Document bBaRV90VB9zYJKLK2Zewyojx3

NO. 92-10123 CHARLES NORMAN WHITE and PAULINE WHITE; HARVEY LEWIS SHADDOX and MARY SHADDOX; ORVEL WOODROW FITTS and MAVIS FITTS; LEO L. DARDEN and RUTH DARDEN; and DANIEL ALLEN DALTON, SR. and MARITA DALTON, Plaintiffs, versus KEENE CORPORATION, et al., Defendants. IN THE DISTRICT COURT TRAVIS COUNTY, TEXAS 353RD JUDICIAL DISTRICT WES1TNGHOUSE ELECTRIC CORPORATION'S OBJECTIONS AND RESPONSES TO PLAINTIFFS' INTERROGATORIES MAILED TO DEFENDANT ON OR ABOUT APRIL 21. 1993 TO: Plaintiffs, by and through their counsel of record, Russell W. Budd, Baron & Budd, The Centrum, 3102 Oak Lawn Avenue, Suite 1100, Dallas, Texas 75219. Comes now Westinghouse Electric Corporation ("Westinghouse"), by and through its attorneys of record, and files these Objections and Responses to Plaintiffs' Interrogatories Mailed to Defendant on or about April 21, 1993. Preliminary Statement and General Objections Westinghouse has a history of cooperation with plaintiffs' counsel, Baron & Budd, and has produced substantial discovery consisting of documents, witnesses and answers to interrogatories. The current interrogatories request verification of the authenticity of certain documents which presumably were previously produced by Westinghouse to Plaintiffs along with literally thousands of other documents. However, many of these documents were not prepared by Westinghouse and Westinghouse cannot attest to their authenticity. Specifically, WESTINGHOUSE ELECTRIC CORPORATION'S OBJECTIONS AND RESPONSES TO PLAINTIFFS' INTERROGATORIES MAILED TO DEFENDANT ON OR ABOUT APRIL 21. 1993 - Page 1 Westinghouse lacks the first hand knowledge necessary to determine whether each of these documents is genuine and authentic. Likewise, the origin of many documents cannot be confirmed as Westinghouse documents because Plaintiffs have supplied copies which do not carry a readable bates number. Furthermore, many of the documents themselves are illegible. Finally, many documents on their face appear to be Westinghouse documents but contain other information either typed or hand written which would not have been found on the original document. Again, without knowing the source of the document or at least the source of this extraneous information, Westinghouse cannot attest to the documents authenticity. In essence, Plaintiffs have failed to provide sufficient information for Westinghouse to provide accurate and meaningful responses. Westinghouse-'s responses to these Interrogatories are made without in any way waiving: (1) the right to object, on the grounds of competency, relevancy, materiality, hearsay or any other proper grounds, to the use of any such information for any purpose, in whole or in part, in any subsequent stage or proceeding in this action or any other action; or (2) the right to object on any and all grounds, at any time, to any other discovery procedure relating to the subject matter of these Interrogatories. Without waiving these objections and subject thereto Westinghouse further responds to the Interrogatories as follows: INTERROGATORIES INTERROGATORY NO. 1: For each document listed below, please answer whether such document is a true and correct duplicate of a genuine and authentic document: ANSWER: See general objection. Subject to these objections, these documents appear to be copies of materials provided by Westinghouse to Plaintiffs in various cases. INTERROGATORY NO. 2: For each document listed below, please answer whether such document was kept and/or generated in the regular course of a regularly conducted business activity of any Westinghouse Entity by an employee or representative of any Westinghouse Entity with knowledge of the act, event, condition or opinion recorded. WESTINGHOUSE ELECTRIC CORPORATIONS OBJECTIONS AND RESPONSES TO PLAINTIFFS* INTERROGATORIES MAILED TO DEFENDANT