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FILE NAME Kaiser Gypsum KG DATE 1996 DOC KG047 DOCUMENT DESCRIPTION Legal - Updated Responses to Interrogatories PATRICK E. JANE J. HAGAN ESQ State Bar 68264 WELLS ESQ State Bar 112178 DILLINGHAM & MURPHY 225 Bush Street Sixth Floor San Francisco CA 94104-4207 415 397-2700 Attorneys for KAISER GYPSUM Defendant COMPANY INC SUPERIOR COURT FOR THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN FRANCISCO IN RE COMPLEX SAN FRANCISCO COUNTY ASBESTOS LITIGATION CASE NO 828684 KAISER GYPSUM COMPANY INC.'S UPDATED RESPONSES TO PLAINTIFFS STANDARD INTERROGATORIES TO DEFENDANTS PROPOUNDING PARTY : RESPONDING PARTY : Plaintiffs Defendant Kaiser Gypsum Company Inc. SET Standard DATE December 30 1996 COMES NOW defendant Kaiser Gypsum Company Inc. hereinafter 20 Kaiser Gypsum and provides the following updated responses to 21 plaintifs pplaintiffs laintiffs standard interrogatories propounded pursuant to San 22 Francisco County Complex Asbestos Litigation General Order No. 29 29 KAISER GYPSUM'S PRELIMINARY STATEMENT AND OBJECTIONS 24 Kaiser Gypsum was constituted in 1952 and has been 25 headquartered in California since that date Kaiser Gypsum 26 disposed of its last operating manufacturing plant in August 1978 27 and subsequently has not engaged in manufacturing or product sales 281 anywhere in the United States Thus all Kaiser Gypsum product  sales occurred between 1952 and 1978 Therefore Kaiser Gypsum's responses to plaintiffs standard interrogatories are based almost entirely on its ongoing review of documents presently available to the These updated interrogatory responses reflect Kaiser Gypsum's knowledge at this time and supersede any previous interrogatory answers Kaiser Gypsum reserves the right to further supplement these responses in the event that more complete or accurate information becomes available Kaiser Gypsum notes that these responses are made without reference to the factual circumstances of any particular case and accordingly Kaiser Gypsum reserves the right to state additional objections or provide supplemental responses that might be appropriate in the specific context of a given plaintiff's claim Kaiser Gypsum objects to requests for information that are unlimited as to geographical scope on the grounds that such requests are unduly burdensome and are not reasonably calculated to lead to the discovery of evidence admissible in cases that are 19 subject to General Order No. 29. Accordingly Kaiser Gypsum's 20 present responses hereto are limited to products sold and 21 operations conducted within the State of California 22 Kaiser Gypsum objects to these interrogatories to the extent 23 that they call for information protected by the attorney 24 privilege or work product doctrine 25 This Preliminary Statement and the objections contained forth 26 herein are incorporated into each of the responses set 27 below 28 / / 1 KAISER GYPSUM'S RESPONSES TO INTERROGATORIES RESPONSE TO INTERROGATORY NO 1 a Joseph R. Hobby b 2680 Bishop Drive Suite 225 San Ramon California 94583 c Vice President d present Vice President RESPONSE TO INTERROGATORY NO 2 Kaiser Gypsum is a corporation a Its full and correct corporate name is Kaiser Gypsum Company b Inc. Kaiser Gypsum is incorporated under the laws of the | State of Washington c Kaiser Gypsum was organized in 1952 through a somewhat complicated process Specifically on June 19 1952 Permanente Cement Company now known as Kaiser Cement Corporation formed a wholly owned subsidiary named Kaiser Gypsum Company a California 18 Corporation On August 1 1952 Kaiser Gypsum Company purchased 19 from the Henry J. Kaiser Company two gypsum wallboard plants 20 located at Long Beach and Redwood City California On December 1 1952 Kaiser Gypsum Company was merged into 22 Pacific Coast Cement Company another subsidiary of Permanente 23 Cement Company with Pacific Coast Cement Company a Washington 24 Corporation which at the time of the merger had no assets or 25 operations and which was incorporated on November 28 1927 being 26 the survivor The name of the combined company was then changed 27 to Kaiser Gypsum Company Inc. 28 i Kaiser Gypsum's principal place of business is located at 3000 Busch Road Pleasanton California 94566 e Kaiser Gypsum has held a certificate of authority to do business in California from 1952 to the present f Kaiser Gypsum's California registered agent is CT Corporation 818 West Seventh Street Los Angeles CA 90017 g Kaiser Gypsum is a wholly owned subsidiary of Kaiser Cement Corporation whose principal place of business is located at 3000 Busch Road Pleasanton California 94566 RESPONSE TO INTERROGATORY NO 3 Yes See the history of Kaiser Gypsum's formation in 1952 that is provided in its answer to Interrogatory c above RESPONSE TO INTERROGATORY NO 4 a No. b Not applicable c Not applicable RESPONSTEO INTERROGATORY NO 5 18 No. 19 RESPONSE TO INTERROGATORY NO 6 20 a Kaiser Gypsum's corporate records are located at its 21 headquarters whose address is 3000 Busch Road Pleasanton 22 California 94566 at 2680 Bishop Drive San Ramon CA 94583 and 23 at a commercial storage site or sites located in the greater San 24 Francisco area 25 b Joseph R. Hobby Vice President 2680 Bishop Drive San 26 Ramon California 27 RESPONSE TO INTERROGATORY NO 7 28 a through h No. RESPONSE TO INTERROGATORY NO 8 a See response to e and g b No. c See response to e and g d See response to e and g e Yes 1953 to 1976 f See response to e and g g Yes 1953 to 1976 RESPONSE TO INTERROGATORY NO 9 10 Not applicable 11 RESPONSE TO INTERROGATORY NO 10 12 I. 13 Kaiser Gypsum Gypsum's Business Gypsum Lath and Gypsum Wallboard Plaster - No Asbestos Used 14 Kaiser Gypsum was organized by Henry J. Kaiser 1882-1967 and 15 the famous industrialist World War II hero in 1952 and terminated its United States sales and manufacturing in 1978 Between 1952 and 1978 Kaiser Gypsum's principal business consisted of manufacturing and marketing gypsum plaster gypsum lath and gypsum wallboard The word gypsum is derived from the Greek word gypso meaning chalk Gypsum is hydrous calcium 21 22 23 24 25 26 27 28 sulfate Gypsum plaster is sometimes called Plaster of Paris because gypsum plaster was widely used in the capital of France during the 19th century Gypsum occurs in nature in rock form and is found in abundance in Baja California Mexico A. Gypsum Plaster Products During Kaiser Gypsum's first years in business most houses and many other buildings had interior walls that were made with plaster The plaster products sold by Kaiser Gypsum were essentially ground gypsum rock packaged in bags Such gypsum plaster products were mixed with water and an aggregate most commonly sand at the construction site to form a paste The paste was applied by hand and smoothed with a trowel to form a wall or ceiling surface Sometimes several layers of plaster were used with the underneath layers being brown in color and the surface layer being white When dried the plaster became quite hard A plaster wall or ceiling typically was finished by painting the plaster surface or coverinigt with wallpaper 10 Kaiser Gypsum's plaster products designed for the above 11 construction uses included Hardwall Plaster Fibered Hardwall 12 Plaster Dual Purpose Fibered Hardwall Plaster Dual Purpose 13 Unfibered Hardwall Plaster Wood Fibered Hardwall Plaster Slow 14 Set Gauging Plaster and Quick Set Gauging Plaster They also 15 included plaster products for casting e.g. making ornaments or 16 statues including Casting Plaster and Slow Set Casting Plaster Kaiser Gypsum also manufactured Plaster Retarder and Structural 18 Gypsum Mixed Gypsum Concrete Kaiser Gypsum plaster 19 products also included Mix plaster a mixed product 20 Gun Plaster introduced in 1957 was applied by mixing the sacked product on the job site in special portable mixing machines and it was then pumped through a large diameter hose to the inside of 24 a building where it was sprayed by plasterers onto walls with 25 comparative speed and economy Kaiser Gypsum never used asbestos 26 as a componenitn any of those products 27 28 B. Gypsum Lath Products 2 The surface to which gypsum plaster was applied was called lath Lath was sometimes made of wire but lath also could be 4 made of hard paper covered sheets of gypsum plaster called | stucco sometimes made with holes in them gypsum The lath sheets would be affixed to the interior wall framing and plaster would then be applied to the lath The holes in the lath would help keep the plaster in place while it dried Kaiser Gypsum made gypsum lath of this type Kaiser Gypsum lath products 10 included Plain Lath and Perforated Lath Back Insulating 11 Lath Duralath Gypsum Veneer Base and Kaiserwall Kaiser Gypsum 12 never used asbestos as a component in any of those products 13 14 15 16 17 18 19 20 21 22 23 C. Gypsum Wallboard Products In years following the Korean War there were numerous innovations in housing construction including many changes intended to lower housing construction costs One such change was the substitution of gypsum wallboard or drywall for plaster plaster Gypsum wallboard like gypsum lath is basically a hard sheet of gypsum plaster that is affixed to the wall framing Typically gypsum wallboard would be made in 8 feet long They typically were pieces that 1/2 inch or were 4 feet wide 5/8 inch thick and During the manufacturing plaster was covered by a process the wallboard's special paper that could core of gypsum be painted or 24 covered with wallpaper 25 Because more walls partitions or ceilings could be made 26 using gypsum wallboard in a given period of time than could be 27 made by plastering over lath constructing houses apartments and 28 other buildings with wallboard was less expensive Over time as building codes were were amended to permit use of gypsum wallboard more construction construction of interior walls partitions and ceilings cceilinegs cieilingls ings was done using wallboard and less using plaster Reflecting this trend Kaiser Gypsum's business focused more on gypsum wallboard as time passed By 1960 about half of the construction in California used wallboard and half still used plaster Plaster use continued to decline and by the early 1970's substantially all of the market market demand was for gypsum wallboard Kaiser Gypsum never used asbestos as a component in any of its gypsum wallboard 10 products 11 D. Asbestos Products Exceeded 90 of Total Sales 12 The bulk of Kaiser Gypsum's sales has always consisted of & 13 products that did not use asbestos as a component To illustrate 14 the following chart shows sales totals in dollars for the years 15 1969-1975 1969-1975 1969-1975 the last full year prior to the complete cessation of the use of asbestos as a component in Kaiser Gypsum products Asbestos Product 17 17 Year Asbestos Products Total Sales Percentage of Total 18 1969 41,360,000 43,299,000 96 19 1970 37,258,000 39,457,000 94 20 1971 48,403,000 51,671,000 1972 58,468,000 63,056,000 94 93 1973 65,803,000 71,382,000 22 1974 64,996,000 70,139,000 92 93 23 1975 41,318,000 43,935,000 94 24 As these figures illustrate Kaiser Gypsum's sales of non- 25 containing products always were substantially more than 26 90 of its business 27 28 II Accessories For Use With Gypsum Wallboard A. Nails Wall And Door Frames Cornerbead Paper Products - No Asbestos Used With the expansion of its gypsum wallboard business Kaiser Gypsum also began selling other products needed to construct ~ interior walls partitions or ceilings using gypsum wallboard These included special nails and other devices used to attach wallboard to the supporting frame They also included metal wall or partition frames especially made for installing wallboard 10 metal cornerbead used to make partition corners hard and metal 11 doorframes for use in walls made using gypsum wallboard Partly 12 to ensure that it could get access to adequate amounts of the 13 special paper used to make wallboard by covering its gypsum 14 plaster core Kaiser Gypsum acquired paper plants where it also 15 manufactured commercial paper products such as cardboard boxes 16 Kaiser Gypsum never used asbestos as a component in any of those 17 18 19 20 21 22 23 24 25 26 27 28 products - B. Wallboard Joint Compounds Asbestos Used As A Component. When the walls or ceilings of a room are made from gypsum wallboard large pieces of wallboard are installed side by side leaving small spaces where two pieces of wallboard meet These spaces need to be filled so that they cannot be seen after the wall is painted or covered with wallpaper The products used to perform that task are called joint compounds or joint finishing compounds At the time of use these joint compounds are thick putty or like substances which permits them to be pushed into the spaces and smoothed with a putty knife or spatula Paper or ey C 1 cloth reinforcing tape is pushed into the joint compound to help prevent cracking as the joint compound dries The joint compound dries to form a hard rock substance Kaiser Gypsum manufactured and marketed such wallboard joint compounds and prior to the 1970's these joint compounds contained a small percentage of chrysotile asbestos as a component The purpose of the chrysotile asbestos component was to prevent cracks from forming as the joint compound dried Asbestos is the Greek word for incombustiwbhl iceh refers to things that will not burn Chrysotile is the most common type of asbestos used in products in the United States Chrysotile is a fibrous rock material derived from the rock serpentine which is very common in California where it is the state rock These Kaiser Gypsum products were 1 Joint Cement Compound 2 Finishing Topping Compound 3 Purpose Wallboard Compound 4 . One Joint Compound 6 mix Joint Compound mix Finishing Compound 19 mix Dual Purpose Joint Compound 20 7 mix Topping Compound Laminating Compound 21 Kaiser Gypsum's separate responses to interrogatory subparts 22 a for each of these products are as follows 23 1 Joint Cement Compound 24 a The trade name of this product originally was Kaiser 25 Joint Cement about 1957 it was changed to Kaiser Joint Compound 26 b Kaiser Gypsum marketed Kaiser Joint Cement in 1952 but 27 did not manufacture the product itself Kaiser Gypsum does not 28 know whether the product marketed in 1952 contained asbestos as a hye component Kaiser Gypsum began manufacturing Kaiser Joint Cement in 1953 at which time chrysotile asbestos was used as a component c Kaiser Gypsum last manufactured Kaiser Joint Compound with chrysotile asbestos as a component in 1975 d The Kaiser Gypsum California plants that made this product were located at Redwood City and Antioch These plants were in operation at different times The product was manufactured at Redwood City from 1953 through 1957 and at Antioch 10 from 1957 to 1975. Because of the heavy weight of the product 11- low profit margin and high transportation