Document dQJk2z9RZZvJMYBanJ6nBrrrQ

FILE NAME John Crane JC DATE 2004 DOC JC013 DOCUMENT DESCRIPTION Legal - John Crane Answers to Interrogatories Sworn Answers to Interrogatories by John Crane in the Newport News Circuit Court dated April 2004 Interrogatory No. 1 State your correct corporate name the state of your incorporation the address of your principle place of business Answer Crane Packing Company was organized in Illinois in 1917. It merged with John Crane Houdaille a Delaware corporation on August 1981. On March 27 1988 Defendant changed its name to John Crane Inc. Sworn Answers to Interrogatories by John Crane in the Newport News Circuit Court dated April 5 2004 e Interrogatory No. 6 Identify all products which contained any amount of asbestos which you manufactured me a the brand name of each product e b a specific description of the product e f the location of each manufacturing facility Sworn Answers to Interrogatories by John Crane in the Newport News Circuit Court dated April 2004 Answer to Interrogatory No. 6 e a See the John Houdaille General Asbestos Packing Style List e f Morton Grove Illinois 1960-85 Sworn Answers to Interrogatories by John Crane in the Newport News Circuit Court dated April 5 2004 Interrogatory No. 7 As to each product any and all catalogues or data which would have accompanied each product g any and all photographs of the product h any and all samples of the product Answer e See catalogues attached to Answer 50. g None are available except what is shown in the catalogues h John Crane previously gave samples to plaintiffs counsel John Crane has no other samples to produce Sworn Answers to Interrogatories by John Crane in the Newport News Circuit Court dated April 5 2004 e InterrogatoNroy. 11 When and how did you first become aware that any warnings were placed on any containing products im A nswer Defendant first became aware of warnings on bags of raw asbestos about 1980 but it has no records in that regard Sworn Answers to Interrogatories by John Crane in the Newport News Circuit Court dated April 2004 e Interrogatory No. 15 Do you have knowledge of any asbestos deaths or any diagnosis of asbestosrelated lung disease prior to 1986 among any of your employees Sworn Answers to Interrogatories by John Crane in the Newport News Circuit Court dated April 2004 Answer to Interrogatory No. 15 The claimants were a Raul Soza sales b Joseph Leon c Jaime Cruz a d Anthony Edwards e James Smail sales f Sue Payne On information and belief John Crane states none of these people claimed they had a malignancy of any kind Sworn Answers to Interrogatories by John Crane in the Newport News Circuit Court dated April 5 2004 e Interrogatory No. 19 State whether your Board of Directors prior to 1986 at any time had any meetings which included discussion of or reference to installation removal, asbestos exposure the sale use or handling of asbestos products or any alleged health hazards associated with asbestos any recommendation or discussion of warnings caution labels safety procedures or testing for the asbestos products any claims for compensation arising our of persons who alleged asbestos related death disease abnormality or impairment e Answer Defendant has found no record of any such discussions Sworn Answers to Interrogatories by John Crane in the Newport News Circuit Court dated April 2004 e Interrogatory No. 20 Identify your medical officers from 1940 through 1986 If you did not have a medical officer please identify what person or persons performed functions related to employee health within your company Answer Defendant did not employ a medical officer It did maintain a first aid station staffed by a nurse Sworn Answers to Interrogatories by John Crane in the Newport News Circuit Court dated April 2004 e Interrogatory No. 44 Prior to 1972 did Defendant ever advise any purchaser or user of containing products that there was any threshold limit value which applied to the dust created from the use of containing products and that the dust associated with the use of containing products should be kept below the threshold limit value of five million particles per cubic foot Answer No. Sworn Answers to Interrogatories in the United States District Court for the Eastern District of Virginia Newport News Division - January 13 1988 Interrogatory No. 2 Identify all other manufacturers of each product containing asbestos from whom you bought products Supplemental Answer 2/12/88 : John Crane beginning in the 1930's purchased sheet packing at various times from Raybestos- fm Manhattan Corp. Richard Klinger Co. and Gatke Corporation The sheet packing was labeled by such sellers for John Crane by imprinting the particular style number on the material along with the names John Crane and Crane Packing Co. Sworn Answers to Interrogatories in the United States District Court for the Eastern District of Virginia Newport News Division - January 13 1988 Interrogatory No. 3 Describe in detail Houdaille's complete corporate history e Answer Crane Packing Company was organized in Illinois in 1917 and began the manufacture and sale of containing products about 1930. It merged with John Houdaille Inc. a Delaware corporation on August 3 1981 Sworn Answers to Interrogatories in the United States District Court for the Eastern District of Virginia Newport News Division - January 13 1988 Interrogatory No. 4 State all components with percentage amounts for each product containing asbestos manufactured by Crane- Houdaille Supplemental Answer 2/12/88 Sheet packing a and gaskets were usually 75 to 85 Chrysotile fibers was primarily used though for a few certain special applications crocidilite would have been used Sworn Answers to Interrogatories in the United States District Court for the Eastern District of Virginia Newport News Division - January 13 1988 Interrogatory No. 5 State the name and address of each entity from whom Houdaille has ever bought or received raw asbestos fiber Answer John Crane states that its records are incomplete for all of the suppliers of asbestos materials to John Crane but its most common suppliers of such products and materials were Manhattan Manville Amatex Richard Klinger Inc Southern Asbestos Southern Textile Vermont Asbestos Group Asbestos Corp. Ltd Donald R. Fitzgerald Co and Gatke Corporation Sworn Answers to Interrogatories in the United States District Court for the Eastern District of Virginia Newport News Division - January 1988 Interrogatory No. 19 When did Crane- Houdaille first receive any information that exposure to asbestos might cause illness or disease Answer John Crane first learned of the alleged health hazards of asbestos in approximately 1970 by reason of general publicity surrounding the passage of OSHA Sworn Answers to Interrogatories in the United States District Court for the Eastern District of Virginia Newport News Division - January 13 1988 Interrogatory No. 20 As to each asbestos associated disease asbestosis lung cancer mesothelioma etc. of which Houdaille is presently aware state the date that Houdaille first received any information that said disease process might be caused by exposure to asbestos Answer See response to Interrogatory No. 19