ON OR ABOUT APRIL 2L 1993 - Page 2 ANSWER: See general objection and response to Interrogatory No. 1. The attached documents appear to have been produced to Plaintiffs' counsel by Westinghouse. However, because hundreds of thousands of pages of documents have been made available to Plaintiffs from a large variety of sources within Westinghouse, Westinghouse is unable to determine whether the materials were maintained in the regular course of regularly conducted business activity. Therefore, Westinghouse cannot attest that these documents were "kept and/or generated in the regular course of a regularly conducted business activity of any Westinghouse entity by an employee or representative of any Westinghouse entity with knowledge of the act, event, condition or opinion recorded." The foregoing is also true with respect to any document produced by Westinghouse which was generated by some source outside the corporation. Subject to the foregoing objections and without waiving same see individual responses below. EXHIBIT NO. DESCRIPTION a) WH-55 Westinghouse Electric & Manufacturing Company, Purchasing Department specification No. 7305-A. Blanket Insulation over 850 F., Approved December 20, 1934, Revised, February 5, 1934. Bates Nos. 000874-000875. ANSWER: Appears to be a document generated by Westinghouse. b) WH-57 Materials File Card No. 8407. Re: Cement, Heat Insulating (Plastic Insulations). June 5, 1946. Westinghouse Standards Department. Bates No. 000672. ANSWER: Appears to be a document generated by Westinghouse. c) WH-93 Materials File Card (2 pages). No. 46601AA thru AC. Re: Heat Insulating Block, High Temperature. April 5, 1969. Westinghouse Standards Department. Bates No. 000908. ANSWER: Appears to be a document generated by Westinghouse. WESTINGHOUSE ELECTRIC CORPORATION'S OBJECTIONS AND RESPONSES TO PLAINTIFFS' INTERROGATORIES MAILED TO_DEFENDANT ON OR ABOUT APRIL 21. 1993 - Page 3 o d) WH-326 Document titled "Sample Sheets 1951" with attachment. ANSWER: Appears to be a document generated by Westinghouse. e) WH-327 Document titled "Sample Sheets 1952" ANSWER: Appears to be a document generated by Westinghouse. f) WH-333 Document titled "Legal Guidelines for Business Writing" with attached "Terms & Definitions Commonly Used" ANSWER: Appears to be a document generated by Westinghouse. g) WH-337 Document titled "Table I, Evaluation of Asbestos Exposure Results of Air Samples" ANSWER: Appears to be a document generated by Westinghouse. h) WH-338 Memo dated March 27, from Wesley E. Pinos, to IN Transportation & Generator, Harry Mower, Safety Engineer. ANSWER: Appears to be a document generated by Westinghouse. i) WH-339 Photocopy of products used on turbine: Insulation, Flange Cover Insulation,-Crossover Pipe Moulded Insulation and Block Insulation. ANSWER: Appears to be a document generated by Westinghouse. j) WH-340 The Saranac Laboratory for the Study of Tuberculosis of the Edward L. Trudeau Foundation letter dated January 31, 1936 from Leroy U. Gardner, M.D., Director to E. C. Bames, Westinghouse Electric Company. ANSWER: This is not a Westinghouse generated document. WESTINGHOUSE ELECTRIC CORPORATION'S OBJECTIONS AND RESPONSES TO PLAINTIFFS* INTERROGATORIES MAILED TO DEFENDANT ON OR ABOUT APRIL 21. 1993 - Page 4 k) WH-341 Letter dated December 23, 1936 from Susy Schu... to Mr. Barnes, Westinghouse Company. ANSWER: This is not a Westinghouse generated document. I) WH-342 Report titled "Intraperitoneal Reactions caused by Dusts, G20, G21 and G22. Preliminary Report" submitted by Susy Schu... (injection September 23, 1936) ANSWER: This is not a Westinghouse generated document. m) WH-345 Statement of Claim. Home v. Westinghouse Electric and Manufacturing ComDanv. Court of Common Pleas of Allegheny Countv. Pennsylvania. August 1937. ANSWER: This is not a Westinghouse generated