Document dQVOd087912K7r0VG323LMBdG

FILE NAME: Synkaloid (SYN) DATE: Undated DOC#: SYN025 DOCUMENT DESCRIPTION: Legal - Defense response to interrogatories 30-32 and 49-50 INTERROGATORY ISO. 30; Does Defendant contend that asbestos products can be manufactured or designed so as to eliminate all potential health hazards to persons working with or exposed to them? If the answer is affirmative, explain in detail, and attach any studies or surveys on which this answer is based. ANSWER: Defendant objects on the grounds this question is completely irrelevant, overbroad, ambiguous and speculative. It pertains to all types of "asbestos products" and thus extends far beyond the types of products which The Synkoloid Company previously manufactured which contained small amounts of chrysotile asbestos for limited purposes. Wtrether or not "asbestos products" can be so manufactured or designed today using the latest technological advances is irrelevant to The Synkoloid Company's limited use of asbestos between 1949 and March, 1976. IN TERRO G ATO RY NO. 31 : Describe in detail the types of packages or packaging which Defendant or any of its subsidiary or predecessor companies used for asbestos material or products, listing the dates each type of package was used, a physical description of each type of package, and providing a description of any printed material or trademarks that appeared thereon. ANSWER: The Synkoloid Company objects to the extent this interrogatory is overbroad in scope and requests information which is irrelevant and not reasonably calculated to lead to the discovery of admissible evidence. Subject to these objections, and without waiving same, Defendant refers to its June 1972 catalog, which is available for inspection at the office of the undersigned counsel Defendant has found it difficult, if not impossible, to respond to this interrogatory due to the passage of time and lack of necessary documents or information. However, to the extent such information is available, Defendant refers to its answer to Interrogatory Nos. 6 and 22. INTERROGATORY NO. 32: Has Defendant or any of its subsidiary or predecessor companies at any time entered into a "rebranding" agreement with any other company, either as buyer or seller, concerning asbestos materials or asbestos products? If so. state, as to each such agreement: A. The name of the company manufacturing the asbestos products. B. The trade name affixed to those products. THE SYNKOLOID CO.'S ORIECIIONS. ANSW DS AND RESPONSES TO PLAINTIFFS' MASTER MTERROGATORIES AND REQUESTS POR PRODUCTION PROPOUNDED TO DEFENDANT P^ .1 1 CAMERON MASTER ANSWER: The Synkoloid Company objects to this interrogatory as overly broad, vague, ambiguous as to the meaning of the term "Research Department," irrelevant and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving said objections and limiting our response to those years during which The Synkoloid Company utilized small amounts of chrysotile asbestos in some of their products, Defendant responds: Not to our knowledge. INTERROGATORY NO. 49: Does your company have, or has it ever had, or have your predecessor(s) or subsidiaries ever had, a Medical Department? If so, state: A. The year such Medical Department was established; B. Whether or not such Medical Department has operated continuously since being established; C. The name of each director, chief, or head of your Medical Department year by year, beginning with the first year you had a Medical Director or Medical Department, and the last known address and phone number of each; D. State the duties and responsibilities of such Medical Department. ANSWER: The Synkoloid Company never had a Medical Department as that term is used and implied in this interrogatory. INTERROGATORY NO. 5fli Did your company or its predecessors) or subsidiaries ever place any warning directly on any of its asbestos-containing product or on their packaging. If so, identify the product(s) and year said warning was first applied. ANSWER: The Synkoloid Company states that it lacks documents or other information that would indicate whether or not such information was published or distributed, but states that, based upon the information known or reasonably available to Synkoloid Company, a caution clause was placed on Synkoloid's 25 lb. bags used by professional^applicators. However, Synkoloid further answers that such information was unnecessary. Synkoloid began the reformulation of its products to remove asbestos after it learned in 1975 that there might be a health risk associated with asbestos. T H E SY N K O LO ID C O .'S O BJECTIO N S, ANSWERS AND RESPONSES T O PLAINTIFFS* MASTER INTERROGATORIES AND REQUESTS FOR PRODUCTION PROPOUNDED TO DEFENDANT PM 40 CAMERON MASTER