Document bqBnnNmpyRw06M072pEqXLOO

4 E 5800 MKW/kmg IL030.ASB 12/08/88 PLAINTIFF'S EXHIBIT K-1947 STATE OF ILLINOIS IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT COUNTY OF MC LEAN CAROL ANN COOKE and JUDITH ANN O'NEAL, Special CoAdministrators for the Estate of Ben Smith, deceased and CAROL ANN COOKE, Individually, Plaintiffs, vs. ILLINOIS CENTRAL GULF RAILROAD COMPANY, et al., Defendants. ) ) ) ) ) ) i ) ) ) ) ) NO. 88 L 52 ^ DEFENDANT, OWENS-ILLINOIS, INC.'S RESPONSES TO PLAINTIFFS' FIRST REQUEST FOR DISCOVERY FROM DEFENDANT. OWENS-ILLINOIS. INC. REQUEST NO. 1. All witness statements of any sort, whether signed or unsigned (together with all documents purporting to reflect the same), and a list of those statement for which a privilege from disclosure is claimed. RESPONSE NO. 1. This defendant objects to responding to this request in that it seeks information protected from discovery by the attorney work product privilege and the attorney-client privilege, information not relevant to the subject matter of this litigation, and not reasonably calculated to lead to the discovery of admissible evidence. l jai I ,, >239 (( REQUEST NO. 2. All data as to the physical cr mental condition of Ben Smith prior to his death excluding all documents provided you by plaintiffs' counsel and excluding all documents, copies of which have already been provided plaintiffs' counsel through formal discovery. RESPONSE NO. 2. This defendant objects to this request as being irrelevant and not reasonably calculated to lead to the discovery of admissible evidence and not limited to any issue which is the subject of this case. This defendant further objects to this request on the grounds that it seeks information within the work-product privilege and on the ground that it is oppressive and burdensome in that it would have to review all of the files and all of the records of all of its attorneys all over the country to respond to this request. REQUEST NO. 3. All data as to the physical or mental condition of Carol Cooke excluding all documents provided you by plaintiffs' counsel and excluding all documents, copies of which have already been provided plaintiffs's counsel through formal discovery. RESPONSE NO. 3. This defendant objects to this request as being irrelevant and not reasonably calculated to lead to the discovery of admissible evidence and not limited to any issue which is the subject of this case. This defendant further objects to this request on the grounds that it seeks information within the work-product privilege and on the ground that it is oppressive and burdensome in that it would have to review all of the files and all of the records of all of its attorneys all over the country to respond to this request. REQUEST NO. 4. All photographs of Ben Smith. 2 (( RESPONSE NO. 4. This defendant has found no documents responsive to this request. REQUEST NO. 5. All photographs of Carol Cooke. RESPONSE NO. 5. This defendant has found no documents responsive to this request. REQUEST NO. 6. All photographs, models, sketches or diagrams of any of the sites at which Ben Smith worked. RESPONSE NO. 6. This defendant objects to responding to this request in that it seeks information protected from discovery by the attorney work product privilege and the attorney-client privilege. REQUEST NO. 7. All photographs, models, sketches or diagrams of any of the products involved in this litigation. RESPONSE NO. 7. This defendant objects to responding to this request in that it seeks information protected from discovery by the attorney work product privilege and the attorney-client privilege. Also, this request is overly broad, vague, and ambiguous. Without waiving the above objection, refer to Exhibit I of this defendant's answers to plaintiff's Interrogatories. REQUEST NO. 8. All pamphlets, brochures or other documents prepared, distributed or utilized by defendant to advertise or promote asbestos-containing products during the 1950's or 1960's. RESPONSE NO. 8. This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958. To the extent that this request refers to the 3 (( period of time during which this defendant engaged in the manufacture, sale and distribution of asbestos-containing products, refer to Exhibit I. REQUEST NO. 9. Each document authored by an employee of defendant in the course of his employment, dealing in whole or in part with the consequences of exposure to asbestos. RESPONSE NO. 9. This defendant objects to this interrogatory as being irrelevant and not reasonably calculated to lead to the discovery of admissible evidence and not limited to any issue which is the subject of this case. This defendant further objects to this interrogatory on the grounds that it seeks information within the work-product privilege and on the ground that it is oppressive and burdensome in that it would have to review all of the files and all of the records of all of its attorneys all over the country to respond to this interrogatory. REQUEST NO. 10. All medical records of those present or former employees of defendant who have filed claims for worker's compensation or occupational disease benefits alleging an injury or disease from exposure to asbestos and all personnel and employment records which evidence or reflect the duration, quantity and quality of his or her exposure to asbestos while employed by defendant. RESPONSE NO. 10. This defendant objects to this interrogatory on the basis that it seeks information which is not relevant to the subject matter of this litigation and is not reasonably calculated to lead to the discovery of admissible evidence, except as it relates to the period of time during which this defendant engaged in the manufacture, sale and distribution of its asbestos-containing products. Without waiving the above objection, during the period in which this defendant engaged in 4 (I the manufacture of its asbestos-containing products, it received no workers' compensation claims for any asbestos-related disease. REQUEST NO. 11. Each written warning, caution or other document