document. n) WH-346 Pittsburgh Plate Glass Company letter dated September 16, 1938 from F. R. Holden, Ph.D. Industrial Hygienist to E. Barnes, Westinghouse Electric and Manufacturing Co. ANSWER: This is not a Westinghouse generated document. o) WH-347 Memorandum dated January 11, 1946 from E. C. Barnes, Headquarters Medical Department to South Philadelphia Works. ANSWER: Appears to be a document generated by Westinghouse. p) WH-348 Memorandum dated April 20, 1948 from E. C. Barnes to 3-B-42 Trans. & Generator Div., Mr. Paul Edelman. ANSWER: Appears to be a document generated by Westinghouse. q) WH-349 Memorandum dated May 14, 1948 from E. C. Barnes to Sharon Works, R. L. Miller. ANSWER: Appears to be a document generated by Westinghouse. WESTINGHOUSE ELECTRIC CORPORATION'S OBJECTIONS AND RESPONSES TO PLAINTIFFS' INTERROGATORIES MAILED TO DEFENDANT ON OR ABOUT APRIL 21.1993 - Paw S r) WH-350 Memorandum dated June 11, 1954 from N. Wilbur Speicher, to South Philadelphia Works, W. E. McKeldin. ANSWER: Appears to be a document generated by Westinghouse. s) WH-351 Memo dated July 24, 1957 from H. Wilbur Speicher to James McClimans; re: Report of Plant Visit. ANSWER: Appears to be a document generated by Westinghouse. t) WH-353 Westinghouse memo dated April 16, 1958 from C. F. Ehalt to Office Methods Representatives, Manager ofEast Pittsburgh Accounting; subject: Revision of Procedure for Preservation and Destruction of Records - East Pittsburgh Departments. ANSWER: Appears to be a document generated by Westinghouse. u) WH-357 Letter dated October 15, 1971 from Pete Rotelli to Hon. George Guenther, OSHA. ANSWER: This is not a Westinghouse generated document. v) WH-358 Owens-Coming Fiberglas letter dated March 1, 1972 from Gerald E. Devitt to H. W. Speicher. ANSWER: This is not a Westinghouse generated document. w) WH-360 Handwritten note concerning Asbestos Cloth with date 8/7/72 and name of Bill Lane. ANSWER: Appears to be a document generated by Westinghouse. x) WH-363 Memorandum dated August 28, 1972 from Zella R. Rees to South Philadelphia Works, W. C. Lane. ANSWER: Appears to be a document generated by Westinghouse. WESTINGHOUSE ELECTRIC CORPORATION'S OBTEOTONS AND RESPONSES TO PLAINTIFFS' INTERROGATORTF.S MAILED TO DEFENDANT ON OR ABOUT APRIL. 21. 1993 - Pare 6 y) WH-366 Memorandum dated January 29, 1973 from H. Wilbur Speicher to East Pittsburgh, W. G. Craig. ANSWER: Appears to be a document generated by Westinghouse. z) WH-367 Memorandum dated February 7, 1973 from R. L. Bergquist to East Pittsburgh Works, W. G. Craig, re: Use of Asbestos Material in Soldering Operations. ANSWER: Appears to be a document generated by Westinghouse. aa) WH-369 Memorandum dated February 16, 1973 from H. Wilbur Speicher to East Pittsburgh, W. G. Craig. ANSWER: Appears to be a document generated by Westinghouse. bb) WH-370 Memorandum dated March 19, 1973 from E. J. Hlavaty to D. L. Collier; re: E-4 & 5 Operations involving Asbestos Materials. ANSWER: Appears to be a document generated by Westinghouse. cc) WH-372 Memorandum dated April 16, 1973 from R. L. Bergquist to East Pittsburgh Works 4N5, W. G. Craig; re: Use of Asbestos Material in Soldering Operations P. G. & E. Diablo Canyon #1. ANSWER: Appears to be a document generated by Westinghouse. dd) WH-373 Memorandum dated April 24, 1973 from John F. Adams to East Pittsburgh Works, E. J. Hlavaty; re: Results of Air Samples Taken for Airborne Asbestos Fibers in Section E-5, LRA, East Pittsburgh Works, with attachment. ANSWER: Appears to be a document generated by Westinghouse. ee) WH-374 Memorandum dated May 15, 1973 from John F. Adams to East PGH., F General Office, B. J. Pleunik. ANSWER: Appears to be a document generated by Westinghouse. WESTINGHOUSE ELECTRIC CORPORATION'S OBJECTIONS AND RESPONSES TO PLAINTIFFS' INTERROGATORTE.S MAILED TO DEFENDANT ON OR ABOUT APRIL 21. 