costs distribution 12 tended to center around the location of the manufacturing plant 13 The product consisted primarily of minerals including casein or 14 polyvinyl clay talc limestone and mica The product 15 manufactured in Kaiser Gypsum's California plants included between 16 % by weight and 16 by weight chrysotile asbestos as a component 17 depending on the formula in effect at a given date 18 e This product was a white to white powder It was packaged and sold in sacks of 10 to 25 lbs and in boxes of 5 and 2018 2018 lbs Each container was labeled with the name of the 21 manufacturer Kaiser Gypsum Company Inc. the name of the product 22 and directions for its use 23 f This product was a dry powder which when mixed with 24 water formed a thick paste Upon application it dried to a hard 25 durable surface It was used to fill gypsum wallboard joints 26 embed joint reinforcing tape finish joints and to cover and 27 finish nail heads and metal cornerbead 28 3 2 Finishing Topping Compound 2 a The trade name of this product was Kaiser Gypsum Finishing topping Compound b Kaiser Gypsum began manufacturing finishing topping compound in 1955 and chrysotile asbestos was used as a component at that time c Kaiser Gypsum last manufactured finishing topping compound with chrysotile asbestos as a component in 1975 d The Kaiser Gypsum California plants that made this 10 product were located at Redwood City and Antioch These plants 11 were in operation at different times The product was 12 manufactured at Redwood City from 1955 to 1957 and at the Antioch 13 plant from 1957 to 1975. Because of the heavy weight of the product low profit margin and high transportation costs 15 distribution tendetdo center around the location of the 16 manufacturing plant This product consisted primarily of minerals 17 including casein or or polyvinyl clay talc limestone and mica 18 The product included between 5.3 by weight and 16 by weight 19 chrysotile asbestos as a component depending on the formula in 20 effect at a given time 21 e This product was a white to white powder It was 22 packaged and sold in sacks of 25 lbs Each container was labeled 23 with the name of the manufacturer Kaiser Gypsum Company Inc. 24 the name of the product and instructions for its use 25 f This product was a dry powder which when mixed with 26 water formed a thick paste Upon application it dried to a hard 27 durable surface It was used to top and finish gypsum wallboard 28 joints -- 3 a Purpose Wallboard Compound The trade name of this product was Kaiser Gypsum 3- Purpose Wallboard Compound b Kaiser Gypsum began manufacturing Purpose Wallboard Compound in 1968 and chrysotile asbestos was used as a component at that time c Kaiser Gypsum last manufactured Purpose Wallboard Compound with chrysotile asbestos as a component in 1976 d The Kaiser Gypsum California plant that made this 10 product was located at Antioch Because of the heavy weight of 11 the product low profit margin and high transportation costs 12 distribution tended to center around the location of the a 13 manufacturing plant This product consisted primarily of minerals 14 including casein or polyvinyl clay talc limestone and mica 15 The product included between 5.1 by weight and 14.2 by weight 16 chrysotile asbestos as a component 17 e The product was a white to white powder It was 18 packaged and sold in sacks of 25 lbs Each sack was labeled with 19 the name of the manufacturer Kaiser Gypsum Company Inc. the 20 name of the product and directions for its use 21 f This product was a dry powder which when mixed with 22 water formed a thick paste Upon application it dried to a hard 23 durable surface It was used to tape top and finish gypsum 24 wallboard joints nailheads and metal cornerbead 25 4. One Joint Compound 26 a The trade name of this product was Kaiser Gypsum Day 27 Joint Compound Powder 28 an b Kaiser Gypsum began manufacturing One Day Joint Compound Powder in 1968 and chrysotile asbestos was used as a component at that time c Kaiser Gypsum last manufactured One Day Joint Compound Powder with chrysotile asbestos as a component in 1975 d The Kaiser Gypsum California plants that made this product were located at Santa Ana and Antioch Because of the heavy weight of the product low profit margin and high transportation costs distribution tended to center around the 10 location of the manufacturing plant The product consisted 11 primarily of limestone and mica The product included 12 3.4 by weight chrysotile asbestos as a component 13 e This product was a white to white powder It was packaged and sold in sacks of 25 lbs Each sack was labeled with 15 the name of the manufacturer Kaiser Gypsum Company Inc. the 16 17 18 19 name of the product and directions for its use f This product was a dry powder which when mixed with water formed a thick paste Upon application it dried to a hard durable surface It was used to fill gypsum wallboard joints 20 embed joint reinforcing tape finish joints and to cover and 21 finish nailhead and metal cornerbead 22 5 Mix Joint Compound 23 a The trade name of this product was Kaiser Gypsum Mix 24 Joint Compound b Kaiser Gypsum began manufacturing Mix Joint Compound in 1959 and chrysotile asbestos was used as a component at that time c Kaiser Gypsum last manufactured Mix Joint Compound with chrysotile asbestos as a component in 1962 d The Kaiser Gypsum California plant that made this product was located at Long Beach Because of the heavy weight of the product low profit margin and high transportation cost distribution tended to center around the location of the manufacturing plant This product consisted primarily of minerals including casein or polyvinyl clay talc limestone and mica The product included chrysotile asbestos as a component The 10 percentage presently is unknown Investigation is continuing | 11 e This product was a white to white colored paste was packaged and sold in cans of 4 or 5 gallons and in cartons of 13 5 gallons Each container was labeled with the name of the 14 manufacturer Kaiser Gypsum Company Inc. the name of the product 7 15 and directions for its use 16 f This product was a thick paste like material which upon application dried to a hard durable surface It was used to fill 18 gypsum wallboard joints embed joint reinforcing tape finish 19 joints and to cover and finish nailheads and cornerbead 20 6 Mix Finishing Compound 21 a The trade name of this product was Kaiser Gypsum Mix 22 Finishing Compound 231 b Kaiser Gypsum began manufacturing Mix Finishing 24 Compound in 1959 and chrysotile asbestos was used as a component ; 25 at that time 26 c Kaiser Gypsum last manufactured Mix Finishing 27 Compound with chrysotile asbestos as a component in 1962 28 1 d The Kaiser Gypsum California plant that made this product was located at Long Beach Because of the heavy weight of the product low profit margin and high transportation cost distribution tended to center around the location of the manufacturing plant This product consisted primarily of minerals including casein or polyvinyl clay talc limestone and mica The product included chrysotile asbestos as a component The percentage presently is unknown Investigation is continuing e This product was a white to white colored paste It 10 was packaged and sold in cans of 4 or 5 gallons and in cartons of 11 5 gallons Each container was labeled with the name of the 12 manufacturer Kaiser Gypsum Company Inc. the name of the product 13 and directions for its use 14 f This product was a thick paste like material which upon application dried to a hard durable surface It was used to finish gypsum wallboard joints and to cover and finish nailheads and cornerbead 7 Mix Dual Purpose Joint Compound a The trade name of this product was Kaiser Gypsum Mix Dual Purpose Joint Compound b Kaiser Gypsum began manufacturing Mix Dual Purpose Joint Compound in 1960 and chrysotile asbestos was used as a component at that time c Kaiser Gypsum last manufactured Mix Dual Purpose 25 Joint Compound with chrysotile asbestos as a component in 1975 26 d The Kaiser Gypsum California plants that made this 27 product were located at Long Beach Antioch and Santa Ana 28 Because of the heavy weight of the product low profit margin and ater, Neel! high transportation costs distribution tended to center around the location of the manufacturing plant This product consisted primarily of minerals including polyvinyl clay talc limestone and mica The product included between 1.5 by weight and % by weight chrysotile asbestos as a component depending on the formula in effect at a given date e This product was a white to white or light buff colored paste It was packaged and sold in 5 gallon metal cans or plastic pails and 4 or 5 gallon cartons Beginning in 1966 small 10 amounts were sold in 5 quart plastic buckets as an accommodation 11 product for lumber dealers under the name purpose premix 12 compound Each container was labeled with the name of the 13 manufacturer Kaiser Gypsum Company Inc. the name of the product and directions for its use 15 f This product was a thick paste like material which upon 16 application dried to a hard durable surface It was used to 17 finish finish gypsum wallboard joints embed joint reinforcing tape 18 fifnish inish joints and to cover and finish nailheads and metal 19 cornerbead 8 a Mix Topping Compound The trade name of this product was Kaiser Gypsum Mix Topping Compound b Kaiser Gypsum began manufacturing Mix Topping 24 Compound in 1968 and chrysotile asbestos was used as a component 25 at that time 26 c Kaiser Gypsum last manufactured Mix Topping Compound 27 with chrysotile asbestos as a component in 1976 28 1 d The Kaiser Gypsum California plants that made this product were located at Santa Ana and Antioch Because of the heavy weight of the product low profit margin and high transportation costs distribution tended to center around the location of the manufacturing plant This product consisted primarily of minerals including casein or polyvinyl clay talc limestone and mica The product included between 0.9 by weight and % by weight chrysotile asbestos as a component depending on the formula in effect at a given date e This product was a white to white or light buff colored paste It was packaged and sold in metal and plastic buckets of 4 or 5 gallons and in cartons of 4 gallons Each container was labeled with the name of the manufacturer Kaiser Gypsum Company Inc. the name of the product and directions for | its use f This product was a thick paste like material which upon aplication aplication aplication aplication aplication application apalicatpion papllicatiion cation dried to a hard durable surface It was used to top 18 and finish gypsum wallboard joints 19 9 Laminating Compound 20 a The trade name of this product was Kaiser Gypsum 21 Laminating Compound 22 b Kaiser Gypsum began manufacturing Laminating Compound in 23 1961 at which time chrysotile asbestos was used as a component 24 c Kaiser Gypsum last manufactured Kaiser Gypsum Laminating 25 Compound with chrysotile asbestos as a component in 1972 at which 26 time the product was discontinued 27 d The Kaiser Gypsum California plants that made this 28 product were located at Antioch and Santa Ana These plants were in operation at different times The product was manufactured at Antioch from 1961 through 1970 and at Santa Ana in 1971 and 1972 Because of the heavy weight of the product low profit margin and high transportation costs distribution tended to center around the location of the manufacturing plant The product consisted primarily of soya flour and limestone The product included between 6.5 by weight and 10 by weight chrysotile asbestos as a component depending upon the formula in effect at a given date e This product was a white to white powder It was packaged and sold in sacks of 25 lbs Each container was labeled with the name of the manufacturer Kaiser Gypsum Company the name of the product and directions for its use Inc. f This product was a dry powder which when mixed with water formed a thick paste It was used as an adhesive to laminate one piece of gypsum wallboard to another which was occasionally done to create gypsum drywall partitions having 17 17 thicker wallboard than could be created by a single sheet For example gypsum wallboard typically came in sheets 1/2 inch and 5/8 inch thick If one wanted a gypsum wallboard that was 1 inch thick this would be created by laminating together two pieces of gypsum wallboard that were each 1/2 inch thick Laminating compound was used for this purpose Additionally it was used to laminate gypsum wallboard to sound deadening board which would increase the wall's capacity to prevent transmission of sound from one room to another 27 28 1 Kaiser Gypsum's responses to interrogatory subparts g applicable to all of the eight wallboard joint compound products discussed above are as follows g Kaiser Gypsum is unsure as to the intended meaning of The U.S. Government's Qualified Products List but has no knowledge that any of its wallboard joint compound products ever appeared on such a list h Kaiser Gypsum is aware of the following suppliers of chrysotile asbestos John K. Bice Harrison & Crosfield Carmonia Chemical Co. Western Chemical Co. ERB, Philip Carey Corp. Carey Canadian Asbestos ^' Manville Union Carbide Corp. E. S. Browning Loomis Chemical Co. Benson Chemical Paul W. Wood Manville Current addradedresses adsreses ses if any are not known to Kaiser Gy Gypsp um sum any Most of the specific time periods during which these firms supplied asbestos are unknown i i through iii Kaiser Gypsum is not aware of ever selli such products to shipyards power companies or refineries Kaiser 22 Gypsum sold such products to governmental customers in Norther 23 California from approximately 1952 to 1976. These customers consis 24 largely of building contractors or building materials dealers 25 Kaiser Gypsum has some retained sales orders and sales 26 invoices for some years which identify the purchasers of Kaiser 27 Gypsum products the dates of sale the amount of each product 28 sold and in some cases the sites to which the products were to 5 ^' be delivered These documents do not distinguish between sales of containing products and other products j Sales orders and sales invoices See also Response to Interrogatory b C. Decorative Texture Finishes For Interior Walls or Ceilings - Asbestos Used As A Component Drywall partitions or walls made from gypsum wallboard are sometimes decorated with wall covering or wallpaper that is fixed to the wall by an adhesive or glue On other occasions such walls are finished by painting them There are many varieties of paint 10 including some that are intended to create a textured surface 11 rather than a smooth surface Kaiser Gypsum manufactured and 12 marketed several texture paint products that during certain years 13 used chrysotile asbestos as one of numerous