Document b5GwOeVEdJm15MOD27Rr2bp2O

1-26-1994 11557 5GB 1 In compliance with 2 produce for testimony one or more officers, directors, managing agents 3 and/or person(s) on its behalf and who have knowledge of facts known 4 or reasonably available to ALCOA concerning the following items: 5 1. Any and all records or other information concerning any and 6 all work performed by Hubert E. Wright at the ALCOA plant in 7 Vancouver, Washington, during the years 1944 through 1971 inclusive, 8 including, but not limited to his work in the Mechanical Maintenance 9 Department and in the "pot" room. 10 2. Any and all records or other information concerning any and 11 all asbestos-containing materials at the ALCOA plant in Vancouver, 12 Washington, during the years 1944 through 1971 inclusive, including, 13 but not limited to, pipecovering and block. 14 3. Details of ALCOA's records retention policy from 1944 until 15 the present, including, but not limited to, specific policy(s) 16 regarding retention of the following records for the years 1944 to 17 1971 inclusive: employee records including, but not limited to, job 18 descriptions and specific job assignments; repair of furnaces and 19 boilers and pipecovering; installation of new furnaces and boilers and 20 pipecovering; specification manuals on any and all boilers; and 21 records reflecting purchase and receipt of asbestos or asbestos22 containing products. 23 Plaintiffs specifically request and expect that defendant comply 24 with Civil Rule 30(b)(6). 25 This testimony upon oral examination will be taken on the ground 26 and for all purposes set forth under the Civil Rules; that the said Notice of Deposition Pursuant To Civil Rule 30(b)(6) - 2 ALCOA0002298 SCHROETER. GOLDMARK A BENDER. "" *TL*W-- ................. 500 Centra] Building 810 Third Avenue Seittle. Washington 98104 <206i6??.8nnft RF 26-1994 11:57 t 5GB 206 682 2305 P.05/05 1 witness will give evidence materiel to the establishment of the 2 plaintiffs' case. 3 DATED this 4 day of r , 1994. SCHROETER, GOLDMARK & BENDER 5 6 RUTZI 7 Counsel for Plaintiffs Bar Membership No. 11533 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Notice of Deposition Pursuant To Civil Rule 30(b)(6) - 3 ALCOA0002299 Schhoeteh .AGTTOoRlNdEYmS a*Trk t1 Bender..,.m.. . 500 Central Building - 810 Third Avenue Seinle. Wuhingion 9810* TOTAL P.05