1993 - Paw 7 ff) WH-379 Memorandum dated April 18, 1974 from R. A. Gerbrands to East Pittsburgh - Room 2G46, H. W. Speicher, re: Asbestos Blanket, with handwritten notation. ANSWER: Appears to be a document generated by Westinghouse. gg) WH-382 Document entitled Excerpt from "Technological Feasibility and Economic Impact of OSHA Proposed Revision to the Asbestos Standard" prepared by WESTON Environmental Consultants", re: regulation proposed on October 9, 1975. ANSWER: This is not a Westinghouse generated document. hh) WH-383 Article titled "The Asbestos Exposure ofInsulation Workmen". Insulation Hveiene Prowess Reoorts. bv Irvins J. Selikoff. M.D.. Vol. 6. No. 1. Spring 1975. ANSWER: This is not a Westinghouse generated document. ii) WH-384 Memorandum dated January 8, 1975 from Zella R. Heasley to R&D Center - 401-3X9, A. Zervins. ANSWER: Appears to be a document generated by Westinghouse. jj) WH-385 Memorandum dated June 10, 1975 from Dick Wolf to R. C. Boyd, PCB Division. - ANSWER- Appears to be a document generated by Westinghouse. kk) WH-393 South Carolina Department of Labor Citation and Notification of Proposed Penalty dated January 12, 1976; re: Westinghouse Electric Corporation Micarta Division. ANSWER: This is not a Westinghouse generated document. WESTINGHOUSE ELECTRIC CORPORATION'S OBJECTIONS AND RESPONSES TO PLAINTIFFS' INTERROGATORIES MAILED TO DEFENDANT ON OR ABOUT APRIL 21- 1993 - Page S INTERROGATORY NO. 3: For each document listed below, please answer whether such document was found in your files in such a condition as to create no suspicion concerning its authenticity. ANSWER: See general objections and response to Interrogatory Nos. 1 and 2 above. Except as noted below, each of these documents appears in the condition as found in Westinghouse files. EXHIBIT NO. DESCRIPTION b) WH-57 Materials File Card No. 8407. Re: Cement, Heat Insulating (Plastic Insulations). June 5, 1946. Westinghouse standards Department. Bates No. 000672. ANSWER: This document contains unidentified extraneous information. d) WH-326 Document titled "Sample Sheets 1951" with attachment. ANSWER: This document contains unidentified extraneous information. f) WH-333 Document titled "Legal Guidelines for Business Writing" with attached "Terms & Definitions Commonly Used" ANSWER: This document contains unidentified extraneous information. i) WH-339 Photocopy of products used on turbine: Insulation, Flange Cover Insulation, Crossover Pipe Moulded Insulation and Block Insulation. ANSWER: This document contains unidentified extraneous information. j) WH-340 The Saranac Laboratory for the Study of Tuberculosis of the Edward L. Trudeau Foundation letter dated January 31, 1936 from Leroy U. Gardner, M.D., Director to E. C. Barnes, Westinghouse Electric Company. WESTINGHOUSE ELECTRIC CORPORATION'S OBJECTIONS AND RESPONSES TO PLAINTIFFS* INTERROGATORIES MAILED TO DEFENDANT ON OR ABOUT APRIL 21. 1993 - Page 9 ANSWER: Because this document was not generated by Westinghouse, Westinghouse can provide no information regarding its authenticity. k) WH-341 Letter dated December 23, 1936 from Susy Schu... to Mr. Barnes, Westinghouse Company. ANSWER: Because this document was not generated by Westinghouse, Westinghouse can provide no information regarding its authenticity. 