components Drywall 14 ceilings are sometimes finished with decorative products as are the cement slab ceilings found in some high buildings 16 Kaiser Gypsum also manufactured and marketed decorative texture texture texture texture texture texture 17 products for use on such interior ceilings that during certceartain incertain certain 18 years used chrysotile asbestos as one of numerous components 19 The Kaiser Gypsum decorative wall and ceiling texture products 20 21 were 1 Cover texture paint 22 2 Spray or Spray Cover texture paint 23 3 Kaiser texture paint 4 Covertex TSS wall texture 24 5 Spray ceiling texture 251 Kaiser Gypsum's responses to interrogatory subparts a 26 for each of these products are as follows 27 28 1 a Cover Texture Paint The trade name of this product was Cover texture paint b Kaiser Gypsum marketed Cover texture paint in 1952 but it did not manufacture the product itself Kaiser Gypsum does not know whether the product marketed in 1952 contained asbestos Kaiser Gypsum began manufacturing this product in 1953 at which time chrysotile asbestos was used as a component c Kaiser Gypsum last manufactured Cover texture paint with chrysotile asbestos as a component in 1967 when the product was discontinued d The Kaiser Gypsum California plants that made this product were located in Redwood City and Antioch These plants were in operation at different times The product was manufactured at Redwood City from 1953 through 1957 and at the Antioch plant from 1957 through 1967 Because of the heavy weight of of the product low profit margin and high transportation costs 18 distribution tended to center around the location of the 19 manufacturing plant The product consisted primarily of casein 20 limestone and mica The product included between 4.4 by weight 21 and 8.6 by weight chrysotile asbestos as a component depending 22 upon the formula in effect at a given date 23 e This product was a white to white powder It was 24 packaged and sold in sacks of 25 lbs and sacks of 50 lbs Each 25 container labeled with the name of the manufacturer Kaiser 26 Gypsum Company Inc. the name of the product and directions for 271 its use 28 f This product was a dry powder which when mixed with water formed a texture paint It was used to produce texture effects over gypsum wallboard surfaces 2 a Spray Or Spray Cover Texture Paint The trade name of this product was Spray Later it was changed to Spray Cover texture paint b Kaiser Gypsum began manufacturing this product in 1956 at which time chrysotile asbestos was used as a component c Kaiser Gypsum last manufactured Spray Cover texture paint with chrysotile asbestos as a component in 1967 when the product was discontinued d The Kaiser Gypsum California plants that made this product were located in Redwood City and Antioch These plants 14 were in operation at different times The product was 15 manufactured at Redwood City from 1956 through 1957 and at the 16 Antioch plant from 1957 through 1967 Because of the heavy weight of the product low profit margin and high transportation costs 18 distribution tended to center around the location of the 19 manufacturing plant The product consisted primarily of casein 20 limestone and mica The product included between 6.6 by weight 21 and 36.6 by weight chrysotile asbestos a component depending 22 upon the formula in effect at a given date 23 e This product was a white to white powder However 24 some colored versions of the product were offered It was 25 packaged and sold in sacks of 25 lbs and sacks of 50 lbs Each 26 container was labeled with the name of the manufacturer Kaiser 27 Gypsum Company Inc. The name of the manufacturer Kaiser Gypsum 28 Company Inc. the name of the product and directions for its use f This product was a dry powder which when mixed with water formed a texture paint that was used to produce texture effects over gypsum wallboard surfaces 3 Kaiser Texture Paint a The trade name of this product was Kaiser texture paint b Kaiser Gypsum marketed Kaiser texture paint in 1952 but it did not manufacture the product itself Kaiser Gypsum does not know whether the product manufactured in 1952 contained 10 asbestos Kaiser Gypsum began manufacturing this product in 1953 11 at which time chrysotile asbestos was used as a component | 12 c Kaiser Gypsum last manufactured Kaiser texture 13 paint with chrysotile asbestos as a component in 1967 when the paint 14 product was discontinued 15 d The Kaiser Gypsum California plants that made this product were located in Redwood City and Antioch These plants were in operation at different times The product was manufactured at Redwood City from 1953 through 1957 and at the Antioch plant from 1957 through 1967 Because of the heavy weight of the product low profit margin and high transportation costs distribution tended to center around the location of the 22 manufacturing plant The product consisted primarily of casein 23 limestone and mica The product included between 4.0 by weight 24 and 8.0 by weight chrysotile asbestos as a component depending 25 upon the formula in effect at a given date 26 e This product was a white to white powder however 27 some colored paints were sold It was packaged and sold in sacks 28 of 10 lbs and sacks of 25 lbs Each container was labeled with ) 1 the name of the manufacturer Kaiser Gypsum Company Inc. the name of the product and directions for its use f This product was a dry powder which when mixed with water formed a texture paint It was used to produce texture effects over gypsum wallboard surfaces 4 Cover Tss Wall Texture a The trade name of this product was Kaiser Gypsum Cover- Tex TSS wall texture paint b Kaiser Gypsum began manufacturing Cover Wall Texture in 1968 at which time chrysotile asbestos was used as a component c Kaiser Gypsum last manufactured Cover Wall Texture with chrysotile asbestos as a component in 1975 d The Kaiser Gypsum California plants that manufactured this product were Santa Ana and Antioch These plants were in operation Santa Ana at different times The product was manufactured at from 1968 through 1975 and at the Antioch plant from 1968 through 1975. Because of the heavy weight of the product low profit margin and high transportation costs distribution tended to center around the location of the manufacturing plant The product consisted primarily of casein limestone and mica The product included between 4.2 by weight and 8.7 by weight chrysotile asbestos as a component depending upon the formula in effect at a given date e The product was a white to white powder It was packaged and sold in 50 lb. sacks Each container was labeled with the name of the manufacturer Kaiser Gypsum Company Inc. the name of the product and directions for its use Sar W f This was a dry powder which when mixed with water formed a paint product designed for hand or spray application When dry it produced a hard durable surface It was used to produce texture effects over gypsum wallboard surfaces 5 a Spray Ceiling Texture The trade name of this product was Kaiser Gypsum Spray Ceiling Texture b Kaiser Gypsum began manufacturing Spray Ceiling Texture with chrysotile asbestos as a component in 1961 10 c Kaiser Gypsum last manufactured Spray Ceiling Texture H with chrysotile asbestos as a component in 1975 12 d The Kaiser Gypsum California plants that manufactured 13 this product were Santa Ana and Antioch These plants were in 14 operation at at different times The product was manufactured at 15 Santa Ana from 1973 through 1975 and at the Antioch plant from 16 1961 through 1971. Because of the heavy weight of the product low profit margin and high transportation costs distribution 18 tended to center around the location of the manufacturing plant 19 The product consisted primarily of casein limestone and mica 20 The product included between 1.3 by weight and 9.9 by weight chrysotile asbestos as a component depending upon the formula in effect at a given date e The product was a white powder with polystyrene aggregate It was packaged and sold in 32 lb. sacks Each 25 container was labeled with the name of the manufacturer Kaiser 26 Gypsum Company Inc. the name of the product and directions for 27 its use 28 f This was a dry powder which when mixed with water formed a paint product designed for spray application When dry it produced a hard durable surface It was used to produce texture effects over gypsum wallboard or interior concrete ceilings * * * Kaiser Gypsum's responses to interrogatory subparts g applicable to all of the five decorative texture products discussed above are as follows g Kaiser Gypsum is unsure as to the intended meaning of The U.S. Government's Qualified Products List but has no knowledge that any of its decorative texture products ever appeared on such a list h Kaiser Gypsum is aware of the following suppliers of chrysotile asbestos John K. Bice Harrison & Crosfield Carmonia Chemical Co. Western Chemical Co. Philip Carey Corp. Manville Carey Canadian Asbestos 7 Union Carbide Corp. E. S. Browning Loomis Chemical Co. Benson Chemical Paul W. Wood Manville 22 Current addresses if any are not known to Kaiser Gypsum 23 Most of the specific time periods during which these firms 24 supplied asbestos are unknown 25 i i through iii Kaiser Gypsum is not aware of ever 26 selling such products to shipyards power companies or refineries 27 Kaiser Gypsum sold such products to governmental customers in 28 Northern California from approximately 1952 to 1975. These customers consisted largely of building contractors or building materials dealers Kaiser Gypsum has some retained sales orders and sales invoices for some years which identify the purchasers of Kaiser Gypsum products the dates of sale the amount of each product sold and in some cases the sites to which the products were to be delivered These documents do not distinguish between sales of containing products and other products j Sales orders and sales invoices See also Response to 10 Interrogatory b 11 D. Electric Radiant Heat System Finishing Products - Asbestos Used As A Component In areas where electricity was expected to be particularly inexpensive some houses and apartments were constructed with electric radiant heating systems In some such radiant heating systems grooves were cut in gypsum wallboard ceilings and electrical heating cables secured in the grooves The groovecracks were then then filled and the ceiling covered with a decorative finish In other systems electric heating wires were stapled to the surface of wallboard Then the ceiling was covered with a thick decorative finish that would conceal the heating wires Kaiser Gypsum made several products for finishing such systems and these products used chrysotile asbestos as one of numerous components These Kaiser Gypsum products were 1 Filler Compound 2. Radiant Heat Compound 3. Radiant Heat Scrimless Surfacing Compound Kaiser Gypsum's responses to interrogatory subparts a for each of these products are as follows 1 a Filler Compound The trade name of this product was Kaiser Gypsum Filler Compound b Kaiser Gypsum began manufacturing Filler Compound in 1961 at which time chrysotile asbestos was used as a component c Kaiser Gypsum last manufactured Filler Compound with chrysotile asbestos as a component in 1972 when the product was discontinued d The Kaiser Gypsum California plant that made this / product was located at Antioch It manufactured Filler Compound from 1961 to 1970. Because of the heavy weight of the product the low profit margin and high transportation costs distribution tended to center around the location of the manufacturing plant The product consisted primarily of minerals including limestone and mica The product used chrysotile asbestos as a component in its formula but the amount of asbestos called for in the formula used to manufacture the product at the Antioch plant is uncertain Investigation is continuing e This product was a white to white powder It was packaged and sold in sacks of 50 lbs Each container was labeled 21 with contained the name of the manufacturer Kaiser Gypsum 22 Company Inc. the name of the product and directions for its use 231 f This product was a dry powder which when mixed with 24 water formed a thick paste Upon application it dried to a hard 25 durable surface It was used to cover radiant heating system 26 ceiling surfaces 27 28 2. a Radiant Heat Compound The trade name of this product was Kaiser Gypsum Radiant Heat Compound b Kaiser Gypsum began manufacturing this product in 1968 at which time chrysotile asbestos was used as a component c Kaiser Gypsum last manufactured Radiant Heat Compound with chrysotile asbestos as a component in 1974 when the product was discontinued d The Kaiser Gypsum California plant that made this 10 product was located in Santa Ana where it was manufactured from 11 1968 through 1974. Because of the heavy weight of the product 12 the low profit margin and high transportation costs distribution 13 tended to center around the location of the manufacturing plant 14 The The The product consisted primarily of sand and white portland cement 15 The product included between 3.3 by weight and 3.6 by weight 16 chrysotile asbestos as a component 17 e This product was a white to white powder It was 18 packaged and sold in sacks of 60 lbs Each container was labeled 19 with the name of the manufacturer Kaiser Gypsum Company Inc. 20 the name of the product and directions for its use 21 f This product was a dry powder which when mixed with 22 water formed a thick paste that was used to cover radiant heating cables stapled to ceiling surfaces 24 3 Radiant Heat Scrimless Surfacing Compound 25 a The trade name of this product was Kaiser Gypsum Radiant 26 Heat Scrimless Surfacing Compound 27 28 b Kaiser Gypsum began manufacturing this product in California in 1972 at which time chrysotile asbestos was used as a component c Kaiser Gypsum last manufactured Radiant Heat Scrimless Surfacing Compound with chrysotile asbestos as a component in 1974 when the product was discontinued d The Kaiser Gypsum California plant that made this product was located in Santa Ana where it manufactured from 1972. Because of the heavy weight of the product the low profit 10 margin and high transportation costs distribution tended to 11- center around the location of the manufacturing plant The 12 product consisted primarily of sand silica flour and mica The 13 product included % by weight chrysotile asbestos as a component 14 e This product was a greenish powder It was packaged and 15 sold in sacks of 25 lbs and in sacks of 50 lbs Each container 16 was labeled with the name of the manufacturer Kaiser Gypsum 17 Company Inc. the name of the product and directions for its use This product was a dry powder which when mixed with 19 water formed a thick paste that was used to cover radiant heating 20 cables embedded in ceiling surfaces 21 * * * 22 Kaiser Gypsum's responses to interrogatory