which was intended by defendant to reach those persons who would breath or ingest the asbestos from asbestoscontaining products manufactured and/or sold by defendant. RESPONSE NO. 11. This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958. This defendant has no documents responsive to this request in its business records. It does not appear that any warning concerning asbestos was given in that it does not appear that this defendant had reason to believe that the use of its products would result in a foreseeable risk of harm. REQUEST NO. 12. A transcript (including exhibits), other than those previously produced in this cause, of each instance where an employee of defendant testified at deposition or trial in asbestos disease litigation. RESPONSE NO. 12. The document outlined in this request has not been found as part of this defendant's business records. To the extent that this defendant is in possession of copies of such documents, it possesses copies of documents collected only in preparation for litigation. This defendant objects to producing it. The document is available from its proper source. REQUEST NO. 13. A transcript (including exhibits), other than those previously produced in this cause, of each instance where an individual whom defendant listed, retained or called as an expert witness, testified at deposition or trial in asbestos disease litigation. 5 c( RESPONSE NO. 13. The document outlined in this request has not been found as part of this defendant's business records. To the extent that this defendant is in possession of copies of such documents, it possesses copies of documents collected only in preparation for litigation. This defendant objects to producing it. The document is available from its proper source. REQUEST NO. 14. All documents which record or reflect the asbestos exposure of those present or past employees of defendant who have contracted asbestosis, lung cancer or mesothelioma; this is a request for the documents which reveal the name or address of the employee, the disease and date of diagnosis, the present or last known condition of the employee, the death certificate, the dates and location of each employment and a description of the jobs performed, and the analysis of each air sample taken from the employee's breathing zone or any air reported to be similar thereto. RESPONSE NO. 14. This defendant objects to this request as being vague, ambiguous, irrelevant, overly broad, burdensome and oppressive, not reasonably calculated to lead to the discovery of admissible evidence and not limited to any issue which is the subject of this case. reports. REQUEST NO. 15. Defendant's last three annual RESPONSE NO. 15. This defendant objects to this request on the basis that it seeks information which is not relevant to the subject matter of this litigation and is not reasonably calculated to lead to the discovery of admissible evidence, except as it relates to the period of time during which this defendant engaged in the manufacture, sale and distribution of its asbestos-containing products. 6 (( REQUEST NO. 16. An affidavit stating whether production is complete according to the knowledge of defendant and defendant's insurance carriers, attorneys, agents and employees. RESPONSE NO. 16. This defendant states that it has referred to the relevant business records of the Owens-Illinois Glass Company, which are still in the possession of OwensIllinois, Inc., in connection with the preparation of answers to these interrogatories unless otherwise indicated. 7 c( EXHIBIT I c AFFIDAVIT ( STATE OF OHIO COUNTY OF LUCAS ) ) SS: ) A. H. SMITH, being duly sworn according to law, deposes and says that he is an Assistant Secretary of Owens- Illinois, Inc. , a defendant herein; that as such he is authorized to make an Affidavit on its behalf; and that the facts set forth in the foregoing DEFENDANT, OWENS-ILLINOIS, INC.'S RESPONSES TO REQUEST FOR PRODUCTION, are true and correct to the best of his knowledge, information and belief. ft, M. A. H. SMITH SWORN TO before me c of v and subscribed /a this > / day Jjr Notary Public My Commission Expires: WMrJLaoOYNW Mv rl!!"? Pubte' 5,0,0 of 0f>!o Commission Exoircs C-f 1 e 11*02 JU. le^je, Structural Insulating Slock--i* a near-white, rigid mineral insulating "materia] weighing approximately 20 pounds per cubic foot. It is composed principally.of calcium.silicate. Except for density and for those characteris tics that are changed by density it is similar to Kayla Heat Insulating Block. a lightweight insulation used to insulate against heat loss from hot surfaces. Kaylo Structural Insulating Block (20-lb. density) is designed to develop maximum strength and fire resistance without sacrificing its advantages of light weight and low thermal conductivity. In fact the practical combination of these four properties--strength, weight, insulating value and fire resist ance-makes it almost unique as a building material. It weighs nominally 20 pounds to the cubic foot (actually on an oven dry basis from 19.5 to 22 lb.), has a compressive strength of approximately 500 lb. per sq. in., a "k" of 0.66 at 100 mean and outstanding resistance to the travel of heat and flame at building fire temperatures. STRUCTU For use in fabrications that are to be Underwriters' Laboi atones inspected, Kaylo Structural Insulating Block furnished bearing the Underwriters' label for fire hazar classification for Duilding material. Kaylo Structural Insulating Block is not a finished build ing material in itself and is not made for exposure to the weather. Its principal uses are as a structural roof tile, or roof deck unit, in which a steel reinforcing mat is inserted at the time of forming, and as a core material. In this latter use it serves as the core of laminated structures where the faces or laminates are applied with adhesives, and also as the core of structural shells or envelopes where the Kaylo core material is simply inserted in the open spaces and held by its own contact or by such conven tional methods as dips or other attachments. In any of these applications it adds rigidity to the structure vnd- vastly increases insulation value and fire resistance. I PHYSICAL PROPERTIES I----------------------------------------------------- Light Weight--Nominal 20-lb. density Kaylo Block is about a third lighter than yellow pine. On an oven-dry basis it weighs from 19.5 to 22 pounds per cubic foot. High Strength--Its compressive strength is approximately 500 lb. per sq. in. with a deformation of 5 per cent. Flexural strength is approximately 175 lb. per sq. in. Fireproof--Kaylo 20-lb. density Structural Insulating Block has been tested at the Underwriters' Laboratories in Chicago and given the following rating, baaed on com parison with untreated Red Oak as 100. Flame spread....................... 