1) WH-342 Report titled "Intraperitoneal Reactions caused by Dusts, G20, G21 and G22. Preliminary Report submitted by Susy Schu... (injection September 23, 1936) ANSWER: Because this document is not a Westinghouse generated document, Westinghouse is uncertain as to whether this is a complete document and can provide no information regarding its authenticity. m) WH-345 Statement of Claim. Homa v. Westinehouse Electric and ManufacturinG Comoanv. Court of Common Pleas of Alleehenv Countv. Pennsylvania. August 1937. ANSWER: Not only does this document contain unidentified extraneous information but also it was not generated by Westinghouse and Westinghouse can provide no information regarding its authenticity. Westinghouse is unaware of the basis of this unsubstantiated claim and whether the documents contained herein are a complete copy of the claim. n) WH-346 Pittsburgh Plate Glass Company letter dated September 16, 1938 from F. R. Holden, Ph.D. Industrial Hygienist to E. Barnes, Westinghouse Electric and Manufacturing Co. ANSWER: Not only does this document contain unidentified extraneous information but also this document was not generated by Westinghouse and Westinghouse can provide no information regarding its authenticity. t) WH-353 Westinghouse memo dated April 16, 1958 from C. F. Ehalt to Office Methods Representatives, Manager ofEast Pittsburgh Accounting; subject; Revision of Procedure for Preservation and Destruction of Records - East Pittsburgh Departments. WEST1NGHOUSE ELECTRIC CORPORATION'S ORTECTIONS AND RESPONSES TO PLAINTIFFS' INTERROGATORIES MAILED TO DEFENDANT ON OR ABOUT APRIL 21. 1993 - Page 10 1 ANSWER: This document contains unidentified extraneous information. u) WH-357 Letter dated October 15, 1971 from Pete Rotelli to Hon. George Guenther, OSHA. ANSWER: Not only does this document contain unidentified extraneous information but also is a non-Westinghouse generated document and Westinghouse can provide no information regarding its authenticity. v) WH-358 Owens-Coming Fiberglas letter dated March 1, 1972 from Gerald E. Devitt to H. W. Speicher. ANSWER: Not only does this document contain unidentified extraneous information but also is a non-Westinghouse generated document and Westinghouse can provide no information regarding its authenticity. w) WH-360 Handwritten note concerning Asbestos Cloth with date 8/7/72 and name of Bill Lane. ANSWER: This document contains unidentified extraneous information. x) WH-363 Memorandum dated August 28, 1972 from Zella R. Rees to South Philadelphia Works, W. C. Lane. ANSWER: This document contains unidentified extraneous information. z) WH-367 Memorandum dated February 7, 1973 from R. L. Bergquist to East Pittsburgh Works, W. G. Craig, re: Use of Asbestos Material in Soldering Operations. ANSWER: This document contains unidentified extraneous information. bb) WH-370 Memorandum dated March 19, 1973 from E. J. Hlavaty to D. L. Collier; re: E-4 & 5 Operations involving Asbestos Materials. ANSWER: This document contains unidentified extraneous information. WESTINGHOUSE ELECTRIC CORPORATION'S OBJECTIONS AND RESPONSES TO PLAINTIFFS' INTERROGATORIES MAILED TO DEFENDANT ON OR ABOUT APRIL 21. 1993 - Paw 11 s V cc) WH-372 Memorandum dated April 16, 1973 from R. L. Bergquist to East Pittsburgh Works 4N5, W. G. Craig; re: Use of Asbestos Material in Soldering Operations P. G. & E. Diablo Canyon #1. ANSWER: This document contains unidentified extraneous information. ff) WH-379 Memorandum dated April 18, 1974 from R. A. Gerbrands to East Pittsburgh - Room 2G46, H. W. Speicher; re: Asbestos Blanket, with handwritten notation. ANSWER: This document contains unidentified extraneous information. gg) WH-382 Document entitled Excerpt from "Technological Feasibility and Economic Impact of OSHA Proposed Revision to the Asbestos Standard" prepared by WESTON Environmental Consultants", re: regulation proposed on October 9, 1975. ANSWER: Because this document was not generated by Westinghouse, Westinghouse can provide no information regarding its authenticity. hh) WH-383 Article titled "The Asbestos ExDOSure of Insulation Workmen". Insulation Hveiene Prowess Reoorts. bv Irvine J. Selikoff. M.D.. Vol. 6. No. 1. Spring 1975. ANSWER: Because this document was not generated by Westinghouse, Westinghouse can provide no information regarding its authenticity. ii) WH-384 Memorandum dated January 8, 1975 