subparts g 23 applicable to all of the three radiant heating system surfacing 24 products discussed above are as follows 25 g Kaiser Gypsum is unsure as to the intended meaning of 26 The U.S. Government's Qualified Products List but has no 27 knowledge that any of its radiant heating system surfacing 28 products ever appeared on such a list h Kaiser Gypsum is aware of the following suppliers of asbestos John K. Bice Harrison & Crosfield Carmonia Chemical Co. Western Chemical Co. Philip Carey Corp. Manville Carey Canadian Asbestos Union Carbide Corp. E. S. Browning Loomis Chemical Co. Benson Chemical Paul W. Wood Manville Current addresses if any are not known to Kaiser Gypsum Most of the specific time periods during which these firms supplied asbestos are unknown i i through iii Kaiser Gypsum is not aware of ever selling such products to shipyards power companies or refineries Kaiser Gypsum sold such products to governmental customers in Northern California from approximately 1952 to 1976. These customers consisted largely of building contractors or building materials dealers Kaiser Gypsum has some retained sales orders and sales 19 invoices for some years which identify the purchasers of Kaiser 20 Gypsum products the dates of sale the amount of each product 21 sold and in some cases the sites to which the products were to 22 be delivered These documents do not distinguish between sales of 23 containing products and other products j Sales orders and sales invoices See also Response 25 to 26 Interrogatory b 27 E. Gypsum Wallboard Accessories For 28 Exterior Use - Asbestos Used As A Component Kaiser Gypsum experimented with gypsum wallboard products for use on the exterior surfaces of buildings but those products proved unsuccessful Kaiser Gypsum never discovered a way for them to be manufactured that would allow them to effectively withstand the wide variety of weather and temperature conditions that exterior products confront Those exterior gypsum products were marketed in several test areas and as in the case of interior gypsum drywall products required the use of materials to fill the spaces between pieces of gypsum wallboard and to 10 provide a decorative finish Kaiser Gypsum offered products for 11 those purposes whose components included small percentages of 12 chrysotile asbestos These products were 13 1 Terior Premix Prefill Compound 14 2 Terior Premix Wall Texture Compound 15 Kaiser Gypsum's responses to interrogatory subparts a 16 for each of these products are as follows 1 Terior Premix Prefill Compound 17 18 a The trade name of this product was Kaiser Gypsum X- . 19 Terior Premix Prefill Compound b & c Kaiser Gypsum began and ceased marketing this 20 21 product during 1975. Chrysotile asbestos was used as a component 22 for the brief period during which this product was manufactured d The Kaiser Gypsum California plant that made this 23 product was located at Antioch The product was marketed in a 24 limited market area where exterior gypsum wallboard was being sold 25 on a test basis Kaiser Gypsum Terior Premix Prefill Compound 26 was made primarily of raw gypsum PVA emulsion and mica The 27 28 1 product included 1.5 by weight chrysotile asbestos as a component e This product was a white to white paste It was packaged and sold in metal cans and plastic buckets of 60 lbs and in cartons of 48 and 60 lbs Each container was labeled with the name of the manufacturer Kaiser Gypsum Company Inc. the name of the product and directions for its use f This product was a paste that was used to fill joints in gypsum wallboard installed on building exteriors 2. Terior Premix Wall Texture Compound a The trade name of this product was Kaiser Gypsum X- Terior Premix Wall Texture Compound b & c Kaiser Gypsum began and ceased marketing this product during 1975. Chrysotile asbesto wass used as a component for the brief period during which this product was manufactured d The Kaiser Gypsum California plant that made this product was located at Antioch The product consisted primarily of limestone acrylic emulsion and mica The product included 19 1.5 by weight chrysotile asbestos as a component 20 e The product was a white to white paste It was 21 packaged and sold in lb metal cans plastic buckets and 22 cartons Each container was labeled with the name of the 23 manufacturer Kaiser Gypsum Company Inc. the name of the product 24 and directions for its use 25 f This product was a white to white paste that was 26 used to provide surface texture to gypsum wallboard installed on 27 building exteriors 281 sold and in some cases the sites to which the products were to 2 be delivered These documents do not distinguish between sales of containing products and other products j Sales orders and sales invoices See also Response to Interrogatory b III Products Made At Kaiser Gypsum's Oregon Plant From 1956 to 1978 Kaiser Gypsum owned and operated a plant located at St. Helens Oregon whose basic capability was to make building construction products by compressing wood fibers extracted from wood chips to make various types of sheets and boards A. Firtex Products - No Asbestos Used The overwhelming majority of the products Kaiser Gypsum made at its Oregon plant were sold with the trademark Firtex No product sold under this trade name ever used asbestos as a component Firtex products included various types of materials intended to provide dampen noise Such insulation against outside temperatures or to products included sheathing that was nailed to walls before outer layers of bricks or siding were installed They also included sheet products for insulating roofs They also 21 included sound deadening board that was used in partitions to 22 reduce the noise that could be heard from adjacent rooms 23 Firtex products also included materials intended for use on 24 ceilings One type was tiles that could be glued or tacked to 25 ceilings to reduce noise Another group of such products was used 26 in suspended ceilings Suspended ceilings are made by hanging a 27 wood or metal frame from the structural members of a ceiling and 28 then laying square or rectangular decorative and insulating pieces into the frame Those pieces were termed lay boards Such suspended ceilings used a significant amount of the room's vertical space and because that vertical space cost money to build suspended ceilings were most commonly found in commercial buildings or office buildings which typically had higher ceilings than houses during the 1956-1978 period when Kaiser Gypsum made the products The Firtex line of products was quite successful : and Kaiser Gypsum sold them in great volume B. Mineral Fiber Products 1 Kaiser Gypsum Ordinary And Hour Fire Rated Mineral Fiberboard Products - No Asbestos Used As rise buildings became more common in California during the 1960's building code authorities became increasingly concerned about the risks of fires in those buildings and encouraged the development and use of products that were less likely to burn Since its Firtex chip products would burn Kaiser Gypsum sought to develop other ceiling tile and lay 18 board products that would be more resistant to fire Kaiser machinery 19 Gypsum found that the manufacturing at its St. Helens 20 Oregon plant could be used to make ceiling tiles and lay boards 21 for suspended ceilings with various types of mineral wool as the 22 principal component instead of wood chips Mineral wool is the 23 name given to products made by heating various types of rock to extremely high temperature where they melt spinning them into 24 threads and then letting them cool Mineral wool looks something 25 like steel wool that is used for rubbing rust off of metal or used 26 in certain kitchen scouring pads Mineral wool does resist fire 27 and Kaiser Gypsum was successful in developing ceiling tiles and 28 Mineral Fibreboard - U.L. Fire Rated Underwriters Laboratories Inc. Design a The trade name of this product a mineral fiber product was Kaiser Mineral Fibreboard - U.L. Fire Rated Underwriters Laboratories Inc. Design The same product was cut into ceiling tiles and lay boards for use in suspended ceilings It was used for acoustical ceiling tile and suspended lay board in 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 circumstances where a hour fire resistance classification was specified Both the ceiling tiles and the lay boards were sold under the trade name Kaiser Mineral Fibreboard Fire Rated Underwriters Laboratories Inc. design | b Kaiser Gypsum began manufacturing Mineral Fibreboard- U.L. Fire Rated with chrysotile asbestos as a component in 1963 c Kaiser Gypsum last manufactured Mineral Fibreboard Fire Rated with chrysotile asbestos as a component in 1974 when the hour rated product was discontinued d The plant that made this product was located at St. Helens Oregon This product included 1.6 by weight chrysotile chrysotile | asbestos as a component e This product consisted of ceiling tiles and lay boards with face side white or colored and with perforated or fissured design for acoustical treatment The tiles were 1/2 or 5/8 by 12 by 12 and the lay boards came in two sizes 1/2 or 5/8 by 24 by 24 and 1/2 or 5/8 by 24 by 48. They were packaged and sold in boxes of various quantities The boxes contained the name of the manufacturer Kaiser Gypsum Company Inc. the name of the product and other printed material Kaiser Gypsum's hour rated ceiling tiles and suspended ceiling hte lay board products in which chrysotile asbestos was used as a component were required to be specially marked because they looked similar to other Kaiser Gypsum mineral fiberboard ceiling tiles and lay boards that did not contain asbestos as a component and building inspectors wantetdo be able to check to make sure that products with a hour fire resistance classification actually were being used by the building contractor when those had been specified It is believed that hour fire- rated ceiling tile and suspended ceiling lay board was stamped on the back with either the initial KG or the word Kaiser Gypsum It is believed that this marking was employed during the entire period that the hour rated products were manufactured by Kaiser Gypsum g Kaiser Gypsum is unsure as to the intended meaning of The U.S. Government's Qualified Products List but has no knowledge that any of its hour rated mineral fiberboard products producptroducts s ever appeared on such a list h h Kaiser Gypsum is aware of the following suppliers of asbestos John K. Bice Harrison & Crosfield Carmonia Chemical Co. Western Chemical Co. Philip Carey Corp. Manville Carey Canadian Asbestos Union Carbide Corp. 24 E. S. Browning 25 Loomis Chemical Co. Benson Chemical 26 Paul W. Wood Manville 27 28  Current addresses if any are not known to Kaiser Gypsum Most of the specific time periods during which these firms supplied asbestos are unknown i i through iii Kaiser Gypsum is not aware of ever selling such products to shipyards power companies or refineries Kaiser Gypsum sold such products to governmental customers in California from approximately 1963 to 1974 These customers consisted largely of building contractors or building materials dealers Kaiser Gypsum has some retained sales orders and sales invoices for some years which Gypsum products the dates of identify the purchasers of Kaiser sale the amount of each product sold and in some cases the sites to which the products were to 14 be delivered These documents do not distinguish between sales of 15 containing products and other products 16 j Sales orders and sales invoices See also Response to 17 18 19 20 22 23 24 25 26 27 28 Interogatory Interrogatory b IV Types Never Of Products Kaiser Gypsum Made And Never Marketed Kaiser Gypsum has never mined milled or marketed asbestos Kaiser Kaiser Kaiser Gypsum never designed manufactured or marketed any product in which amosite crocidolite or other amphibole forms of asbestos was used as a component Kaiser Gypsum never designed manufactured or marketed floor tile pipe insulation or pipe covering refractory products boiler insulation acoustical plaster or sprayed fireproofing or sprayed thermal insulation products Kaiser Gypsum never designed manufactured or marketed any sort of brake products It never designed manufactured or marketed paper products textile products or roofing products in which asbestos was used as a component Kaiser Gypsum never had designed manufactured or marketed any products intended for use & in ships or shipyards or any products intended for use in trains or other railroad equipment or railroad facilities V. Fire Type Gypsum Wallboard - Allegedly Contaminated Vermiculite Ore This part of Kaiser Gypsum's response though not directly called for by the subject interrogatories is being made in light of earlier versions of Kaiser Gypsum's responses to these interrogatories and evolving knowledge in the context context of of 11 historical regulatory uncertainties and disputes about whether 12 vermiculite ore used as a component in some Kaiser Gypsum Null 13 Fire Type Gypsum Wallboard products may have been contaminated 14 in a way that caused certain workers to be exposed to airborne 15 asbestos Kaiser Gypsum's position is that no Kaiser Gypsum 16 Null Type Gypsum Wallboard using vermiculite ore ore ore as a 17 component could have been a substantial contributing factfactor or to any 18 disease caused by exposure to airborne asbestos fibers 19 As background in 1954 Kaiser Gypsum introduced Fire 20 brand wallboard a 5/8 thick gypsum wallboard that was approved 21 by the Research Committee of the Pacific Coast Building Officials 22 Conference and certified by the National Board of Fire Underwriters for a hour fire rating This product was 24 developed in response to the appearance of California building 25 code requirements that walls in several types of public buildings 26 must have such hour fire resistance The term hour fire 27 rating meant that when used as a wall surface the gypsum 28 Ceo y 1 wallboard would resist the passage of flame and heat for at least one hour The certified product had to be made in accordance with Underwriters Laboratories Code No. 3543. Wallboard products that that that were fire rated were labeled as Type " to distinguish them from from from ordinary gypsum wallboard products that had not passed rating tests When introduced in 1954 the primary component of Kaiser Gypsum's Fire wallboard was gypsum stucco gypsum plaster that forms the greatest percentage which is the by weight of all 10 gypsum wallboard Gypsum plaster including wallboard stucco 11 does not burn and consequently all gypsum plaster and gypsum 12 drywall construction poses less risk of fire than does wall yy 13 construction featuring wood or plastic paneling However the 14 ordinary 5/8 gypsum wallboard did not pass the hour fire 15 test because the heat of the test caused the gypsum plaster to 16 shrink and crack letting the fire through in