0.0 Fuel contributed..................negligible Smoke produced.................. 0.0 MO ttl ISO Moon Tomporotvro, 'F. Good Insulotien Value--At low mean temperature* Kaylc Structural Insulating Block is one of the most efficier. structural mineral insulations. At high mean temperature it still compares favorably with heat insulating material of its own weight. High light Reflectivity--Where left exposed and untreatec (aa with the underside of a roof deck) Kaylo Structure Insulating Block has high light reflectivity. Its light re flection factor is from 70 to 80 per cent. Nen-Abrative Surface--Its surface is non-abrasive. It ha a somewhat "soapy'' feel that makes it pleasant to handle At the same time it has a firm surface that assures goc* contact with surfaces applied over it. He Added Binder--It contains no added binder, but ir. stead constitutes its own binder. Hence its characteristic are not modified as to temperature limit, solubility, insu lation value, fire resistance or otherwise by "binde limitations." (1 L INSULATING BLOCK (20-LB. DENSITY) od Wariiobillty--Kaylo Structural Insulating; Block is sponsive to wood working tools. It can be sawed with a and saw or power saw, can be routed, tongue-androoved, sanded, and, in fact, run through most woodorking equipment. igh Modulus of flasHclty--The modulus of elasticity of 0-lb. density block is approximately 160,000 lb. per sq. in. w Spacific Hoot--The specific heat of Kaylo Structural nsulating Block is approximately 0.22. :ollulor Structure--Kaylo Structural Insulating Block is bout 80 per cent inter-communicating air cells. The cells re extremely small, less than a micron in diameter. w Moisture Absorption--Kaylo Structural Block is hy.Toscopie. It will absorb moisture from humid air and will each equilibrium at lower moisture contents when exposed o lower humidities. However, because of its extremely mall pore size and other characteristics, its behavior with espect to moisture differs from that of most porous maeri It has unusual capacity to distribute moisture hti. .. its mass, and to give it off to surrounding air of jwer moisture content. Its moisture absorption when surrounded by humid air s low. Test specimens dried for 24 hours at 215* F., cooled ind then exposed on all surfaces to an atmosphere of 90 ler cent relative humidity and a temperature of 120* F. ir six hours, absorbed less than one per cent of moisture y volume. onsistent with the common practice for good construeon involving porous insulating materials of high internal irface area, Kaylo Structural Insulating Block should e sealed against moisture on the warm side when it is objected to extremely low temperatures. High Wet Strength--Kaylo Structural Insulating Block, like most other insulating materials, is not intended to serve immersed in water or exposed to extremely damp or humid conditions, yet its flexural strength when wet (im mersed 10 hours; is reduced only about 15 per cent. Dimontlonally Stable--The dimensions of Kaylo Struct ural Insulating Block change little with changes in moist ure content. Experience has shown from the manufacture of thousands of units of laminated structures that they have unusual dimensional stability and unusual freedom from warping. Avoiloble with end without Reinforcing--In the form of roof tile Kaylo Structural Insulation is available with a steel reinforcing mat. In the form of core material for var ious types of structure it is available without reinforcing. Accepts Nolls end Screws--Both nails and screws can be used with Kaylo Structural Block. Tables showing holding power of both are available on request. Kails should be of the cement-coated type without barbs that abrade the sides of the opening they make as they are driven into the block. Galvanized or non-ferrous nails may be used where greater resistance to corrosion is required. Screws may be inserted either with or without drilling a pilot hole. Sizes--Kaylo Structural Insulating Block is made in a standard size of 18 x 36 inches. Since most uses involve manufacturing operations, thick nesses that are practical can best be worked out with the manufacturer or Kaylo Insulating Products after approxi mate quantities needed are known. These will usually be between one and two inches thick. Certain thicknesses are suggested by certain building re quirements. A thickness of from IK to 2 inches of Kavlo Structural Insulating Block is required to withstand a typical building fire for one hour--usually somewhat more for a partition than for a door because of the greater per formance required of a partition. 20-lb. and 11-lb. Dontlty Block Con Bo Used in Combination. Where two thicknesses of insulation are used to build up an insulating structure it is /nible to use the two den sities in combination to develop the best insulation value strength and fire resistance. AMERICAN STRUCTURAL PRODUCTS COMPANY Toledo 1, Ohio c LAMINATION ----------------------------^ ommotion over a Kaylo Insulating Cora--Almost any face material may be bonded to Kaylo Structural Insulating Block surfaces. Bonding agents can be selected to meet tne requirements of the particular facing--also to satisfy i ADHESIVES FOR JOINING EE&Y7I1' k.--i STRUCTURAL INSULATING BLOCK TO: Wood Vonoor Aluminum Stainless Stool the sernce r^uirements of the finished product--a-.'