from Zella R. Heasley to R&D Center - 401-3X9, A. Zervins. ANSWER: This document contains unidentified extraneous information. kk) WH-393 South Carolina Department ofLabor Citation and Notification of Proposed Penalty dated January 12, 1976; re: Westinghouse Electric Corporation Micarta Division. ANSWER: Not only does this document contain extraneous information but also this is not a Westinghouse generated document and Westinghouse can provide no information regarding its authenticity. Furthermore, Westinghouse WESTINGHOUSE ELECTRIC CORPORATIONS OBJECTIONS AND RESPONSES TO PLAINTIFFS' INTERROGATORIES MAILED TO DEFENDANT ON OR ABOUT AFRIT, 21. 1993 - Paw. 12 # does not know the basis for the complaint herein or whether this document is complete. INTERROGATORY NO. 4: Has Westinghouse stipulated or agreed to the authenticity of any of the documents referenced in Interrogatory No. 1 with any person prior to the date of these Interrogatories? ANSWER: Westinghouse is not aware of any stipulation to the authenticity of any of the documents referred to in Interrogatory No. 1 except to the extent Westinghouse may have stated that the documents were provided by Westinghouse via document production in various cases. WESTINGHOUSE ELECTRIC CORPORATION'S OBJECTIONS AND RESPONSES TO PLAINTIFFS* INTERROGATORIES MAILED TO DEFENDANT ON OR ABOUT APRIL 21. 1993 - Page 13 Respectfully submitted, VIAL, HAMILTON, KOCH & KNOX 1717 Main Street Suite 4400 Dallas, Texas 75201-4605 (214) 712-4400 FAX (214) 712-4402 State Bar No. 09460500 ROBERT E. THACKSTON State Bar No. 00785487 B. SCOTT TILLEY State Bar No. 20032700 McGUIRE, WOODS, BATTLE & BOOTHE One James Center Richmond, Virginia 23219 (804) 775-1000 ATTORNEYS FOR WESTTNGHOUSE ELECTRIC CORPORATION WESTTNGHOUSE ELECTRIC CORPORATION'S OBJECTIONS AND RESPONSES TO PLAINTIFFS* INTERROGATORIES MAILED TO DEFENDANT ON OR ABOUT APRIL 21. 1993 - Page 14 STATE OF_______________ COUNTY OF______________ V BEFORE ME, the undersigned authority, on this day personally appeared DANIEL VICKOVIC, Assistant Secretary of Westinghouse Electric Corporation, who being by me duly sworn, upon his oath deposes and says that he is duly authorized as an agent by and on behalf of Westinghouse Electric Corporation to make this Verification, that he has read Defendant's Answers to Plaintiffs' Master Interrogatories and Requests for Production, and that the facts stated therein are within his personal knowledge and are true and correct. DANIEL VICKOVIC, Affiant SUBSCRIBED AND SWORN TO BEFORE ME on this the day of _____________, 1993. Notary Public in and for the State of_____________ My Commission Expires: WESTINGHOUSE ELECTRIC CORPORATION'S OBJECTIONS ANDRESPONSES TO PLAINTIFFS* INTERROGATORIES MAILED TO DEFENDANT ON OR ABOUT APRIL 21. 1993 - Page 15 CERTIFICATE OF SERVICE This is to certify that a true and correct copy of the foregoing Westinghouse Electric Corporation's Objections and Responses to Plaintiffs' Interrogatories mailed to Defendant on or about April 21, 1993 have been forwarded to counsel for Plaintiffs via certified mail, return receipt requested, and to all other known counsel of record via U.S. Mail, regular delivery, on this the day of May, 1993. A1TUKNEYS tuK DEFENDANT WESTINGHOUSE ELECTRIC CORPORATION'S OBJECTIONS AND RESPONSES TO PLAINTIFFS* INTERROGATORIES MAILED TO DEFENDANT ON OR ABOUT APRIL 21. 