less than an hour 17 Kaiser Gypsum found that by adding small proportions of glass 18 fiber and perlite a board could be constructed that would resist 19 shrinking and cracking under the heat of the fire test for the 20 required hour period Perlite is a very light substance white in color that looks like puffed breakfast cereal It is often used in soil for potted plants to help keep the soil from caking Perlite is made by heating little pieces of volcanic 24 glass to very high temperatures which causes them to pop like 25 popcorn 26 Kaiser Gypsum continued to market its Fire Type X 27 gypsum wallboard products that contained perlite for more than a 28 decade following their introduction in 1954 However other manufacturers introduced rated wallboard products that used vermiculite instead of perlite to provide added fire protection 3 Vermiculite is a like mineral found in the ground in a number i of places In the 1890's it was known by gold prospectors as fool's gold because it sparkled in the sun like precious metal Vermiculite does not weigh much which makes it useful as a component of construction materials and the melting point of vermiculite is about 2500 degrees which makes it valuable as fireproofing Vermiculite consists of many layers of thin plates that have small amounts of water trapped in them When heated the water turns to steam causing these plates to expand Such expanded vermiculite is used by nurseries everywhere to help hold air and moisture in plant soil so that young plants will grow faster and stronger Until 1965 Kaiser Gypsum could not use vermiculite to provide fire fire protection in gypsum wallboard because other companies had secured patents from the United States government which gave them exclusive rights to use vermiculite in their gypsum wallboard products In 1965 Kaiser Gypsum secured patent licenses from other companies which authorized Kaiser Gypsum to 22 begin with vermiculite in its wallboard products to provide 23 increased protection against fire Kaiser Gypsum then began to 24 develop such wallboard products and to present them for fire- 25 testing Since vermiculite expands when it is heated vermiculite 26 used in a wallboard tends to offset the shrinkage that occurs in 27 gypsum when it is heated and thus vermiculite could serve to 28 help a wallboard to hold its shape and provide the desired fire protection Because the capacity to expand was desired the Kaiser Gypsum products used as the ingredient vermiculite that had not previously been expanded This unexpanded vermiculite was referred to sometimes as vermiculite ore When testing and fire code authorities recognized and certified these Kaiser Gypsum products as rated or qualified to be marketed as Type X Kaiser Gypsum began marketing vermiculite gypsum wallboard under its fire brand Kaiser Gypsum manufactured limited quantities of 1/2 Fire Type X wallboard beginning in 1967 and began manufacturing 5/8 Fire Type X wallboard 11 in 1969. It continued to market such products until it disposed 12 of the last of its gypsum business in April 1978 Like other 13 wallboard products those Fire wallboards consisted 14 primarily of gypsum plaster The formulas varied over the years 15 but the vermiculite ore percentage did not exceed % by weight of | 16 the products Controversy concerning vermiculite reflects the regulatory 18 proposals published and regulations adopted by the U.S. 19 Occupational Safety and Health Administration OSHA and the 20 responses of vermiculite companies to those government actions OSHA is a U.S government agency created by federal legislation in 1970 that adopts and enforces workplace safety and health regulations OSHA has been politically controversial from the 24 beginning California originally established a parallel state 25 program administered by its Division of Occupational Safety and 26 Health but that agency and program were terminated several years 27 ago 28 1 The federal OSHA undertook to regulate exposure to asbestos in the workplace as one of its first regulatory undertakings and 3 OSHA adopted regulations on asbestos in 1972 See Kaiser Gypsum's response to Interrogatory No. 15 below Thereafter it undertook to enforce those regulations In due course it began to threaten manufacturers who used various substances other than asbestos with charges of violating the OSHA asbestos exposure regulations This triggered a lasting legal and scientific dispute concerning what minerals are asbestos for purposes of 10 the OSHA regulations and what minerals should be regulated like 11 asbestos even if they are not asbestos 12 In that context vermiculite supplier W. Grace & Co. 131 hereinafter Grace issued an Important Notice to Vermiculite 14 Ore " Processors dated March 17 1976 warning that employers of workers handling vermiculite ore should be aware of the OSHA regulations because OSHA was applying them to Grace vermiculite plants and proposed to make the regulation of dust more strict under the regulations Grace stated that the issues related to vermiculite reflected a tramp mineral found in vermiculite 20 deposits named tremolite defined by OSHA as one of the asbestos 21 family Disputes over these OSHA proposals persisted for years 22 Then on June 20 1986 OSHA published in the Federal Register at 23 51 Fed Reg 22612 a Final Rule that defined asbestos to include tremolite and applied asbestos exposure limits and 251 warnings to tremolite However shortly thereafter those 26 regulations were stayed that is not made effective by OSHA as 27 to tremolite and several other minerals to prevent the federal 28 courts from deciding whether the regulations were arbitrary and capricious See 51 Fed Reg 37002 Oct. 17 1986. The scientific and regulatory debate continued for more years until OSHA published regulations in 1992 57 Fed Reg 24310 June 8 1992 declaring that some tremolite is platy or fibrous and platy tremolite would not be deemed to be asbestos However OSHA found other tremolite was fibrous or asbestiform and that such asbestiform tremolite would be regulated as asbestos OSHA further limited these regulations by providing that even products with asbestiform tremolite would not be subject to asbestos regulation if asbestiform tremolite is present in a product in concentrations less than 1.0 percent by weight Kaiser Gypsum admits that for a limited number of years some of its Fire products contained vermiculite but Kaiser Gypsum denies that these products contained asbestiform tremolite Kaiser Gypsum further contends that any attempt under state law to deem any products that that have less than the amount that would subject them to federal regulation to be containing products would be preempted by federal law and the Supremacy Clause of the U.S. Constitution RESPONSE TO INTERROGATORY NO 11 22 Not applicable 23 RESPONSE TO INTERROGATORY NO 12 24 Kaiser Gypsum is unaware of entering into any such rebranding 25 agreements 261 RESPONSE TO INTERROGATORY NO 13 27 During 1952 Kaiser Gypsum purchased Joint Cement Cover 28 texture paint and Kaiser texture paint from Wesco Waterpaints 1 Inc. then located in Berkeley California that was packaged in Kaiser Gypsum's name It is unknown to Kaiser Gypsum whether asbestos was used as a component of those products During December 1953 after Kaiser Gypsum began manufacturing joint compounds and texture paints Kaiser Gypsum entered into an agreement with Wesco Waterpaints Inc. then located in Berkeley California to purchase joint cement topping compound and texture paint packaged in Kaiser Gypsum's name for a period of 90 days It is unknown to Kaiser Gypsum whether any purchases were made pursuant to this agreement or whether any products purchased had : asbestos as a component In an abundance of caution Kaiser Gypsum is providing the information it has obtained from its records Kaiser Gypsum has no information demonstrating that any product obtained from Wesco Waterpaints Inc. was an asbestos- containing product Kaiser Gypsum knows of no other agreement entered by it that provided for rebranding any product of another company's which may have been an containing product in Kaiser Gypsum's name for sale in California RESPONSE TO INTERROGATORY NO 14 Kaiser Gypsum did not purchase or acquire asbestos from the General Service Administration or any branch or agency of the United States Government RESPONSE TO INTERROGATORY NO 15 24 Yes as to products marketed in 1972 or thereafter 25 a Beginning in 1972 in response to regulations adopted by 26 the U.S. Occupational Safety and Health Administration see 37 27 Fed Reg 11318 June 7 1972 Kaiser Gypsum affixed caution 28 labels to the packages and containers of its containing products The OSHA regulations requiring this label were made subject to the limitation that no label is required where asbestos fibers have been modified by a bonding agent coating binder or other material so that during any reasonably foreseeable use handling storage disposal processing or transportation no airborne concentrations of asbestos in excess of the exposure limits prescribed in paragraph b of this section will be released In light of existing ambiguities as to what tests OSHA would recognize as adequate to demonstrate a product's falling within this exception Kaiser Gypsum applied the caution label to all its manufactured products in which chrysotile asbestos was used as a component Initially the labels were four inches by eight inches in size and had yellow backgrounds with red letters They were affixed to the bag or container of the product by adhesive in a prominent place Later as new bags and containers were purchased the labels were printed onto the side of the bag or container and are believed to have been the same color or colors 19 as the container or the printing thereon The label read 20 CAUTION contains asbestos fibers avoid 21 creating dust breathing asbestos dust may 22 cause serious bodily harm 231 b Beginning in 1972 exact date unknown 24 c This label caution remained the same during the 251 remaining time the products upon which it was used continued to 26 use asbestos as a component 27 RESPONSE TO INTERROGATORY NO 16 28 Not applicable RESPONSE TO INTERROGATORY NO 17 Most of Kaiser Gypsum's products were sold in the form of a powder or paste therefore name of the company was on the packaging of the product However Kaiser Gypsum's hour fire- rated ceiling tiles and suspended ceiling lay board products in which asbestos was used as a component were specially marked because they looked similar to other Kaiser Gypsum mineral fiberboard ceiling tiles and lay boards that did not contain asbestos as a component and building inspectors wanted to be able 10 to check to make sure that hour rated products actually 11 were being used by the building contractor when those had been 12 specified It is believed that each piece of hour rated 13 ceiling tile and suspended ceiling lay board was stamped on the 14 back with either the initial KG or the word Kaiser Gypsum 15 Such marking was employed during the entire period that the hour 16 rated products were manufactured by Kaiser Gypsum RESPONSE TO INTERROGATORY NO 18 18 Harlan C. Dupuis former Manager of Research and Development 19 was deposed on April 16 1985 in the following case Katherine 20 Maksim v U.S. Gypsum et al San Francisco County Superior Court 21 No. 768674 22 Melissa A. Youngman former Secretary was deposed 23 on March 4 and 5 1993 in the following cases Donald Breslin v 24 ABEX et al San Francisco County Superior Court Case No. 25 943928 Coy Cossey V. ABEX et al San Francisco County Superior 26 Court Case No. 920148 Norma E. Olsen v ABEX et al San 27 Francisco County Superior Court Case No. 914076 Lynn Weimer v 28 ABEX et al San Francisco County Superior Court Case No. 914594 and Ray Person v ABEX et al San Francisco County Superior Court Case No. 944872 Thomas V. Smith former Technical Supervisor for Accessory Products was deposed on March 11 1992 in the following case Michael F. Richie et al v Manhattan et al Superior Court of the State of California for the County of San Francisco Civ 933324 RESPONSE TO INTERROGATORY NO 19 Kaiser Gypsum has no knowledge that it ever purchased or 10 otherwise acquired an containing product line from 11 another company 12 RESPONSE TO INTERROGATORY NO 20 13 Kaiser Gypsum has retained a number of brochures pamphlets 14 catalogs and other product information documents Many of these 15 documents discuss both containing products and other products and many of the documents are similar For these 17 reasons rather than attempting to identify each individual 18 document Kaiser will Gypsum will make representative documents 19 available for inspection upon reasonable notice at the offices of of 20 Dillingham & Murphy 225 Bus 6th Floor San Francisco 21 California California California 22 a through c - See statement above d To provide potential users of such products with 24 information about the products 25 e Some of these documents still exist 26 f See above statement 27 g See Response to Interrogatory No. b 28 RESPONSE TO INTERROGATORY NO 21 Not applicable RESPONSE TO INTERROGATORY NO 22 No not to Kaiser Gypsum's knowledge RESPONSE TO INTERROGATORY NO 23 The interrogatories define contract unit to mean a branch or division of a defendant which has been or is now engaged in installation and removal of raw asbestos fibers and containing products Kaiser Gypsum never has had such 10 a unit 11 RESPONSE TO INTERROGATORY NO 24 12 Not applicable 13 RESPONSE TO INTERROGATORY NO 25 14 Kaiser Gypsum had product liability insurance during the 15 period of time it manufactured or sold containing 16 products 17 22 23 24 25 26 27 28 ei RESPONSE TO INTERROGATORY NO 26 2 a Kaiser Gypsum is insured under a number of general corporate liability insurance policies that were issued by primary insurance carriers including Truck Insurance Exchange Fireman's Fund The Home Insurance Company and National Union Insurance Company which Kaiser Gypsum maintains provide coverage for personal injury claims Certain policy terms and conditions are subject to disputes between Kaiser Gypsum and carriers Kaiser Gypsum also believes that it is insured undera number of excess liability insurance policies that were issued by a number of different insurance carriers including some that may no longer be capable of responding to their obligations The terms and conditions of these excess policies may be subject to dispute 14 Kaiser Gypsum will supplement this response in the event the 15 circumstances in a particular case may make more detailed 16 information on insurance policies of relevance taking into 17 account the carrier and dispute resolution status pertaining at that time 19 DATE 12/30/96 12/30/96 12/30/96 12/30/96 12/30/96 20 21 22 , DILLINGHAM & MURPHY By E. i aed Well Well PATRICK J. HAGAN ESQ E. JANE WELLS ESQ Attorneys for Kaiser Gypsum Defendant Company Inc. 24 25 26 27 28 I the undersigned say I have read the foregoing document to the extent that the information set forth in the foregoing document is personally known to me the information is true and correct to the best of my knowledge to the extent that the information set forth in the foregoing document is not known to me but is required by law to be provided in said responses I believe the responses to be correct to the extent that the responses state legal objections the responses 10 have been prepared by my attorneys based on their work product and other information known to them and are not within my personal knowledge 11 I declare under penalty of perjury under the laws of the State of California that 12 the foregoing is true and correct 13 Executed this > > day of DecDmber ecember . 