-' still offer some choice in curing procedures. Some adhesives which may be used with various t-.-pes of face materials are listed below. (This list is not intended to be complete. Its only, purpose is to identify a partial list of adhesives. These have been found to provide a tensile strength of 35 lb. per sq. in. and a minimum shear strength of 100 lb. per sq. in. when cured in the manner indicated. ADHESIVES FOR JOINING LIKE MATERIALS: Insulating Block to Insulating Block Aluminum to Aluminum Stainless Stssl to Stainless Stool Dwrit* Nt. 3024A Q 3034AWM307 3034AW7 tnnaBif ottji Pyyere 711 CeiebeiW 730 0 Q Vi*vli*el ma 3S-1I 0 AmbyrliN rsu \.hk 703* O Wy< Q Sr< 1114 O - I301W (OW) Oiinit No. 303AA Q Imri 71S w.uMt 0 Q Intolvlft Ns. 1 0 Uff(kt 4143 90 Vwkl*k DvpAfff 4453 00 900 PwBMl 4444 900 G. I. 2143 G. C. 7021 O 9 MA 2KU Amkorli** 7114 0 Ulhk CXI 131 0 Mhi o Ourita Ne. 3034 0 Ne. A. NM347 M100 0 3 MK 134 IflMlvtG N. 1 O o iAfr(k 4142 Valflxk OO 900 4433 OvRMl 4444 900 0. t. 3143 9 0. t 7031 9 ma 29-19 9 ArnktHift 7114 9 teiHk 7034 9 IsSlya Silleete 0 Mnb 9 Dvrl*. 3C34A 7** 011)1 O o o O. L 3143 Marts* fII o 0 90 Ssbcirs* 3003 0 Viorbsal MA 31-11 Amtorlit* ttW UotU 7024 o o o IXC 131 o Silk*** o ldvi o Sync* X U4I o 13*W (OW) 00 000 4433 000 0. L 7031 latrik 7034 o o oSaiili Uf 130 o 4493 0. t 7031 Ustik 7024 iMlik cu m ft4v O o O o Q damped at room temperature for 24 hours. 0 damped in oven at 120* F. far t haur. Symbols for method of care: 0 Placed In press at 10 p.s.i. at 300* F. far 10-30 minutes. For Maximum Strength 0 Placed in press at 100 p.s.i. at 300* F. far 10-30 minutes. i t Q damped in even at 250* F. for 10-30 minutes. High-frequency curing hu been tried succasfully on on experimental basis with wood, sluminum tnd stainless steel bonded to s Keylo suliting core. Many of the msnuficturers melting the sbove listed .dhceivte can provide sdhesivee suitsble (or high-frequency curing. r MflSEOGM OTCaQDCTGDMO. | pos(iD(?s I TOIIOO 1, OHIO Swbtidiery et OWINS-IUINOIS OlASS COMPANY Coor"** 1444, A*o*a BfWMHWil 7f*4*Ctt CimpMt Pmestpd W J A. jH( ( A new n.e&j&ins WITH A REMARKAB1I COMBINATION OF KAYLO HEAT INSULATING BIOCK is a new type of lightweight mineral insulation that is tffititnt enough to be used at ordinary room temperatures and resistant enough to perform effectively up to 1200 F. Few new products of any kind have been so thor oughly researched before being placed on the market. Kaylo Heat Insulating Block is the achievement of many years' work by Owens-Illinois Glass Company engi neers. physicists and chemists. It combines the most desirable characteristics of the ideal heat insulation. LOW DENSITY. Kaylo Heat Insulatiog Block weighs only 11 pounds per cubic foot. This light weight (less than one pound to the board foot) simplifies handling, shipping and application. LOW THERMAL CONDUCTIVITY. The coefficient of conductivity, or k, of Kaylo Heat Insulating Block places it among the most efficient insulations for medium high temperatures. Its insulation value comes principally from its fine, cellular structure. These cells are so tiny and so numerous that they present a material surface of approximately 140 acres per cubic foot of iosulation. Experience shows that the efficiency of Kaylo insula tion improves after exposure to service temperatures. EFFECTIVE OVER WIDE TEMPERATURE RANGE. Kaylo Heat Insulating Block performs efficiently not only on temperatures in the low pressure steam and hot water range but on temperatures in the super heated steam range as well. One-material coverage with Kaylo insulation handles applications which often require two thicknesses of different materials. HIGH COMPRESSIVE STRENGTH. Its compressive strength is unusually high for a mineral product of such light weight. HIGH FLEXURAL STRENGTH. Its flexural strength is higher than the normal requirements for heat insula tion of this type. This strength makes for easv hand ling and application, and contributes to long'service with low maintenance. NO ADDED BINDER. Kaylo insulation is an inorgaaic compound, containing no added binder. Its per formance characteristics, therefore, are not affected by additives, which often reduce insulating value, modify effective temperature range or otherwise limit per formance. EASY TO APPLY. Kaylo Heat Insulating Blocks are clean-cut and trim. They are easy to fit into place to Notice the clean, straight edges on these insulated pre cipitator hoppers. Applicators find it easy io work with Kaylo Heat Insalatini Block because they art so easy to cut and yet have a high lexurai strength. On large er small equipment, inside or out, Kaylo Heat Insulating Block performs efficiently and with a minimum of maintenance. Here it it being applied to the walls of a large precipitator. ( ation > VANTAGES... like a good-looking installation. Thtia "toot" im leiMM and aon-imtiiiny They can be cut. scored nd saw ed with ordinary woodworking tools. Finishes nat go oxer the block, whether cement, cloth or other vpes. can be applied smoothly and with a minimum f effort. No special tools are needed. .OW MOISTURE ABSORPTION. Kaylo Heat Insulat- ng Block absorbs little moisture from surrounding tumid air. EFFECTIVE AFTER LONG SERVICE. Kaylo Heat Insulat. ng Block remains strong, free from excessive powderng, and shows little loss in weight or shrinkage after long application to temperatures up to 1200 F. Even conventional rumbling tests, run after prolonged heating, produce relatively little crumbling or break down of the material. TYPICAL APPLICATIONS: lr .