneco Polymers, Inc., Union ) Carbide Corporation and ) Occidental Chemical Corp.] For its response to plaintiffs' request for production of documents, Nos. 101-110, Defendant The BFGoodrich Co., responds as follows: REQUEST FOR PRODUCTION OF DOCUMENTS NO.101: All correspondence and documents sent to or received from the Manufacturing Chemists Association or any committee BFG13349 21356001 i Answer: Answer: Answer: Answer: thereof, prior to 1975, pertaining to vinyl chloride or polyvinyl chloride. Defendant The BFGoodrich Co., has no documents which satisfy this request. Request For Production Of Documents No. 102: All correspondence and documents sent to or received from any other polyvinyl manufacturer, or any employee thereof, prior to 1975, regarding vinyl chloride or polyvinyl chloride. Defendant The BFGoodrich Co., has no documents which satisfy this request. Request For Production Of Documents No. 103: All internal (within your company) communications, bulletins and memoranda, authored prior to 1975, concerning the actual or potential chronic health effects, including cancer, in animals or humans, of exposure to vinyl chloride. Defendant The BFGoodrich Co., has documents which satisfy this request. These records are voluminous and are available for copying at plaintiffs' expense as is, where is. To arrange for inspection and copying of these records, plaitiff should contact: Robert A. Bunda, Esq., who requests 5 days advance notice to make necessary arrangements at Fuller & Henry, One SeaGate, 17th Floor, Toledo, Ohio 43603, Telephone: (419) 247-2500. Request For Production Of Documents No. 104: All documents in your possession relating to the tentative, preliminary and final results of any studies, surveys, reports, articles, tests or analyses pertaining to the actual or potential chronic health affects, including cancer, in animals or humans, of exposure to vinyl chloride which have not appeared in published medical or scientific journals. Defendant The BFGoodrich Co., has documents which satisfy this request. These records are voluminous and are available for copying at plaintiffs' expense as is, where is. To arrange for inspection and copying of these records, plaitiff should contact: Robert A. Bunda, Esq., who requests 5 days advance notice to make necessary arrangements at Fuller & Henry, One SeaGate, 17th Floor, Toledo, Ohio 43603, Telephone: (419) 247-2500. BFG13350 Answer: Answer: Answer: Answer: Answer: Answer: Request For Production Of Documents No. 105: All documents in your possession inconsistent with or refuting the sworn deposition testimony in this case of your designated representative(s) regarding RVCM concentrations in your resins. Defendant The BFGoodrich Co. , has no documents which satisfy this request. Request For Production Of Documents No. 106: All documents pertaining to the RVCM concentrations in your resins prior to 1980, which you have not previously produced. Defendant The BFGoodrich Co., has no documents which satisfy this request. Request For Production Of Documents No. 107: Each and every document you intend or expect to introduce into evidence at the trial of this action. This defendant objects to Request For Production Of Document No. 107 as calling for attorney-work product information which is immune from discovery pursuant to FRCP 26(b) (3) . Request For Production Of Documents No. 108: Each and every document reviewed or examined by any of your witnesses in the course of preparing for trial testimony. This defendant objects to Request For Production Of Document No. 108 as calling for attorney-work product information which is immune from discovery pursuant to FRCP 26(b) (3) . Request For Production Of Documents No. 109: Each and every document which will be used by any of your witnesses in the course of giving trial testimony. This defendant objects to Request For Production Of Document No. 109 as calling for attorney-work product information which is immune from discovery pursuant to FRCP 26(b) (3) . Request For Production Of Documents No. 110: Each and every document upon which any of your witnesses will rely or base his or her trial testimony. This defendant objects to Request For Production Of 21350003 BFG13351 Document No. 110 as call information which is immu FRCP 26(b)(3). ajttorney-work. product scovery/pursuant to Of Counsel for The B.F. Goodrich Co., The Firestone Tire & Rubber Company, Conoco, Inc., Uniroyal, Inc., Tenneco, Inc., Tenneco Polymers, Inc., Union Carbide Corporation, and Occidental Chemical Corp.: Louis E. Tosi Robert A. Bunda Peggy Ann Whipple One SeaGate, 17th Floor P.0. Box 2088 Toledo, Ohio 43603 Telephone: (419) 247-2500 Trial Counsel for The B.F. Goodrich Co., The Firestone Tire & Rubber Company, Conoco, Inc., Uniroyal, Inc., Tenneco, Inc., Tenneco Polymers, Inc., Union Carbide Corporation, and Occidental Chemical Corp. CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Responses of The BFGoodrich Co., to Plaintiffs' Request for Production of Documents has been mailed by United States Mail, postage prepaid, to Kirk J. Delli Bovi, Esq., attorney for plaintiffs, at his office located at Murray & Murray Co., L.P.A., 300 Central Avenue, Sandusky, Ohio 44870, and to defense counsel as set is /J^t forth in the attached Schedule of Service this day of December, 1988. too9seiz An Attorney for Defendants The B.F. Goodrich Co., The Firestone Tire & Rubber Company, Conoco, Inc., Uniroyal, Inc., Tenneco, Inc., Tenneco Polymers, Inc., Union Carbide Corporation, and Occidental Chemical Corp. BFG13352 STATE OF OHIO ) CUYAHOGA COUNTY ) SS IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OHIO WESTERN DIVISION Mary A. Dendinger, et al. Plaintiffs vs Chrysler Plastic Products Corporation, et al.. Defendants ) Case No. C87-7117 ) > ) ) ) ) ) ) ) I, Gregory L. Rutman, being duly sworn, state that I am Assistant Secretary of The B.F.Goodrich Company; that the responses to plaintiffs' request for production of documents are not based upon my personal knowledge but are based upon information contained in regular business records and upon information received from other employees; and that the responses to plaintiffs' request for production of documents are true and correct to the best of my knowledge and information. Gregory L. Rutman Assistant Secretary The B.F.Goodrich Company 6100 Oak Tree Boulevard Cleveland, OH 44131 (216) 447-6001 Subscribed and sworn to before me this 8th day of December, 1988. S009SET?! klw/2712k Notary Public WOOOROWW. BAN. Notary fubfe STATE OF OHIO AAttttGcnri?:53>V *L/stime rCVo.mmmmiKs^siinonn Recorded in Lake and Cuyahofa CetaCw BFG13353