1993 - Page 16 CATHY HENDRICKSON (214) 712-4610 Vial, Hamilton, Koch & Knox A PARTNERSHIP INCLUDING PROFESSIONAL CORPORATIONS ATTORNEYS AND COUNSELORS rECENEP bahon & bu 1717 MAIN STREET SUITE 4400 DALLAS, TEXAS 75201 TELEPHONE: 014) 712-4400 May 28, 1993 D/FW Metro Tel.: 988-7375 FAX: 014) 712-4402 Mr. John Dickson District Clerk Courthouse 1000 Guadalupe Street P.O. Box 1748 Austin, Texas 78767 RE: John A. Loper, Sr., et al. v. Fibreboard Corporation, et al.; Cause No. 92-02693 in the 53rd Judicial District Court of Travis County, Texas Charles Norman White, et al. v. Fibreboard Corporation, et al.; Cause No. 92-10123 in the 353rd Judicial District Court of Travis County, Texas Dear Mr. Dickson: Please find enclosed verifications to be attached to Westinghouse Electric Corporation's Responses to Plaintiff s Interrogatories Mailed to Defendant On Or About April 21, 1993, which were previously filed with the Court on or about May 24, 1993. After you have placed your file mark on the enclosed copies of the verifications, please return same to me via the enclosed self-addressed, stamped envelope. I appreciate your courtesy and cooperation and remain Very truly yours, CH/lft Cathy Hendrickson Enclosures cc: All counsel of record via certified mail/rrr l:\INS\CJH\LTRS\I49987.1 SCV EY'-W&STINGKQUSE LAW QEPT, ; 5-24-83 ; 5:Q7PM ; CCITT S3-* 4126424881*.* 3 COMMONWEALTH OF PENNSYLVANIA COUNTY OF ALLEGHENY ) ) ) SS: Before me, the undersigned authority, a Notary Public in and for said Commonwealth and County, personally appeared Daniel D. Vickovic, who, being duly sworn, deposes and says that he is ASSISTANT SECRETARY OF WEST1NGHOUSB ELECTRIC CORPORATION, and that he signs the foregoing DEFENDANT WESTTNGHOUSE ELECTRIC CORPORATION'S OBJECTIONS AND RESPONSES TO PLAINTIFF'S INTERROGATORIES MAILED TO DEFENDANT ON OR ABOUT APRIL 21, 1993, on behalf of that defendant and is duly authorized so to do; that the matters stated in the foregoing document are not necessarily within the personal knowledge of deponent and that deponent is informed that there is no officer of WESTTNGHOUSE ELECTRIC CORPORATION who has personal knowledge of all such matters; and (hat the facts stated In the foregoing document have been assembled by authorized employees and counsel of defendant and deponent is informed by those authorized employees that the facts stated in me foregoing document are true and correct. SWORN TO and subscribe^ before me on this day of ____________ , 1993. Daniel D. Vickovic Assistant Secretary ^j'Cd^uZ6t $ Notary Public NoesrieiSea) NametteA.Arwai, Notary Pubic Pittsburgh, Allegheny County MyCommission EmpiresAug. 8,1994 Member. PennsytsraniaAssosiafion d Notarig B3SSXffl<3K>lfflE ELECTRIC CORPORATION'S OBJECTIONS ANQ_RESPQ>rSES TO PLAINTIFF'S1 INTEKBOr.ATnHTKS MAJLEP TO DEFENDANT ON OR ABOUT APRIL 21.1993 - Page 15 RCV 0Y1WESTINGH0U56 LAW DEPT. ; 5-24-93 1 5:07P ; CCITT S3-* 4126424681; 4 COMMONWEALTH OF PENNSYLVANIA COUNTY OF ALLEGHENY ) ) ) SS: Before me, the undersigned authority, a Notary Public in and for said Commonwealth and County, personally appeared Daniel D. Vickovic, who, being duly swam, deposes and says that, he is ASSISTANT SECRETARY OF WESTINGHOUSE ELECTRIC CORPORATION, and that he Signs the foregoing DEFENDANT WESTINGHOUSE ELECTRIC CORPORATION'S OBJECTIONS AND RESPONSES TO PLAINTIFF'S INTERROGATORIES MAILED TO DEFENDANT ON OR ABOUT APRIL 21, 1993, on behalf of that defendant and is duly authorized so to do; that the matters stated in the foregoing document are not necessarily within the personal knowledge of deponent and that deponent is informed that these is no officer of WESTINGHOUSE ELECTRIC CORPORATION who has personal knowledge of all such mailers; and that the facts stated in the foregoing document have been assembled by authorized employees and counsel of defendant and deponent is informed by those authorized employees that the facts stated in the foregoing document axe true and correct. ' SWORN TO and subscribed before me on this day of S/Kaxj . 1993. Daniel D. Vickovic Assistant Secretary Notary Public ..__ Noiana! Seal Nannette A. Anta!, Notary PuWc My Commsscn SpiresAug. 8,1994 Pennsylvania Association ai NoSes ELECTRIC CORPORATION'S OBJECTIONS AMP RESPONSESJOJIAINTITFS1 INTERROGATORIES MAILED to DEFENDANT ON OR ABOUT APRIL 21.199? - Page H