-or outside, for large installationsor small, up to 12uo F.. use Kaylo Heat Insulating Block to insulate: Breechings Hot Air Ducts Tanks Towers . Dryers Evaporators Heat Exchanger! Condensers Lehrs Autoclaves Ovens Furnaces Turbines Chilling Pits Boilers Precipitators Locomotives <oylo Heat Insulating Black covers both Mat and curved .urfacts on the power house equipment pictured here. By ninimmng heat lost, is aaves fuel and keeps temperatures within the room at comfortable Irvala. PHYSICAL CHARACTERISTICS . .. .Assft<Ai't|t " " *' " .................................... ........... so l. a*''" Hiaueai COMRtUHVI M.INOTM l* a.tw-- ..iso t ' * A#For* Kot*9.......... Ahf 24 K'#n ........... at 750* 7.................................. .......... at <000* 7............................. ... i aa ix. avr *a....Ulih. ear ta- ...nr ix. avr - ... ra ix . Mf **- ,n loss til WR10W atattael ~ ............................... at ............ .......................................................................... at ................................................... ...................................... ............. (Coavav'-onal - ~*w oh*',0 Satara Vi LLn attar Xaatvtf tor J ................................ at .. ....................................... .................................. at 1000* ..................................... ........................... et 1200* 7................................ O.salHMOMAl ATA*"-"1' Jt l--of *--** oh*r , ........................ at ................................................... ............................... at .............. ...................... .. " ................................ ahar tvraha ....................................... saot.it... .......... wte"*o% *h* ..................... `rsv---..... at J00' I. a ................... .1.2% 0.0*<R> .0 1% STAI avwi. utis* iTjftv--t x.. i- - ___ THICKNESS (inches) " --n ft rx -~~T'------------- _. _ . o^:r.._o_ ------'t^ix^o. c~:o-- ___ _____ ---i"' prrrre-.xxc.; ~o._ linrz^n~r _ ofhff *<i*i or ovottobJ# Oft p#CfeJ rde' SOURCES OP TEST DATA: The date shows os these pages are supported by tests run at ear* ious laboratories, aU well known to the insu lation industry. They are further supported by the performance of the product in service. Mere detailed Infermatien on Kaylo Heat Insulating Block is available on request. American Structural Products Company, Toledo l, Ohio. A NE-V HEAT INSULATION WITH A REMARKABLE COMBINATION OF ADVANTAGES.... Ivaylo Heat Insulating Block a new type of lightweight mineral sulation that it tfiieitnt enough to used at ordinary room temperatu: and rtsisUnt enough to perform eff. lively up to 1200* F. Few new products of any kind ha been to thoroughly researched befc being placed on the market. Ka^ Heat Insulating Block is the achie meat of many years' work by Ow e; Illinois Glass Company enginee physicists and chemists. No other material, new or old. effectively combines the most des able characteristics of the ideal ht insulation. For instance ... LOW DENSITY Kaylo Heat Insulating Bio weighs only 11 pounds per cutuc fo This light weight (less than onepou to the board foot) simplifies handhr shipping and application. It grea reduces weight --an important ad; (age on ships, for an example. .. 1941, S*ha*erI C< N1MI U.kA. Notice the dean, straight edg on these insulated precipitator he pers. Applicators find it easy to do :r kind of work with Kaylo Heat Insul ing Block because they are so easy cut and yet they hase a - .ti'eiv hi. fiexural strength. The . -s abo'e ' hoppers are also insulated ith K.m Heat Insulating Block. OVV THERMAL CONDUCTIVITY The coefficient of conductivity, or K' . of Kaylo Heat Insulating Block, s 'uown on the chart on page four. >1. it among the moat efficient in itiation! for medium high temperaures. its insulation value comet prin pally from its fine, interlaced cellular tructure These cells are so tiny and o numerous (hat they present a raaerial surface of approximately 140 ,cres per cubic foot of insulation. Experience shows that the insulaion value of Kaylo insulation imtroves when the material is put into .ervice. EFFECTIVE OVER WIDE TEMPERATURE RANGE Kaylo Heat Insulating Block per forms efficiently not only on tempera tures in the low pressure steam and hot water range but on temperatures in the superheated steam range as well. This is shown by the flatness of the conductivity curve. One-material cov erage with Kaylo insulation handles applications which often require two thicknesses of different materials. HIGH COMPRESSIVE STRENGTH 's compressive strength is unusl .y high for a mineral product of tuch light weight. Kaylo Heat Insu lating Block withstands compression values equivalent to those of a man s walking on it or even to those of a heel's being ground into it. high flexural strength Its flexural strength is higher than the normal requirement for heat insu lation of this type. This strength makes for easy handling and applica tion, and contributes to long service with low maintenance. NO ADDED BINDER Kaylo insulation is an inorganic compound, containing no added binder. Its performance characteris tics, therefore, are not affected by additives, which often reduce insulat ing value, modify effective tempera ture range or otherwise limit per formance. EASY TO APPLY WELL Kavlo Heat Insulating Blocks are clean-cut and trim. They are easy to fit into place to make a good-looking installation. Their "feci" is pienanw and non-irritating. They can be cut, scored and sawed with ordinary wood working tools. Finishes that go over the block, whether cement, cloth or other types, can be applied smoothly and with a minimum of effort. No special tools are needed. -OW MOISTURE ABSORPTION Moisture absorption is no prob lem with Kaylo insulation. Even when subjected to an atmosphere of 90 9c relative humidity and a temperature of 120 F., in standard tests, speci mens absorb less than 1 91 moisture by volume. RETAINS EFFECTIVENESS AFTER LONG SERVICE Kaylo Heat Insulating Block re mains strong, free from excessive powdering, and shows little loss in weight or shrinkage after long appli cation to temperatures up to 1200 F. Even conventional tumbling tests, run after prolonged heating, produce relatively little crumbling or break down of the material. STANDARD SIZES Lengths (inches) 36 36 - 36 36 36 36 3<> 36 36 36 Widths (inches) 6 6 6 6 6 12 12 12 12 ii Thicknesses (inches) 1 ivy 2 2 Vi 3 1 iVi 2 2'A 3 Oihr sues arc BvtiUblc on special order. N D A REMARKABLE VERSATILITY On large or