1996 at San Ramon California 15 16 17 Kaiser Gypsum Company Inc.'s 18 Updated Responses to Plaintiffs Standard Interrogatories to 19 Defendants In Re San Francisco Superior Court 20 Complex Asbestos Litigation 21 22 23 24 25 26 27 28 Hobby Joseph R. Joseph Hobby if PROOF OF SERVICE BY C.C.P. 1013a 2015.51 I the undersigned declare That I am employed in the City of San Francisco County of San Francisco State of California that I am over the age of eighteen years and not a party to the within cause that my business address is 625 Market Street Fourteenth Floor San Francisco California 94105-3315 That on today's date I served the attached 10 KAISER GYPSUM COMPANY INC.'S UPDATED RESPONSES TO 11 PLAINTIFF'S STANDARD INTERROGATORIETSO DEFENDANTS 12 on the parties in said cause by placing a true copy of each 13 14 document enclosed ina sealed envelope with postage thereon fully 15 prepaid in the United States mail at San Francisco California 16 addressed as follows 17 Alan R. Brayton Esq 18 Brayton Harley Curtis 222 Rush Landing 19 P.O. Box 2109 20 Novato CA 96723 21 see also attached service list 22 I declare under penalty of perjury under the laws of 23 the State of California that the foregoing is true and correct 25 Dated December 30 1996 26 Chias With With Chias Chias Chias With WiWitthh Christine Willis 27 proof.mal 28 IN RE COMPLEX ASBESTOS LITIGATION PLAINTIFFS COUNSEL SERVICE LIST Bruce L. Ahnfeldt Esq P.O. Box 6078 Napa CA 94581 Law Offices of Marc C. Barulich 1721 Court Street Redding CA 96001 Brayton Harley Curtis 222 Rush Landing P.O. Box 2019 Novato CA 94948 Casey Gerry Casey Westbrook Reed & Schenk 110 Laurel Street San Diego CA 92101 Attn Frederick Schenk Law Offices of Jack K. Clapper 62 Princess Street Sausalito CA 94965 Law Offices of Frank H. Finney 2033 North Main Street Suite 430 Walnut Creek CA 94596 Law Offices Of Christopher E. Grell 685 Market Street Suite 540 San Francisco CA 94105 Visse & Yanez LLP One Daniel Burnham Court Suite 220 San Francisco CA 94109-5460 | George W. Kilboume Esq 661 Augusta Drive Moraga CA 94556 Kenneth L. Knapp Esq 1109 Quail Street Newport Beach CA 92660 w Offices of J. Kenneth Lynch One Sansome Street Suite 2100 San Francisco A 94105 McCarthy Johnson & Miller 595 Market Street Suite 2200 San Francisco CA - 94105 Law Offices of John C. Robinson 365 Notre Dame Drive Vallejo CA 94589 Robles & Gonzales One Bayfront Plaza Suite 900 100 S. Biscayne Boulevard Miami FL 33131 Steven B. Stein Esq One Embarcadero Center Suite 2112 San Francisco CA , 94111 Law Offices of Sterns Walker & Lods 100 First Street Suite 2300 San Francisco CA 94104 Wartnick Chaber Harowitz Smith & Tigerman 101 California Street Suite 2200 San Francisco CA 94111 707-224-6547 Fax 707-224-2518 916-244-0988 415-898-1555 Fax 415-898-1247 619-238-1811 Fax 619-544-9232 415-332-4262 Fax 415-331-5387 510-256-3307 Fax 510-256-3308 415-541-9866 Fax 415-541-9869 415-441-1707 Fax 415-441-0340 510-372-3304 714-851-1200 415-951-4616 Fax 415-951-4653 415-882-2992 707-554-2393 Fax 707-554-2394 305-371-5944 415-543-0152 Fax 415-626-2185 415-896-5566 Fax 415-986-5896 complxpl.Icosmplxptl.Ist IN RE COMPLEX ASBESTOS LITIGATION , Defense Counsel Service List Revised 1/16/96 oe, Adams Nye Sinunu & Walker 633 Battery St 5th Floor San Francisco 982-8955 CA 94111 Attn Barbara R. Adams Fax 982-2042 On behalf of General Plumbing Supply Co./Forderer Cornice Works Inc./Precision Auto Parts The Boister Co./Times Mirror Co./The Brose Co./Monument Car Steel Grip Inc./Ace Hardware Sears Roebuck & Co./Potter Electric Williams & Son Inc./Crossfield Products Corp./ Plumbers Specialty Co. Inc./Broadway-Webster Medical Qualitex Co. Janos Industrial Insulation Corp./The Industrial Maintenance Engineering Contracting Co. Calaveras Asbestos Janos Industrial Corp. yO . Andersen Bonnifield & Stevens 1355 Willow Way Suite 255 Concord CA 94520 ; 602-1400 Attn R.M. Bonnifield Fax 825-0143 On behalf of Patrick J. Ruane Inc.Petrochemical Insulation Inc./O.G Supply Inc./Close Building Materials Inc./Gasket Engineering & Machine Inc. Anderson Galloway & Lucchese 1676 North California Blvd. Suite 500 : 943-8383 Walnut Creek CA 94596 Attn Marty Everson Fax 943-7542 . : On behalf of Babcock & Wilcox Archer McComas Breslin McMahon & Chritton 2033 N. Main St. Suite 800 930-6600 P.O. Box 8035 Walnut Creek CA 94596 Attn Rand Chritton Fax 930-6620 On behalf of Hofmann Co./Continental Can La Habra Products Inc./Bay City Boilers & Engineering Aetna Life & Casualty Co./Bank of Canton of California Insurance Zum Piedmont Lumber Co./Ohio Casualty Carlisle Corp./Cahill Construction Co.Durant Insulated Pipe Co. Johnson Co./Victor Equipment Co./Cathedral Hill Hotel Inc./Anderson Rowe & Buckley Waldron Duffy Inc./Ireland-Robinson & Hadley Inc./Dillingham Construction NA Inc./Ross Island CA Sand & Gravel Fairfax Building Supply MacPhee Company Pipe & Supply __ Amelle Hastie McGee Willis & Greene One Market Plaza Spear Street Tower 495-4747 39th Floor San Francisco 94105-1123 Attn Otis McGee Jr. Fax 495-5123 On behalf of Eaton Corp./Crown Coach Inc./Chrysler NARMCO Inc./World Savings & Loan __._ Becherer Beers Murphy Kannett & Schweitzer 2200 Powell Street Suite 805 Emeryville CA 94608 Attn Patrick J. Becherer Fax , 658-3600 658-1151 On behalf of Chrysler Corporation Inc. Barger & Wolen 101 California Street Suite 4725 San Francisco CA 94111-5848 Fax Attn Gary A. Bresee 434-2800 434-2533 On behalf of The Equitable Life Assurance Society of the United States Law Officeosf Susan L. Benett 1550 The Alameda Suite 330 San Jose 95125 Attn Susan L. Benett Fax 287-2030 287-1303 - On behalf of United Airlines oo M. Bennett & Rowland One Embarcadero Center Suite 950 San Francisco CA 94111 956-4800 Ve . - Attn Allison D. Daniels Wessels Fax 788-5948 oe ee a On behalf of Honda North America Inc. . Bennett Samuelsen Reynolds & Allard 1951 Webster Street Suite 200 444-7688 _ _-. =. ' Oakland CA 94612-2940 Attn Richard L. Reynolds Fax 444-5849 On behalf of Dresser Industries Inc./Harbison-WalkerI/Indresco/On.C c./Harbison-Walker/Indresco/O.C McDonald Co./Slakey Brothers = ---- s+ _ 2 se Arthur Berg Attorney Woodlands O.C. McDonald Des Moines Inc. : 27 22 Paul at Law The ' 1635 Wabasso Way ~~" ~ 547-9575 -- - CA .-- -- Glendale 91208 Attn Arthur Paul Berg ~ - ~ Fax 547-0461 Rock Wool On behalf of Manufacturing Co. - - | ; Berry & Berry Station D P.O. Box 70250 1300 Clay Street 9th Floor Oakland CA 94612-0250 Attn Carolyn Collins Fax ; 873-6700 835-5117 oo Bs mm \.. od ae Designated Defense Counsel ; Francisco . Beveridge & Diamond One Sansome Street Suite 3400 San Francisco CA 4104 ~~ Fax Attn Brett P. Moffatt 397-0100 397-4238 pete rat On behalf of Webb po On Del California Corp./Miles Inc. Francisco ^' Bishop Barry Howe Haney & Ryder 275 Battery St. 12th Floor San Francisco ; 421-8550 Ss CA Nelso Neln son C. Barry ~ . oAfttn Supply Co./A.H Bennett 7=S22 On behalf PPG Industries Products & Fax 362-4730 = Co./Pacific Ship Repair 1960 F.> Bjork Lawrence Poeschi & Kohn 483 Ninth Street Oakland CA 94607 Attn Dorine P. Kohn Fax On behalf of Edwards Rockbestos Metal Products Co. Bledsoe Cathcart Diestel Livingston & Pedersen 601 California St. 16th Floor . San Francisco CA 94108 Attn Gregory L. Spallas Fax Cobb On behalf of Cincinnati Gasket Packing & Mfg Co./T.M Scherba's Auto Stores Inc. Beronio Lumber Co./ . Boornazian Jensen & Garthe 1800 Harrison St. 25th Floor 94612 Mailing P.O. Box 12925 Oakland CA 94604 Attn Robert Crow Fax On behalf of NACCO Materials Handling Group Inc. Successor to Hyster Co. Borton Petrini & Conron One Sansome St. Suite 1000 San Francisco CA 94104 Attn Richard E. Korb Fax 832-8134 832-0461 981-5411 981-0352 834-4350 839-1897 981-4415 391-5538 On behalf of Ford Whoisale Co. Inc./Throwbot Inc. - Boughey Garvie & Bushner One Post St. Suite 2400 San Francisco CA 94104 Attn Todd J. Holcomb Fax 398-4500 398-2455 On behalf of Service Engineering Co.H Ship Service Co.Matthew G. Norton Co./Southwest Marine935-30 Bowles & Verna 2121 N. California Blvd. Suite 875 P.O. Box 8180 Walnut Creek 935-3300 CA 94596 Attn Robert D. Phillips Jr. as Fax 935-0371 On behalf of Anheuser Inc./Kilpatrick's Bakeries Bradley Curley & Asiano 150 Spear St. 12th Floor San Francisco CA 94105-1535 94105-1535 Attn Ann M. Asiano Fax 442-4888 442-4884 On behalf of Power Engineering & Equipment Conductotherm Conductotherm Industries Inc. Branson FitzGerald & Howard 643 Bair Osland Rd Suite 400 P.O.P.O. Box 2189 365-7710 Redwood City CA 94064-2189 Attn Henry D. Rome Fax 364-5297 On behalf of Synkoloid Supply Co./Valley Stucco & Putty Plant Inc./Artra Group Inc. Successor to Dutch Boy Inc./Pine Cone Lumber Co. Inc. & Brobeck Phleger Harrison One Market Plaza Spear StreetTower _ 442-0900 - San Francisco CA 94105 Attn William P. Griffin Fax 442-1010 Richfield On behalf of Fibreboard Corp./Atlantic Corp./Atlantic Corp./Western MacArthur Co Brobeck Phleger & Harrison One Market Plaza Spear Street Tower 442-090042-090 San Francisco CA 94105 Attn John Carlson Fax 442-1010 On behalf of LD Brinkman Co. _ _ Brobeck Phleger & Harrison 4675 MacArthur Court Suite 1000 Newport Beach CA 92660-1846 Attn Kathlene W. Lowe Fax 752-7535 752-7522 . On behalf of Koll Real Estate Group Inc. Bronson Bronson & McKinnon 505 Montgomery St San Francisco CA 94111 986-4200 Attn Lawrence M. Cirelli Fax 982-1394 On behalf of BOC Group Inc./Airco Gas & Gear Corp./Electrical Insulation Suppliers Inc. Brown Pistone Hurley & Van Vlear 8001 Irvine Center Drive Suite 900 727-0559 . - ~.... _. .. , - Irvine CA 92718 Attn Michael K. Wolder Fax 727-0656 On behalf of Advance Mechanical Contractors Inc. 4 _ 100 Capps Staples Ward Hastings & Dodson 1777 Botelho Drive Suite _... . 939-4411 Walnut Creek CA 94596 Attn Marsha L. Fax _ Coe, 7 Do Stephenson 939-5241 On of behalf Graybar Electric Borax Inc. Carroll Burdick & McDonough 44 Montgomery St. Suite Cee eye eee ES i San Francisco 989-5900 Th. 400 .s> -- CA 94104 AttnJames B. RobertG. Miller Straus ' 2 Co./Schlage E. .. . On behalf of McDonnell Douglas Strauss & = 2 supecqeme ee Fax 989-0932 setae Lock Oscar Erickson ws. - Corp./Levi =" Ingersoll Co./J.PStevens & Co.Inc./D Zelinsky & Sons Inc./The Dial Corp./Superior BoilerWorkr s ===e === ==" Montgomery St. ae Carroll Burdick & McDonough 44 -. CA 94104 Attn Teke Kelley _.. 1... St. Suite 400SanFrancisco Fax 989-5900 Fax 989-0932 weet oo ee en a ~ On behalf of Ericsson Inc. Anaconda Carroll Burdick & McDonough 44 Montgomery St Suite 400 San Francisco 989-5900 CA 94104 Attr RobertJa. Beringer Savings -.. On behalf of St. Francis Selas Corporation of America -- Fax of America 989-0932 7} ---~---- ee ae ee CA 225-6550 Caswell Bell Hillison Bumside & Greer 5200 N. Palm Ave. Fresno 93704-2228 Krbechek . tit i rMe ail P.O. Box 5259 Fresno CA 93755-5259 Aum Randolf Fax Fax = 225-7912 EES ? On behalf of Terminal Air Brake Supply Inc. Clapp Moroney Bellagamba Lavis & Vucinich 4400 Bohannon Drive Suite 100 327-1300 Menlo Park CA 94025 Attn Christopher W. Wood . Fax 327-3707 On behalf of EV Roberts & Associates Inc./Acousta-Lite/Floorcraft/El Camino Parts Co./Claude Short _ Inc./Delmer's ' Dodge F. Atkinson Co./Keystone Consolidated Industries Boiler Sales Inc./Delmer's Brakes Wismer & Becker Contracting Engineers Brothers Inc./Cleaver Brooks A Division of Chem Pacific Mechanical Corp./Coca-Cola Co./Venton Plastering Bay Western States Stone Co. Coddington Hicks & Danforth 555 Twin Dolphin Dr. Suite 300 Redwood City 592-5400 CA 94065 Attn David Levine ; Fax 592-5027 On behalf of United Airlines Inc./Hexcel Inc./Hexcel Corp. Connor & Bishop 870 Market St. Suite 600 San Francisco CA 94102 ; Attn Charles S. Bishop On behalf of Mine Safety & Appliances Co./Wabash Power Equipment Co. Cooper White & Cooper 201 California St. 17th Floor San Francisco CA ; Attn Christopher J. Mead P. Makin Fax 94111 - Fax 434-3006 434-1445 433-1900 ' 433-5530 On behalf of California Hydronics Corporation Cooper White & Cooper 201 California St. 17th Floor San Francisco CA 94111 Attn Lawrence J. Siskind A. Meisal Fax 433-1900 433-5530 On behalf of The Kendall Company . Crosby Heafey Roach & May 1999 Harrison Street Oakland CA 94612 Attn Judie Warren ; Fax 763-2000 273-8866 Corp./AMC/Hobart On behalf of Chrysler Corp./AMC/Hobart Brothers Co./Delaval Steam Turbine Co-- MOIndustries Bridgestone Inc./Union Pacific Railroad Co.Lincoln Electric Co./F.P Lathrop Construction Co. Crosby Heafey Roach & May 1999 Harrison Street Oakland CA 94612 , 763-2000 Attn Julie Linn Fax 273-8866 On behalf of Phillips Petroleum Co./Gaylord Container Tosco Corp./Spreckels Sugar Co. Cullom & Burland 550 California St. Suite 700 San Francisco CA 94104 781-7999 Attn Freeman D. Cullom Fax 788-0335 On behalf of Crane Packaging Houdaille _ Cyril & Crowley 456 Montgomery St. 17th Floor San Francisco CA 94104 989-1100 Attn Wendy J. Hannum D. Fenske On behalf of Colberg Inc./TRW Inc./TRW Corp./Moore Resources Cyril & Crowley 456 Montgomery St. 17th Floor San Francisco CA 94104 Attn Michael W. Mark D. Skilling Fax 421-6651 Fax 989-1100 421-6651 On behalf of Pyramid Investment Transamerica Corporation Premier Insurance Co. Danaher Tedford Lagnese & Neal P.C. 700 Capitol Place 21 Oak Street 247-3666 Hartford CT 06106 . Fax 203/5471321 On behalf of Pittsburgh Corning Corporation Daniels Baratta & Fine 1801 Century Park East 9th Floor Los Angeles CA 90067 556-7900 Attn Stephanie J. Berman Fax 556-2807 On behalf of Highland Stucco & Lime Products Inc. Davidovitz & Yaron 111 Pine Street 12th Floor San Francisco CA 94111-5614 658-2929 Attn Jeffrey J. Fadeff - - ------ ~ tae +) Fax 658-2930 On behalf of Todd Mervyn's Enterprises Standard Inc./Trane Co./ - ----: ; 120 Suite _ Railroad Friction Products Corp./Colombini Construction --. - -~.