Document bgyZ1bO8BBN2dRKz1rGqEOm3

FILE NAME: Georgia Pacific (GP) DATE: 1990 DOC#: GP137 DOCUMENT DESCRIPTION: Legal - Defendant GP's Responses to Plaintiffs' 1st Interrogatories NO. 88-14172-1 CARTER O. MYERS, ET AL Plaintiffs, V. FIBREBOARD CORPORATION, ET AL. , Defendants. IN THE DISTRICT COURT OF DALLAS COUNTY, TEXAS 162ND JUDICIAL DISTRICT DEFENDANT GEORGIA-PACIFIC CORPORATION'S RESPONSES TO PLAINTIFFS 1 FIRST SET OF INTERROGATORIES NOW COMES, Georgia-Pacific Corporation (hereinafter raferree! to as "Georgia-Pacific" or "Defendant"), a Defendant in the above-styled action, by and through its attorneys of recorl and responds to Plaintiffs' First Set of Interrogatories as follows: PRELIMINARY STATEMENT Georgia-Pacific previously served its Objections to Plaintiff's First (sic) Set of Interrogatories on April 10, 1990 which for convenience are set out below with the Answers. Some of the events which may be relevant to the matters inquired into by these Interrogatories occurred more than thirtyfour (34) years ago. In addition, effective April 30, 1965, Georgia-Pacific acquired by merger, all the assets and liabilities of the Bestwall Gypsum Company, which manufactured asbestos-containing products, and Georgia-Pacific continued the manufacture, sale and/or distribution of such products until the cessation of the same at various times thereafter. As of 1977 Georgia-Pacific ceased the manufacture of asbestos-containing DEFENDANT GEORGIA-PACIFIC CORPORATION'S RESPONSES TQ.PLAINTIFFS' FIRST SET OF INTERROGATORIES -- Page 1 answering to this interrogatory in regard to any period of time other than the period during which it engaged in the manufacture of the asbestos-containing product(s> involved in this case, which ended in 1977, or concerning any facility not related to that business, on the basis that any such Answer would be irrelevant to the subject matter of this case, would not be reasonably calculated to lead to the discovery of admissible evidence, and would be burdensome and oppressive. In addition, Georgia-Pacific objects to answering this Interrogatory to the extent that it seeks documents and/or other information protected by the attorney work product or attorney-client privilege. INTERROGATORIES 1. Please identify by trade or brand name each asbestos containing product manufactured sold and/or distributed by Defendant. following: For each product identified, please state the a. The years that the product was manufactured sold and/or distributed; b. A description of the chemical composition of the product, including the type of asbestos contained in the product and the percentage of asbestos in each product; A description of the intended uses of the product; and d. The years, if any, that the asbestos was removed in whole or in part from the product. DEFENDANT GEORGIA-PACIFIC CORPORATION'S RESPONSES ^--.PLAINTIFFS ' FIRST SET OF INTERROGATORIES -- Page 3 d. Withdrawn from the market in approximately 1964. Patching Plaster a. 1956 - approximately 1976. b. Approximately 2% chrysotile asbestos. c. Normally applied to repair cracks and holes in wall board and ceiling surfaces. d. Asbestos-free formulation introduced in 1976. Ready Mix a. 1963 - approximately 1977. b. Approximately 1.5% to 5% chrysotile asbestos. c. Normally applied as a taping, finishing, or texturing material over joints, fastener heads, corners and entire areas of gypsum wallboard in walls and ceilings. d. Asbestos-free formulation introduced in 1976. a. 1956 to approximately 1970 or 1971. b. c. in wallboard. Approximately 5% chrysotile asbestos. Normally applied to patch small holes and cracks 1971. Withdrawn from the market in approximately 1970 o Speed Set a. Approximately 1962 - approximately 1974. b. Approximately 2.75% to 6.75% chrysotile asbestos. c. Normally applied over bedding or taping compounds over joints, fastener heads, corners and entire areas of gypsum wallboard on interior walls and ceiling surfaces. DEFENDANT GEORGIA-PACIFIC CORPORATION'S RESPONSES TO PLAINTIFFS' FIRST SET OF INTERROGATORIES -- Page 6 ANSWER: Georgia-Pacific objects to this Interrogatory on the basis that it is overly broad, vague, unduly burdensome, and oppressive and further that a preparation of the response would impose undue burden and expense on Georgia-Pacific. Without waiving its objections, Georgia-Pacific states that it was a member of the Gypsum Association and that documentation with respect to meetings of the Gypsum Association has long been in possession of Plaintiffs' counsel. Georgia-Pacific further states that possibly some of the information sought could be determined from a review of Georgia-Pacific's documents which have previously been made available to Plaintiffs' counsel or through depositions of past and present corporate employees which have been taken on numerous occasions in this litigation. Respectfully submitted THOMPSON & KNIGHT MolTy S. Steli State Bar No. 19102500 David S. White State Bar No. 21295000 3300 First City Center 1700 Pacific Avenue Dallas, Texas 75201 (214) 969-1700 ATTORNEYS FOR DEFENDANT, GEORGIA-PACIFIC CORPORATION DEFENDANT GEORGIA-PACIFIC CORPORATION'S RESPONSES T0_PLAINTIFFS' FIRST SET OF INTERROGATORIES -- Page 29