small equipment, in side or out. Kaylo Heat Insulating Block performs efficiently and with s minimum of maintenance. Here it is be;- applied to the wails of a Urge pr .itator. Workmen are laying block over 6" x 6" wire mesh welded to the stiffeners. The block are then covered with finishing cement and asphalt mastic weatherproofing. Kaylo Heat InsuUting Block cov ers both flat and curved surfaces on rhe power house equipment pictured here. At the right are fresh air intakes; the center compartments house in duced draft fans; and at the left arc conduits leading to a precipitator. Kaylo insulation means continuous fuel savings to this power plant. Hot water is always ready when needed in the office building where this hot water storage tank is installed, thanks to Kaylo Heat Insulating Block. This permanent insuUtion holds water temperature constant with a minimum of power consumption. Olhtr applications for Kavlo Heat Insulating block arc lined on th hack p| PH Y5IC AL( CHARACTERISTICS AT A GLANCE ^ :-r ' - ^-^T^irlbQO* T.-Evii-S.*. "it faoo* _ Aftcfboiling for 24 hours ^yvhile wet) /..... 117 lb. per i lb. After heating for 24 hours.' `*0~7V~ -- -** V Tv-; at 750* P.V.;........ .........................^.-. i... .`iv. at iooo*F..........:.y........................;.!...*....-.. 7.9*' At 1200* f* V??* e iia n 4* ** 9<0 A After boiling for 24 hours (i1?*..'.................T.f........r..~0.2% H) r'` (Conventional Tumbling Test--Loss in weight after 10 minutes) -1--.itt1:' Before t*rig.-.,-.---.---j. .V^ia.- m -*---*-&--*-.*--;...'-.2':2 %-jh- ' ' After heating tor 24 ho________ ____ * ^'M<^a^MKawiK55a8SBf3SS3SW It 1200*.' -t--y Linear Shrinkage 1 ang (or 24 hijx*~ ^ .*:. '- - - * ` __ ' * t - ir 75(T Fe f>4--. . a ... a .'**- Elongation after saturation (max.), 0.4% ^32G>vf*^' (volum*) After 6 hours exposure in atmosphere of 120* F. and 90% Relative Humidity.......... 0.9% agl'.e^ljga^r^l^/ S At 500* F. meao temperature............................................................... 0.474 CGG/A^r OCjS^lLLuOl^ -^3C31 Heat Loss, Surface Temperatures and Efficiencies *. > RATIO r*Af mSULaHNO llOOl *at toss wo* hat memos ] SUVM3 r^HATU|S 0* MSUUTlON -RweiwM M-a MR f r i ' i J O'tiwa, Mn Mm* % a* f 94VSNB*. v ; ij i* * > I > rmo HtAr-iMjuiiTio HOC* pnoiNCiiS On *lAt SUIMCIS *NM Sal A*..IC* * . lx <*-. r. _arS Breechings?^ s'-: ; Lehrs y-V HocAirDucts ' r;'AucIevet*-* - r- if-i Tanks-***z*v*<vv*t. * at- _Ovens ' , Towers r '*- /^V- Furnaces- -- i ~ Dryers- -*-i. *' Turbines . . *-'s Evaporators ^ JIT- v Chilling Phi" Heat ExchangersBoilers '& f ' Condensers.^- A* **,. Preapitators^," , 7.^- .|;?Icomov'es,^Sp -* ir* SOURCES OIAIST DATA ayt*/*T--he^:3aaTsbqynSon .tthaes,e- rp.ages^ sn^porseA.byStem'run atvarious". iSJj*,. lahorsionei, ^aU _well- known to the~' insnlarion industry. They are farther . - - -' supported by. the pcrfarmsoce of the - V. product in service. 7 y ` / r. - -e i-- > V More detailed information on Kaylo Heat losulstiag Block is avail able on retjuest. American Structural Products Company, Toledo 1, Ohio. Subsidiary of Owens-Illinois Glass Company. r 20-LB. DENSITY For use in fabncations that are to be Underwriters' Labor atories inspected, Kaylo Structural Insulating Block is furnished bearing the Underwriters' label for fire hazard classification for building material. Kaylo Structural Insulating Block is not a finished build ing'material in itself and is not made for exposure to the weather. Its principal uses are as a structural roof tile, or roof deck unit, in which a steel reinforcing mat is inserted at the time of forming, and as a core material. In this latter use it serves as the core of laminated structures where the faces or laminates are applied with adhesives, and also as the core of structural shells or envelopes where the Kaylo core material is simply inserted in the open spaces and held by its own contact or by such conven tional methods as clips or other attachments. In any of these applications it adds rigidity to the structure and vastly increases insulation value and fire resistance. 0 0 '* UO l Itt t/l 300 Moo* Ttmporotwr#, f. Good Insulation Value--At low mean temperatures Kaylo PHYSICAL PROPERTIES Structural Insulating Block is one of the most efficient structural mineral insulations. At high mean temperatures it still compares favorably with heat insulating materials Light Weight--Nominal 20-lb. density Kaylo Block is about of its own weight. a third lighter than yellow pine. On an oven-dry basis it weighs from 19.5 to 22 pounds per cubic foot. High light Reflectivity--Where left exposed and untreated las with the underside of a roof deck) Kaylo Structural High Strength--Its compressive strength is approximately 500 lb. per sq. in. with a deformation of 5 per cent. Flexural Insulating Block has high light reflectivity. Its light re flection factor is from 70 to 80 per cent. strength is approximately 175 lb. per sq. in. Non-Abrasive Surface--Its surface is non-abrasive. It has Fireproof-- Kaylo 20-lb. density Structural Insulating Block has been tested at the Underwriters' Laboratories in Chicago and given the following rating, based on com parison with untreated Red Oak as 100. a somewhat "soapy" feel that makes it pleasant to handle. At the same time it has a firm surface that assures good contact with surfaces applied over it. No Added Kinder--It contains no added binder, but in stead constitutes its own binder. Hence its characteristics Flame spread....................... 0.0 are not modified as to temperature limit, solubility, insu Fuel contributed..................negligible lation value, fire resistance or otherwise by "binder Smoke produced.................. 