- 2.50 .tecmeame cee st Smeg ~~ -Dewey Ballantin33e3 South Hope Street Los Angeles CA 90071 wn eres -213 -213 626-3399 On behalf of Championinternational Corp. 300 Santa Fax 625-0562 Dickson Carlson & Campillo Broadway 300 Santa Monica CA 90407 451-2273 __ Mailing P.O_Box P.O_Box 2122 Santa MonicCaA 90407-21A2tt2n Eric M. Zyla 451-9071 5 On behalf of R.T. Vanderbilt Pfizer Inc./American Cyanamid -- Dickson Carlson & Campillo 120 Broadway Suite 300 Santa Monica CA 90407 451-2273 -. Mailing P.O. Box 2122 Santa Monica CA 90407-21A2tt2n Roxanne M. Wilson Fax 451-9071 On behalf of Plant Insulation Company Subic Bay only Dillingham & Murphy 625 Market Street Floor San Francisco 896-0400 CA 94105-3315 Attn John Dahlberg 27 2 le ee Fax 882-4202 On behalf of AT Technologies Inc. 7720 STee we ' oo cnr. : eo eee eee spreSe ees as tt can FOR OUT ee RIM ACRN T E IEEE SOE TN ON NO eee NON RT ES TD Mee teen mY My oem ne eam | BS enter Pay Rem Dillingham & Murphy 625 Market Street 14th Floor San Francisco CA 941u Attn William K. Bissel Fax On behalf of Kaiser Cement Corp./Kaiser Gypsum Co. Inc./Gasket Specialties Inc. 896-0400 764-1970 PE Dolan Lumber Goulds Pumps Inc. Drath Clifford Murphy Wennerholm & Hagen 44 Montgomery Street Suite 1500 392-3006. San Francisco CA 94104 Attn John M. Drath Fax 391-3348 On behalf of USX Corp. Dryden Margoles Schimaneck Hartman Kelly & Wait One California St. Suite 2600 362-6715 San Francisco CA 94111 Attn Lawrence Margoles Fax 362-0638 On behalf of Figgie International Inc./Ford Inc./Ford Motor Co./Sherwin-Williams Co./Phillips Petroleum Co./ Mack Trucks Inc. O'Brien Capco Pipe Co. Inc./Jaguar Cars Duncan Ball Evans & Ubaldi 641 Fulton Avenue Second Floor Sacramento .CA 95825 Attn Jerry M. Duncan Fax 488-1666 488-1699 On behalf of Mercy San Juan Hospital Ericksen Arbuthnot Brown Kilduff & Day 530 Water St. Suite 720 Oakland CA 94607 374A6ttn William J. Hoback Fax 832-7770 832-0102 On behalf of B.F. Goodrich Co./Natkin & Co. Ericksen Arbuthnot Kilduff Day & Lindstrom Inc. 20 California Street Suite 300 , P.Sclar San Francisco CA 94111-4803 Attn Andrew Fax to On behalf of Aramark Services Inc. Successor U.S. Industrial Glove Sydney E. Fairbairn Attorney at Law Seven Mt. Lassen Drive Suite 134 San Rafael CA 94903 Attn Sydney E. Fairbairn Fax 362-7126 362-6401 Co. 479-0940 479-0940 San On behalf of H. Goldman & Sons Farella Braun & Martel 235 Montgomery St. 30th Floor Francisco CA 94104 954-4400 Attn Dennis M. Cusack T. Ryan On behalf of Shorenstein Co./Rockwell Co./Rockwell International John D. Feeney Southern Pacific Lines Law Dept. 8th Floor One Market Plaza San Francisco CA 94105 Fax 541-1000 541-1734 On behalf of Southern Pacific Transportation Co. Fenton & Keller 2801 Monterey Highway On behalf of Lorillard Tobacco Co. + CA Flynn Delich & Wise 580 California Street Suite Attn Faye Lee P.O. Box 791 Monterey 1750 San Francisco 93942 Fax 94104 _ Fax On behalf General Steamship International Ltd. Folger & Levin 275 Battery Street 23rd Floor San Francisco CA 94111 Attn Julie Matlof Fax 373-1241 373-7219 693-5566_693-56_ . 693-0410 986-2800 986-2827 On behalf of Amfac Distribution Hilton Hotels Corp. Street Francisco Christie L Fraser A Law Corporation 201 Filbert Attn Christie Fraser San CA 94133 Fax 394-8880 394-5665 On behalf of Pacific Supply Co. Inc. Fredrickson Mazeika & Grant 550 West C Street Suite 1410 San Diego 234,1722 ~ CA 92101 Attn TomaVs. Mazeika aid On On behalf of University Mechanical & Engineering Contractors : a isFreeburg Judy & Nettels 600 South Lake Avenue 2ndFloor ; Pasadena CA 91106-3955 Attn J. Lawrence Judy~ Fax 234-1759 Sie sheet es 585-4150 eee Fax 585-0718 On behalf of Flintkote Diamond _ == = Frost & Healy1930 Sonoma Blvd. VallejoCA94590 . Attn Norbert . U. Frost oe 643-5696 On On behalfof NapaGlove Co Inc. Sacramento 444-9364 ==" Gallawa Brown Kroesch & 2207 J 95816 Fax CA 95816 7 Kauffroath Street ~ a - Attn Walter Gallawa corte IndustriesWheel On of Amsted --. Chicago behalf Suite 1550 Gardiner Koch & Hines 53 West Jackson 1, Co. Blvd. IL 60604 Fax SS643-1910 =e. = SoS 7 444-5921 se meee 362-0000 Corporation | _.- Attn Torn Gardiner ae . oe On behalf of Ellis _ = Gianelli & Fores 1014 16th Street P.O.Box3212 P.O. Modesto 521-6260 oes we Robert P.Fores ee Attn Attn On behalf ofMotor On --- seer ee ee Parts Distributors _ Fax - 362-0440 CA 95353 Se _ Fax2521-5971 ioe . oN Gibson Dunn & Crutcher One Montgomery Street San Francisco CA 94104 Attn William D. Connell On behalf of Champion International Corp. Gilles Nicora Minor & Sullivan 30 Ragsdale Drive Suite 201 Monterey CA 93940 Attn Timothy J. Steven D. Penrose On behalf of Morton International Inc./Thiokol Corporation Glaspy & Glaspy 100 Pringle Avenue Suite 750 Walnut Creek CA 94596 Fax Fax Fax 393-8200 986-5309 373-5900 373-5991 947-1300 947-1594 behalf of Garlock Inc./Colt Industries Mills Fairmont Hotel Co./Sacramento Tires On Lockheed Shipbuilding Co./Tri Valley Growers Batteries & Accessories Packing 353 Sacramento St. Suite 1500 San Francisco CA 94111 398-8261 Glaspy & Glaspy Fax 398-4416 Attn Brian S. O'Malley On behalf of Morrison Knudsen Corp. Walnut Creek CA 94596 & Lange 100 Pringle Avenue Suite 600 Glynn Cella Attn James D. Luhmann _ Fax 210-2800 945-1975 On behalf of El du Pont de Nemours & Co. San Francisco CA 94111 Goldstein & Phillips One Embarcadero Center 8th Floor . On behalf of Norca Corp. Gordon & Rees 275 Battery St 20th Floor San Francisco CA 94111 - Fax 986-5900 986-8054 AOtntnbeRhiaclhfaordf DN.ebFrikaeska Boiler Co. Inc.J.W. & Sons Curtis & Western Building Materials Edwards Co./Holloway & Freeman inc San Francisco CA 94111 Gordon & Rees 275 Battery Street 20th Floor Fax 986-5900 986-8054 Attn Sara Spees On behalf of Dow Coming Corp. Gordon & Rees 275 Battery Street 20th Floor San Francisco CA 94111 Attn Michael T. Lucey Mitchell Kaplan On behalf of Bendix Allied Signal Inc. Gordon & Rees 275 Battery Street 20th Floor San Francisco CA 94111 Fax - Fax 986-5900 986-3054 986-5900 986-8054 Attn Michael T. Lucey . oo On behalf of FOSECO Inc. Gordon & Rees 275 Battery Street 20th Floor San Francisco CA 94111 Attn Jewel Kolling Basse On behalf of Union Oil of California UNOCAL Gordon & Rees 275 Battery Street 20th Floor San Francisco CA 94111 Attn Thomas C. Crosby On behalf of Triple A Machine Industrial Safety Corp. Gordon & Rees 275 Battery Street 20th Floor San Francisco CA 94111 Attn P. Gerhardt Richard D. Fike Fax 986-5900 986-5900 Fax 986-5900 986-8054 Fax 986-5900 986-8054 .90091 5700 Suite 300N Los , On behalf of Rapid American Corp. ; San Francisco CA 94111 nee - 986-5900 Gordon & Rees 275 Battery Street 20th Floor eo Fax 986-8054 oe -Attn P. Gerhardt Thomas C. Crosby ee - . On behalf of W.R. Grace ConnWilshire Angeles 487-6660 ' Grace Skocypec Cosgrove & Schirm 444 Saith Flower 11th Fl Fax 487-4896 Attn Philip R. Cosgrove |0 .90091 a On 954-0200 "7" _ behalf of General Motors Corporation 7 Graham & James One Maritime Plaza 3rd Floor SanFrancisco94111 Francisco non. - Fax * 391-2493 ' - oo. Attn Andrew I. Port . Goodyear Tire & Rubber Co./Amerada Alcoa Co--HendyInternationalInternational = On behalf of Sealift Inc./Mobil Goodyear Steamship Co./Chevron/Weyerhauser/Lykes Bros./ Matson Navigation Co./Pacific Coast Waterman Marine Service Inc./Victory Carriers 2 Crowley Maritime Co./National Bulk Mormac Transport Farrell Transport Lines Keystone Shipping Co./Delta Central Gulf Shipping Overseas Corp./OMI Bulk Management Co./ ~ Nedlloyd Lines Interocean Management Marine Inc./Pacific Dry Apex Marine ~ Standard Oil of California Coast Shipping Co./Watters - nena American President GloStboa nel&MSakriinneneDrrOinlelEimbnagrcGaudlefrMoarCienneter Suite 1350 oe 391-4200 <--->: 989-4739 Gudmundson Siggins Francisco CA 94111 Attn Richard J. Siggins Fax San On of behalf American Cyanamid - en eel em Smee eee : nl Sn ete = eae a en a Loe ea : Ne tee caren p Meeer t sateen watery Es Dee ar marr eo 9 9 Paaa : . e , Haight Brown & Bonesteel 201 Sansome St. Suite 300 San Francisco CA 9410F4ax 986-7700 986-6945 On Ob beLhiase lafLor fOCbg eCrRg Defendants Locomotive Crane Lord Corporation City Studios Inc./ San Francisco Sourdough Bakeries Inc./Tarkett Inc. 512-7100 Hake & Joyce 100 Spear Street Suite 310 San Francisco CA 94105 Fax 512-7103 Attn WilliaomfMA.voHnaPrkoe ducts Inc./Diamond Walnut Growers Inc. 10th Floor San Francisco On behalf Hancock Rothert & Bunshoft Four Embarcadero Canter Fax CA 94111 Attn James P. Barber Merton A. Howard , On behalf of Borden Inc./AmericFaonurSuEzmubkairMcoatdoerrCoorCpe.nter 10th Floor San Francisco Hancock Rothert & Bunshoft Fax - 981-5550 955-2599 . 981-5550 955-2599 CA 94111 L Attn Ray Wong Underwriters On behalf of General American Premier U5n9d5erMwarritkeertsStreet Suite 900 Hanna Brophy MacLean McAleer & Jensen . San Francisco CA 94105 Attn Neville H. McGilchrist On behalf of Manville Sales Corp Monte Foods Hardin Cook Loper Engel & Bergez 1999 Harrison St. 18th Floor Oakland - Fax CA Fax 543-9110 896-0901 444-3131 839-7940 94612 Attn Eugene Brown Jr. Auto Hartford Fire Insurance On behalf of Oak & IfndaembnictyoUnCihveemricsailtCy oofmSoputlheertn eCaliforniaCalifornia Bullard BellIndustries Hartford Accident . J.H. Fitzmaurice Inc./Kahala Hilton Mortell Company Oakland CA Hardin Cook Loper Engel & Bergez 1999 Harrison St. 18th Floor Fax 444-3131 839-7940 94612 Attn Peter A. Strotz On behalf of ICI Composites Inc.-- ICI Inc.-- ICI Americas Inc. Oakland CA - Hardin Cook Loper Engel & Bergez 1999 Harrison St. 18th Floor Fax 94612 Attn Bruce Stephen J. Valen On behalf of Poulenc Basic Chemicals Co. Stauffer Chemical Hardin Cook Loper Engel & Bergez 1999 Harrison St. 18th Floor Oakland CAFax _ 94612 Attn Bruce McLeod A. Strotz On behalf of The Dow Chemic&alBeCrogmepzanHyarrison St. 18th Floor Oakland CA Fax Hardin Cook Loper Engel , 444-3131 839-7940 444-3131 839-7940 444-3131 839-7940 94612 Attn Marshall A. Thompson On behalf of Alta Building Materials Company Sacramento 95814 Mailing P.O. Box Erich Brown & Wilson 1000 G Street Fax Hardy CA 95853-4530 Attn Brian Charter oF 13530 Sacramento Dexter Corporation Inc. On behalf of Goodyear Tire & Rubber Co.The Brett R. Harrell P.O. Box 1130 Modesto CA 95353 Fax 449-3800 449-3888 579-3717 579-3719 On behalf of E. & J. Gallo Winery 611 W. Sixth St. 30th Floor Los Angeles - - 489-3222 Harrington Foxx Dubrow & Canter , Fax 623-7929 : 90017 Attn William H. Finney Co. 4 On behalf of Ford Motor Co./Navistar International Transportation Center Suite 1800 San Francisco CA 288-9800 =~ Two .. Hassard Bonnington Embarcadero ot Fax 288-9801 M. CA 94111-3993 Attn Robert Hamblett Gateway Building Co./Golden Gateway | - . --.5 Inc./El Inc./El On behalf of Kaiser Hospitals Camino Hospital Land & Development Co./Paramount Development Assoc _____ Holding Perini ~~ Drive Suite 300 South Sacramento 925-6620 "> o> =" Stark Marois Gateway Oaks Hefner & 2710 55 EF S7 _ On behalf of Kirkhill Rubber Company 333 Bush Street San Francisco CA 94104-287894104-2878 ~ 772-6000 Heller Ehrman White & McAuliffe ~ oo On behalf of Wiegmann & Rose International Company CA 90071 620-0460 Hill Farrer & Burrill 445 South Figueroa Street 35th Floor Los Angeles Fax 624-4840 e : : _ ~~ oe _ Attn Craig J. Whitney ; _ & Santa Fe Railroad Co. TT _ of Atchison Topeka - On behalf Wade 505 Shatto Place Los Angeles CA 90020 999-4811 SE Genson Crandallee ne ten Fax 2 380-8946 Even & Angeles Fax Hill Gene Genson Attn On 7 On behalf of Uniroyal ee cent . ee ~~ Jones Hoge Fenton & Appel Inc. 60 South Market St. Suite 1400 San Jose Fax CA 95113-2396 Attn Nora Frimann On behalf of The Austin Company Rubber Manufacturing Co./Container Corp. Howarth & Smith 700 South Flower Street Suite 2900 Los Angeles CA 90017 Fax Attn Thomas F. Vandenburg , On behalf of Georgia Corporation Howrey & Simon 550 South Hope Street Suite 1400 Los Angeles CA 90071 Attn Kathryn M. Conway Fax On behalf of Mohawk Flush Doors Inc. Hudgins & Hunt 135 Main Street Suite 1350 San Francisco CA 94105 Attn Kevan T. Hunt Fax 287-8501 287-2583 OfAmerica 955-9400 622-0791 892-1800 892-2300 ; 979-0100 979-0747 On behalf of Uniroyal Inc. . Law Offices of Michael R. Hudson 500 Sansome Street Suite 601 San Francisco CA 94111 Attn Michael R. Hudson - Fax 882-1556 ~~ 986-1430 On behalf of Skinner Corporation Hyde & Holcomb 1646 North California Blvd. Suite 550 Walnut Creek CA 94596 Fax Attn Patrick J. Hyde . 939-7700 939-2248 On behalf of The Clorox Company Timothy M. Hyden Attorney at Law 18 Crow Canyon CL 380 San Ramon CA 94583 On behalf of Economy Rubber & Gasket Inc. Fax Imai Tadlock & Keeney 180 Montgomery St. Suite 1000 San Francisco CA 94104 Fax Attn Robert C. Keeney Hawkyard On behalf of A.W. Chesteron Co./George Raymond Raymond Interior Systems Imai Tadlock & Keeney 180 Montgomery St. Suite 1000 San Francisco CA 94104 831-0636 831-8483 989-8687 989-7640 ; 989-8687 Attn Theodore T. Cordery . On behalf of See's Campbell Soup Co./Simpson Paper Co./Humboldt Bay Pulp Co. Elliott Co./Rich-Tex Inc./Basic Vegetable Products River Corp./Anchor Hocking Co. Jackson Tufts Cole & Black 650 California Street San Francisco CA 94108 433-1950 Fax 392-3494 Attn Lynn A. Starr . On behalf of Fort Kent Holdings Inc. Jackson & Wallace 580 California Street 15th Floor San Francisco CA 94104 982-6300 Fax 982-6700 Attn John R. Wallace On behalf of New York Life Insurance Fluor Radiator Specialty & Associates Corp Kraft General Foods Inc./Milwhite Inc./M Slayen & Associates Supply Co./Fraser's Boiler Service The Okonite Plant Insulation Co./Armco Inc./Chicago Firebrick Co./Alfred Dunhill of London Apparatus Co./Hamon Cooling Tower Bethlehem Apparatus Zellerbach International Inc. Jaffe Trutanich Scatena & Blum 155 Sansome Street Suite 700 San Francisco 397-9006 7 Fax 397-1339 CA 94104 Attn Michelle M. Lambre , _. of City ". C. - On behalf of KSC Recovery Jedeikin Green Meadows & Schneider 300 Montgomery Street Suite 450 781-7050 San Francisco CA 94111 Attn Joseph Jedeikin Fax 421-5658 On behalf National Sunset Homes Inc./Bryan Steam Corp./E & J. Gallo Heublein Beaulieu Vineyards ae -415 CA 94105 -415 -415 543-8970 Jeffrey & Heinemann 685 Market Street Suite 330 San Francisco : Fax 543-2670 On behalf of Burnham Corporation --J:ones LaMore Brazier & Riddle 1570 The Alameda Suite 150 San Jose CA -= ==280-6800 95126-2306 James Jones ----- <5 et FaxFax 275-628.4 .-.-----. --.ee Attn 397-4600 & oa ==On=behalf of Caterpillar Inc. , 397-4600 > ~~~ "~ Jordan Keeler Seligman Two Embarcadero Center 19th Floor 397- 415 4 396 7-0 460 00 rd San Francisco CA 94111-3984 Attn David Gartshore Fax . 392-2059 a oe On behalf of Stone & Webster Engineering Corporation Kaufman & Logan 111 Pine Street Suite 1300 San Francisco CA 94111 Attn Peter J. Logan oe, Fax On behalf of First Interstate Bank _- wo 94111-3577 Attn Plaza 23rd Wheelabrator Fax Keck Mahin & Cate One Maritime Floor SanFrancisco CA 94111-3577 Fax Attn Robert E. Paterson Sa On behalf of Abex Group Inc. 392-6677 391-4639 392-7077 = 392-3965- Keesal Young & Logan Four Embarcadero Center Suite ; 1500 San Francisco 989-0616 Fax 981-7729 CA 94111 Attn Robert A. Bleicher On behalf of Lear Siegler Diversified Holdings Corp./Progresso Foods Co./Pullman Standard Inc./ Tillie Lewis Foods Inc./Tishman Realty Construction Co./The Pullman Company Burd & Markowitz Two Embarcadero Center Suite 470 San Francisco 397-3100 Kenney Fax 397-3170 CA 94111 Attn Stephen C. Kenney . On behalf of BP Chemicals Kinder Wuerfel & Cholakian 555 Montgomery St 9th Floor San Francisco CA 94111 Attn Edwin S. Nakagawa Fax On behalf of Yolland Materials Co. Kinsella Boesch Fujikawa & Towle 1901 Avenue of the Stars 7th Floor Los Angeles CA 90067 Attn Leonard M. Tavera Suite On behalf of Hannifin Corp./EIS Division Knight Boland & Riordan 88 Kearny Street Suite 1310 San Francisco CA Attn Samuel G. Ware Fax . 