0.0 limitations." (( STRUCTURAL INSULATING BLOCK Good Workability--Kaylo Structural Insulating Block is responsive to wood working tools. It can be sawed with a hand saw or power saw, can be routed. tongue-andgrooved, sanded, and. in fact, run through most wood working equipment. Dimensionally Stable--The dimensions of Kavlo Struct ural Insulating Block change little with changes m moist ure content. Experience has shown from the manufacture of thousands of units of laminated structures that thev have unusual dimensional stability and unusual freedom from warping. High Modulus of Elasticity--The modulus of elasticity of 20-lb. density block is approximately 160,000 lb. per sq. in. low Specific Hoot--The specific heat of Kaylo Struc Available with and without Reinforcing--In the form of roof tile Kaylo Structural Insulation is available with a steel reinforcing mat. In the form of core material for var ious types of structure it is available without reinforcing. tural Insulating Block is approximately 0.22. Cellular Structure--Kaylo Structural Insulating Block is about 80 per cent inter-communicating air cells. The cells are extremely small, less than a micron in diameter. low Moisture Absorption--Kaylo Structural Block is hygroscopic. It will absorb moisture from humid air and wall reach equilibrium at lower moisture contents when exposed to lower humidities. However, because of its extremely small pore size and other characteristics, its behavior with respect to moisture differs from that of Accepts Nails and Screws--Both nails and screws can be used with Kaylo Structural Block. Tables showing holding power of both are available on request. Nails should be of the cement-coated type without barbs that abrade the sides of the opening they make as they are driven into the block. Galvanized or non-ferrous nails may be used where greater resistance to corrosion is required" Screws may be inserted either with or without drilling a pilot hole. Sites--Kaylo Structural Insulating Block is made in a standard size of 18 x 36 inches. t .most porous materials. It has unusual capacity to dis- Since most uses involve manufacturing operations, thick tribute moisture within its mass, and to give it off to nesses that are practical can best be worked out with the surrounding air of lower moisture content. manufacturer of Kaylo Insulating Products after approxi Its moisture absorption when surrounded by humid air is low. Test specimens dried for 24 hours at 215 F.. mate quantities needed are known. These will usuallv be between one and two inches thick. cooled and then exposed on all surfaces to an atmos phere of 90 per cent relative humidity and a tempera ture of 120 F. for six hours, absorbed less than one per cent of moisture by volume. Certain thicknesses are suggested by certain building re quirements. A thickness of from l1*' to 2 inches of Kavlo Structural Insulating Block is required to withstand a typical building fire for one hour--usually somewhat more Consistent with the common practice for good construc tion involving porous insulating materials of high internal surface area. Kaylo Structural Insulating Block should be sealed against moisture on the warm side when it is subjected to extremely low temperatures. for a partition than for a door because of the greater per formance required of a partition. 20-lb. and 11-lb. Dansity Slock Can So Used in Combination. Where two thicknesses of insulation are used to build up an insulating structure it is possible to use the two den High Wet Strength--Kaylo Structural Insulating Block, like most other insulating materials, is not intended to serve immersed in water or exposed to extremely damp or humid conditions, yet its flexural strength when wet (immersed 10 hours) is reduced only about 15 per cent. sities in combination to develop the best insulation value strength and fire resistance. Kaylo Division OWENS-ILLINOIS GLASS COMPANY 20-LB. DENSITY [ structural insulating block - OKSCRIPTION Keyie Strvctvral Insulating Black--is a near-white, rigid mineral insulating material weighing approximately 20 pounds per cubic foot. It is composed principally of calcium silicate. Except for density and for those characteris tics that are changed by density it is similar to Kaylo Heat Insulating Block, a lightweight insulation used to insulate against heat loss from hot surfaces. Kaylo Structural Insulating Block (20-lb. density) is designed to develop maximum strength and Are resistance without sacrificing its advantages of light weight and low thermal conductivity. In fact the practical combination of these four properties--strength, weight, insulating value and fire resist ance--makes it almost unique as a building material. It weighs nominally 20 pounds to the cubic foot (actually on an oven dr basis from 19.5 to 22 lb.), has a compressive strength of approximates 5"" lb. per sq. in., a "k" of 0.66 at 100 mean and outstanding resistance to travel of heat and flame at building fire temperatures. lamination ( .omination ovor a Kaylo Insulating Cor--Almost any face material may be bonded to Kaylo Structural Insul ating Block surfaces. Bonding agents can be selected to meet the requirements of the particular facing--also to satisfy the service requirements of the finished product -- and still offer some choice in curing procedures. ADHESIVES AND PRIMERS FOR JOINING some adhesive- and primers wpacr. may oe useo various types of face materials are listed below idiineenni.st.t.ii.fnf.vy.o..t.aa.i.n..npt.e.aa.n.rr-dtti-ieaa-dll -tll-oiis-s-rbt--eou^cfjo'maJdi.phiyleestpeiuv.repIstos.seoAninsly; apduhrepsoisvee is to re listed does not imply that it is not suitable. These ua.'B been found to provide a tensile strength of 35 ib^ per square inch and a minimum shear strength of 100 lb per square inch jvhen cured according to the manufac turer s recommendation. They are not listed in the order of their adhesive strength.) STRUCTURAL INSULATING BLOCK TO: Wood Vonoer or Paper or Plastics Steel, Stainless Steel Golvana!. or Aluminum Kayla Insulating Block er Cement-Asbestos Board ii . Ovpif* No. 3026a Po*CO<it Oil31 tieox 711 Ca'abood 720 Vldylieol MA 2MI Amfcortito PR 14 Sei'ik 7026 (dul Srxe S-I34I + I301W |0w| toaorBooeod R-12 oO o o o o o o o o Armstrong J-1162 Togo 0 o Dvrito No. 3026A or No. ANH267 NIOO W O Pocoro 711 O 3MIC 126 900 PtflOCOfifO 01131 InsoKlfO No. 1 tnfortoko 4162 VwkofocR 0 0 oo oo DuPont 4633 GOO DvPent S646 GOO IttonobcN R-12 G.C. 2142 G.t 7031 0 o o SetHk 7026 Soihk ut 131 lottlk 1007 VWiyfeool MA 21-11 AmboriilG PR-14 loAix A/WMfrong 2-1162 0 o 0 o o o o Ovrife 3026A PenaceSte 01131 A/NiUroAg J 1162 ImoHrto l GA 2142 Seleetren 3003 VWrfceel MA 20-10 Awtoriiio PR-14 leal* 7026 SeeMk 1X1136 Sodiowi Silcoto t4wa Synce X-I34I+1301W (0W| Rotorvofcond 1-12 Togo O 0 0 0 0 0 o 0o 0 0 o 0 0 o Q Clomped at room temperature for 24 hours. Q Clamped in oven at 120* F. for 1 hour. Symbols for method of rarot 0 Placed in pros* at 10 p.s.i. at 300* P. for 10-30 minutes. For Maximum Strength ^ "i Q Placed in press at 100 p.s.i. at 300* P. for 10-30 minutes. Q Clamped in even at 2S0* P. for 10-30 minutes. High-frsquency cuhni hss been tried successfully on an experimental basis with wood, aluminum and stainloa steel bonded to a Kaylo .isuiacing core. Many of the manufacturers miking tht above listed adhesives ean provide adhesivee suitable for high-frequency curing. Keyle Division OWENS-ILLINOIS GLASS COMPANY Teled* 1, Ohio (12 JOJ 2m Cov'*>" t*4l. Oasm-RMos Clou C** *'<o* vl* The Right Material... Expert Application First. Kaylo Heat Insulation is proted a better material hvdrous calcium silicate. Its light weight, strength, waterinsolubility, low conductivity and wide temperature range give you extra advantages rit no extra cost. Second. Kaylo distributors have the technical knowledge and experience to provide you with a complete insulating service. Their trained applicators are skilled craitsmen who do neat and efficient installation. To be snrc of getting the most out of your insulating dollars for your next job. call the nearest Kaylo distributor. Chances are you can find him listed in the yellow pages of your phone book. If not contact us and we'lt give you his name. wild lot lilt loot--"Karl* Htai imuleiii O0t. N.J70. 0iBn>iili*O't Gian C po*r. D*io*. FoOh*. KAYLO a a . first ItI CQldutTI Silicate ... pioneer ed by OWENS (j)>ILLINOIS Glass Company main omici: ronoo i. OHio-xarto utn omen. aiuwu cmcaoo Houston hist tow aHiuoiirm* ntmutOH si ioun Owens Illinois Glass Company --Kaylo Division AdwMitrmtni No. K m. appefin m th follow,n| publication*; Chemical Engineering Jan 1951 Oil bGn Journal - Jan 12. 1951 Plant Engineering Jan . 1951 Power - Jan . I9SJ Pftrn'fum ReAner -Feb 1953 Chemical Proceeding - Feb.. 19>1 Comburtion -Fth . 1953 If. * , rv Power -- Feb 1953 r via / 1 to Infinity Nesting Kaylo Heat Insulation Requires Fewer Pieces Per Job The complete range of Kaylo Insulation includes pipe covering in Simplified Dimensional Standards for diameters from 14 in. to 72 in., curved block from 72 in. to 60 ft. and flat block for surfaces of less curvature whose radii approach infinity. With its wide selection of interchangeable sizes and shapes. Kaylo Insu lation reduces the number of items needed per job and permits substantial savings in warehousing maintenance stock. wun rot nu tool-- |f|YIO Atftfrowi Otwiixw, Tetop* I, Oho- G*m Compony. mH ... first in calcium silicate ...pioneered by OWENS (^ILLINOIS Glass Company MAIM OlfICI: fOllOC I. OMIO-KATIO taut OffICUl ATUkNU CMICM.O HOUSTON NfW TOM fNIUOIlTNIA rrmiulOH If IOUU Owens-Illinois Glass Company A4vai*amttt Ho. fC-15*--mppaannc >< the following pufcbcatiena: Plant Kn(m*tnn|-- March. 195) Oil A Cat Journal-March 2). <913 Chamca> KnsiMertnt-March. >953 Chemical Proceaemf April. 1953 Petroleum Refiner May. 1953 ( PROOF OF SERVICE The undersigned certifies that a copy of the foregoing instrument was served upon the attorneys of record of all parties to the above cause by enclosing same in an envelope with postage fully prepaid, and by depositing said envelope in lasa United States Post Office mail box in Peoria, Illinois, on ____ / 19 . addressed to such attorneys at their business address as disclosed by the pleadings of record herein. Copy Mailed To: See attached list c Carol Ann Cooke, and Judith Ann O'Neal, Special Co-Administrators for the Estate of Ben Smith, Deceased and Carol Ann Cooke, Individually 4 E 5S00 COOKE ECOOKE STATE OF ILLINOIS IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT McLEAN COUNTY Law No.: 88 L 52 ATTORNEYS FOR PLAINTIFFS James Walker P.0. Box 3455 Bloomington, IL 61702-3455 ATTORNEYS FOR A & H INSULATION Edward J. Matushek, III HASKELL & PERRIN 200 V. Adams St. - Suite 2600 Chicago, IL 60606 Gregory C. Knapp SAINT & AMBROSE, P.C. 5th Floor - Suite A 200 W. Front St. Bloomington, IL 61701 ATTORNEYS FOR ABEX CORPORATION Robert W. Scott SWAIN, HARTSHORN & SCOTT 1806 Savings Center Tower 411 Hamilton Blvd. Peoria, IL 61602 W.R. GRACE & CO. Bret S. Babcock DAVIS A MORGAN 1125 Flrat National Bank Bldg. Peoria, IL 61602 EAGLE-PICHER Lloyd E. Williams WILLIAMS & MONTGOMERY 20 N. Wacker Dr. - Suite 2100 Chicago, IL 60606 * , JOUU Carol Ann Cooke c r ATTOKNETS FOR RATMARK and CELOTEX Fred B. Moore LIVINGSTON, BARGER, BRANDT & SCHROEDER 204 Unity Bldg. P.0. Box 3457 Bloomington, IL 61701 Raymond H. Modesitt PATRICK, WILKINSON, GOELLER & MODESITT 333 Ohio St. P.O. Box 1567 Terre Haute, IN 47808 ATTORNEYS FOR SPRINKMANN SONS CORP., GATKE CORPORATION and EMPIRE ACE James A. Carter HAFELE, THIEMANN & ASSOCIATES 717 First National Bank Building Peoria, IL 61602 OWENS-CORNING FIBERGLAS Robert L. Martier LUNDBLAD & BAKER 401 S. LaSalle St. Chicago, IL 60605 GARLOCK Anthony G. Barone BURDITT, BOWLES, RAD2IUS & RUBERRY 333 W. Wacker Dr. - Suite 1900 Chicago, IL 60606 CHESAPEAKE & OHIO RAILWAY COMPANY, ILLINOIS CENTRAL INDUSTRIES, INC. and ILLINOIS CENTRAL RAILROAD COMPANY William R. Gavin Gundlach, Lee, Eggmann, 5000 W. Main St. Box 692 Belleville, IL 62222 Boyle & Roessler 2 Carol Ann Cooke C C ATTORNEYS FOR BRAND INSULATIONS, INC. Corey P. O'Dell KURNIK, CIPOLLA, STEPHENSON, 120 W. Eastman * Suite 302 Arlington Heights, IL 60004 BARASHA AND O'DELL, LTD. Don C. Hammer Hayes, Schneider, Hammer, 202 N. Center St. P.O. Box 3067 Bloomington, IL 61702 Miles & Cox ATTORNEYS FOR FLINTKOTE Francis A. Spina Tressler, Soderstrom, Maloney & Priess 2100 Manchester Road - Suite 950 Wheaton, IL 60d87 3