94104 Fax 398-1551 398-3301 . 201-2000 284-6020 - 362-0684 956-2750 On behalf of Metropolitan Life Insurance Co. . Knox Lemmon Anapolsky & Sheridan 300 Capitol Mall Suite 1170 Sacramento Fax CA 95814 Attn Susan J. Sheridan 448-9911 448-2566 On behalf of Kenworth Trucking Co. Knox Ricksen 1999 Harrison Street Suite 1700 Oakland CA 94612 . _ 893-1000 Fax 446-1946 Attn Stephen S. Harper On behalf of Combustion Engineering Oshkosh Truck Corp./Meyers Chemicals Wells Fargo Glidden Southwestern Portland Cement Lafayette Kumagai & Clarke 100 Spear St. Suite 400 San Francisco CA 94105 Fax 357-4600 896-0683 Attn Kevin M. Clarke On behalf of Procter & Gamble Coffee KMart Corporation La Follette Johnson De Haas Fesler & Ames 50 California Street 35th Floor San Francisco CA 94111 Attn Joanne Rosendin Fax 433-7610 392-7541 : On behalf of Grefco Inc.General Refractories Co. La Follette Johnson De Haas Fesler & Ames 50 California Street 35th Floor San Francisco CA 94111 Attn Kelley Reid - Fax 433-7610 392-7541 . On behalf of Gentex Corp. Landels Ripley & Diamond 350 Steuart Street San Francisco CA 94105-1250 Fax 788-5000 788-7550 Attn Morgan Gilhuly . . On behalf of J.R. Stanford University Stanford University Lane Powell Spears & Lubersky Two Embarcadero Center Suite 2330 421-8624 San Francisco CA 94111 Attn Kevin C. Mayer Fax 421-8625 Inc./Mobil Inc./Mobil On behalf of Hercules Oil Hofmann Co./Chevron/Ashland Inc. Larson & Burnham 1901 Harrison St 11th Fl Oakland 94612 Mailing P.O. Box 119 444-6800 Fax 835-6666 Oakland CA 94604 Attn Walter Rundin Shingle On behalf of D.W. Nicholson Golden Gate Drywall Inc./State Co./Jack Horton Drywall Inc./ E. McGuire & General Veneer Mfg Co./Hyatt Corp./Frank Connell & Coast Sheet Metal _. & Marine & Industrial Engineering Co./California Drywall Co./Walworth Co.Prudential Insurance Co Carter Construction Co./Daniel Smith Plastering Inc./Victor Kemp Frederick Meiswinkel 2-02 _ Whittaker Corp./Borg-Warner Corp./Mannington Hilton Hotels California Shingle & Shake Co. Goodman Lumber Co.Baker's Pride Oven Co. Great Western Medallion Carpets Corp./ Reynolds Metals 951-1100 951-1100 94111 Attn A&. BMaarrcaRbaeee Corp./Borg-Wamer Automotive ~:~ Co./WF_Hayward Co./WF_Hayward Co.Fruehauf Trailer Inc./ at PAT Ne Automotive AutomtivP e ANE Pee Co./WF_Hayward Central Supply Co. Francisco One Embarcadero Center San Francisco 951-1100 Le Bouef LambGreene <2 erL oS OAS et = Fax 951-1180 CA Lorraine S_2. , ee a |. = mn .-- On behalf of Alcoa Company Lemieux & O'Neill 200 North Westlake Blvd. Suite 100 Westlake Village CA 91362-3755 Attn Tari Cody =~ 495-4770 Fax 495-2787 On behalf of OFCCO Construction Inc. Oil Field Construction Company Inc. -. Bisgaard Lewis D'Amato Brisbois & 221 North Figueroa Street Suite 1200 a ete meee + eeeeeeen Fo Los Attn Steven Angeles CA 90012 Mark Levy Fax On behalf of American Standard Inc./Prudential Insurance 250-1800 <= 250-7900 | Sema ee SORE ee eee =SSS Liebman Reiner & Walsh 3255 Wilshire Blvd. 12th Floor Los Angeles 387-0777 CA 90010 Attn Craig Nelson - Fax 383-6754 On behalf of Riverside Cement Co. Amcord Inc. Lossing & Elston 100 First Street 25th Floor San Francisco CA 94105 Attn Kevin Gray Fax 882-4200 882-4050 On behalf of Wesson Inc. Low Ball & Lynch 601 California Street San Francisco CA 94108 Attn Celeste M. Scott Fax 981-6630 982-1634 On behalf of Beck Electric Supply Sexauer Montague Co./Groeniger & Co./Scott Company Moore Dry Dock Co./EF Mitchler Jose Drywall Corp./Atlas Heating & Ventilating Co. Ltd./ Johnson & Mape Construction Co./Douglass Insulation Co. Inc./The Branson School Co. MBL Inc./John Ray Co.Dyson Corp./Brown Sheet Metal & Mechanical Co. Darcoid Company of California Auto Supply Inc. . Lynch Loofbourrow Gilardi & Grummer 50 Francisco Street Suite 400 San Francisco CA 94133 Attn Robert V. Betette Fax 397-2800 397-0937 On behalf of C.D. Ericson Co. Inc./California State Automobile Association Materials Inc./ Wright Co. Inc./Masonite Corp./A.P Green Services Inc./American Biltrite Inc./Swinerton & Walberg Van Bokkelen Cole Co./J.C Penney Inc. Mackenroth Ryan Jacobson Fong 1610 Arden Way Suite 250 Sacramento 95815 924-1912 Mailing P.O. Box 255800 Sacramento CA 95865 Attn James , R. Wright Fax 923-3872 On behalf of Deere & Company Marron Reid & Sheehy 601 California Street Suite 1200 San Francisco CA 94108 Attn Michael Marron Fax 434-0800 986-1374 Refining Ltd. On behalf of Colonial Sugar & McCutchen Doyle Brown & Enersen Three Embarcadero Center San Francisco CA 94111 Patricia Thrash Fax 393-2000 393-2286 On behalf of Shapell Industries Inc./U.S Steel Sugar James River II Inc./Atlantic Richfield American President McKesson Catholic Healthcare West McCutchen Doyle Brown & Enersen 1331 N. California Blvd. 5th Fl Walnut Creek CA 94596 Mailing P.O. Box V Walnut Creek CA 94596 Attn Susan A. Ogdie Fax 975-5331 975-5390 On behalf of Exxon Texaco Inc./Coastal West Ventures Gypsum America Inc./ Bombardier Inc./Auburn Technology Inc. McGlynn McLorg & Ritchie 177 Steuart St. Suite 200 San Francisco CA 94105 Fax Attn Craig M. Stainbrook On behalf of Ross General Hospital Clorox Co. . McInerney & Dillon One Kaiser Plaza 18th Floor Oakland CA 94612 ; Attn Carol K. Watson Fax 543-9000 543-8300 465-7100 465-8556 On behalf of University Mechanical & Engineering Contractors , McLemore Collins & Toschi 200 Webster Street Suite 350 Oakland CA 94607 835-3400 a Attn Gregory M. Doyle Fax 835-7800 On behalf of Northwestern Equipment & Supply Co. Inc. . McNamara Houston Dodge McClure & Ney 1211 Newell Suite 202 Walnut Creek 939-5330 Mailing P.O. Box 5288 Walnut Creek CA 94596 Attn Thomas E. Pfalzer ss Fax 939-0203 . =5--- On behalf of St. Joseph's Congoleum Inc./Plibrico Sales & Service Inc./Sutter Memorial Hospital General Hospital Corp./Dameron American Terrazzo Co. -- = zo McNamara Houston Dodge McClure & Ney 1211 Newell Suite 202 Walnut Creek - 939-5330 ==Mailing P.O. Box 94596 DouglMcaCslure Fax _. 939-0203 _. =O==n of 5288 Walnut Creek CA Attn C. mo behalf Uniroyal Inc. - ~ ~~ & Mount 725 Mendes South Figueroa Street 19th Floor Los Angeles CA 90017 955-7700 on o.2 N. Attn Attn Suzanne McNulty Nelson re Fax 955-7725 On behalf of Lockheed Corp Chemicals HITCO Corp. Miller Morton Caillat & Nevis 50 W. San Fernando St. Suite 1300 San Jose 292-1765 ; On of..B.T Mancini - ~ >". CA 95113 Attn Pamela J. Silberstein . Fax- 292-4484 On behalf Co. Inc./Brookman Co. me CA 94108 391-6182 : Misciagna & Colombatto 27 MaidenLLane ane 4th Floor San Francisco Attn P. Richard Colombatto St SE te. 391-2904 = eee _... On behalf of Metalclad Insulation Co. ese ae CIT n ren RS Nem ate ene a - SS poemeia sag tnarts Ot te meee te ie Tk Ba ee me See ee ae Fey aa Mitchell Silberberg & Knupp 11377 West Olympic Boulevard Los Angeles CA 90064-1683 Attn Hayward J. Kaiser Fax 312-2000 312-3100 | On behalf of Shapco Inc. Moore & Associates One Embarcadero Center Suite 1200 San Francisco CA 94111 394-7004 Attn Robert Moore Fax 981-1592 ; On behalf of Claremont Hotel Corporation Morgenstein & Jubelirer One Market Plaza Spear Street Tower 32nd Floor San Francisco CA 94105 Attn Charles LaGrave - Fax 896-0666 896-5592 On behalf of Owens Steam & Valve Co./Cathedral Hill Hotel Inc./San Francisco Ladies Protection & Relief Pilkington Aerospace Boiler Works Inc. Morton & Lacy Three Embarcadero Center Suite 2280 San Francisco CA 94111 296-9000 Attn Alan E. Lacy Fax 398-3205 On behalf of E.H. O'Neill Co. Inc./J.E Inc./J.E Steigerwald . ; == Munger Tolles & Olson 33 New Montgomery Tower 19th Floor San Francisco CA 94105-9781 Attn M. Elizabeth Deane Fax 415512-4000 512-4077 On behalf of Tennessee Gas Pipeline Company Nicol & Isaac 4002 22nd Street San Francisco CA 94114 Attn Lisa Nicol 821-4497 On behalf of California Safety & Supply Co. . Fax 821-0791 . O'Brien & Hammond 220 Sansome St 7th Floor San Francisco CA 94104 362-2040 Attn James D. Hammond - Fax 362-1050 On behalf of LaSalle Deitch Co. Inc./Universal Foods Nabisco Brands Goodrich O'Connor Cohn Dillon & Barr 101 Howard St. 5th Floor San Francisco CA 94105 Fax Attn Mark Oium -. 281-8888 281-8890 On behalf of Federal Vallen Safety Supply Co./AlliedSignal Allied Chemical Corp./ - i Walgreen Co. Orrick Herrington & Sutcliffe 400 Sansome Street San Francisco CA 94111 Attn James R. Madison Fax On behalf of Grove Valve & Regulator Co. 941 1-3506 Otis & Hogan One Maritime Plaza Suite 1600 San Francisco CA 94111-3506 Attn J. Morrow Otis Fax On behalf of WTI Rust Holdings Rust Industrial Services Inc./Ralph M. Parsons Co. ~ Pace Drywall Legal Department P.O. Box 573 Concord CA 94522 : Fax 392-1122 773-5759 362-4442 362-7332 602-0900 . 602-0905 Pacific Bell Legal Dept. 140 New Montgomery Street Suite 1015 San Francisco CA 94105 Attn Gerard J. Donnellan = Fax Paetzold White & Brodsky 101 California St. Suite 1875 San Francisco CA 94104 Fax 542-2880 882-4458 249-0966 249-0964 Attn Cheryl Brodsky On behalf of Chiquita American President Lines Bartells.Co.Phelps Bartells.Co.Phelps Dodge Industries Todd Shipyards : Pave McCord Jacobs & Berkes 15303 Ventura Boulevard Suite 1400 Sherman Oaks CA 91403 Attn Mark W. Lau - On behalf of California Portland Cement Co./CalMat Co./Industrial Asphalt a Perkins Coie 1999 Avenue of the Stars 9th Floor Los Angeles CA 90067-6109 TTT. Attn Sibyl D. Marshall - eee Fax - Fax 783-8820 783-0959 = 788-9900 788-3399 On behalf of Custodis Inc. - Francisco Mailing =e". > Pillsbury Madison & Sutro 225 Bush St. San 94104 CA 94120 Attn Marte 38-2096 San Francisco Bassi __ Ta UT WU On ~*~ Sno: SAS San | ee Ute. P.O. Box 7880 983-1000 . CAs Fax | of On behalf Bethlehem Steel Corp. & __ Pillsbury Madison Sutro 400 Capitol Mall Suite 1700 Sacramento CA 95814 Fax -. Attn Benjamin Webster Sieglitz ve ; cs 441-0868 441-3583 : <: toon, a ~ On behalf of Aerojet General Corp. = 15239 Pittsburgh Corning Corporation 800 Presque Isle Dr. Pittsburgh PA 15239 Attn Gerald A. DeSimone toe a 733-3838 Fax 733-5849 , , ee _ __ Pond Shjeflo & Wohl 1730 S. El Camino Reat 6th OT. Attn Michael A. Fox 0 a On behalf of Thorpe Insulation Co. Wim Floor San Mateo 94402 _ . Fax ee: sone eS 341-2901 2 ce aeics 341-2258 ue eee ees crenpenmnnane ae Popelka Allard McCowan & Bondonno 160 W. Santa Clara St 12th Floor . San Jose CA 95113-1721 Attn John P. Cardosi Fax 298-6611 275-0814 On behalf of Giampolini & Company Porter Scott Weiberg & Delehant 350 University Avenue Suite 200 Sacramento CA 95865 Attn Elisa Ungerman Fax Co./ANCO 929-1481 927-3706 On behalf of Economy Lumber Co./Minton's Lumber & Supply Co./ANCO Insulations Inc. Porter Scott Weiberg & Delehant 350 University Avenue Suite 200 Sacramento 929-1481 CA 95865 Attn Craig A. Caldwell Fac 927-3706 , On behalf of Van Housen Auto Parts Pray Price Williams & Russell 555 East Ocean Boulevard Suite 810 Long Beach CA 90802-5055 Attn Bruce Bothwell Fax On behalf of Bay Cities Crane & Rigging Inc. Preuss Walker & Shanagher 595 Market St 16th Floor San Francisco CA 94105.415 94105.415 Attn Thomas W. Pulliam Jr. Fax On behalf of American Honda Motor Co. Inc./Marsh & McLennan Inc./Lac d'Amiante du 436-1231 435-6384 978-2600 ' 978-2613 Quebec Ltee : _ Segue 7 Metals ASARCO Hollingsowrth & Monsanto Co./Hobart Corp./Federated Prindle Decker & Amaro 369 Pine Street Suite 800 San Francisco CA 94104 788-8354 Attn Mary Kirk Hillyard . Fax Corp./Bode-Gravel 788-3625 On behalf of Auburn Manufacturing Co./A.B Boyd Co./Argo International Corp./Bode-Gravel Co./ Wheeler Protective Apparel Thorpe Inc./J.T Thorpe & Son Inc./Hajoca Corp Detrick Co./ Frederick Meiswinkel Inc./D Cummins Gerber Products Inc./Syd Carpenter Marine Contractors Pacific Lockheed Corp./Tri Valley Growers Enterprises Lumber Co./Feuer Corp Gangi Brothers Packing Co./Henry Vogt Machine Co./Geyser Peak Familian Southern Talc American Housing Guild Boise Cascade & Powerline Oil Co./Eternit Inc./ American Biltrite Inc./Dean's Material Inc. b Construction Material Suppliers Inc./Hayward Lumber Co. Kaiser Steel Resources Industrial Contractors Safety Co./Powerline Oil Co. Robertshaw Controls Co./Seal Methods Inc./Pillar Industries Inc.Del Webb Corporation _ Prusik Selby Daley & Swan 303 W. Madison St. Suite 1600 Chicago IL 60606 On behalf of Wheeler Protective Apparel ; Fax 553-4700 553-0332 Raifman & Edwards 131 Steuart Street Fourth Floor San Francisco CA 94105-1230 Attn Jon Logan Edwards - Fax 284-6700 284-6701 On behalf of American Crane & Equipment Corporation : - Rankin Sproat & Pollack 1800 Harrison St. Suite 1616 Oakland 94612 Mailing P.O. Box 28765 Oakland CA 94604 Attn Thomas A. Trapani . Fax 465-3922 465-3006 On behalf of Peninsula California Pacific Medical Center K. Davies Medical Center St. Mary's Hospital Luke's Hospital Muir Hospital Medical Center Bates Hospital Mt. Zion Hospital Francis Hospital Health Pacific Memorial Hospital General Hospital Reisinger & McAuley 1050 Northgate Dr. Suite One San Rafael CA 94903 Attn Jerry Williams On behalf of San Pablo Plumbing Co./Noble Auto Parts MacPhee Co Fax 499-1033 499-0329 | Rice Fowler Boath & Banning 275 Battery Street 27th Floor San Francisco 399-9191 ; a CA 94111 Attn M. Felicia Gay . te ~ On behalf of Mobil Oil Corporation Inc./MattheGw. Norton Co. Rivkin Radler & Kremer Post Office Box 14609 Santa Rosa CA 95402 . Attn Christopher A. Crevasse . ot ee -.. 576-8033 Fax 576-7955 Corp DAR On behalf of Kimberly Industrial Products Inc. 200 0 cor See Ropers Majeski Kohn & Bentley 670 Howard Street San Francisco CA 94105 =. . 543-4800 .. - Attn John Curran Ladd 2 TT OT Fax 415 512-1574 2 On behalf of The Cannery Amax Minerals Co./Calfox Inc./General American Transportation Corp./ --. SSE oe Porter Warner Industries Inc./E.V Roberts & Associates Inc./The Bank of Califomia 2 2 8 Embarcadero Center Westinghouse Electric Corp./Rome Cable Dinwiddie Construction Genuine Parts Co./Glas-Col Apparatus Co./Oakhill Improvement Oahu Sugar Lucky Prudential Insurance Company of CalifornSi afeaty & Supply San Mark H. Rosenthal Californie Francisco 94111 .-:) 986-1364 (5 . 22 California 362-1915- won nin On behalf of Crown Cork & Seal 475 California Sie 2500 Fax -415 REED = | / Rust Armenis Schwartz Lamb & Bills Post Office Box 41958 Sacramento 972-8300 ' CA 95841 Attn Duane Skelton Fax 972-7878 On behalf of Melrose Lumber Supply Lumber Co. Inc./Minton's Lumber & Supply & Company 100 Shoreline Highway Building B Suite 315 Mill Valley CA 94941 332-0550 Attn William M. Bitting Fax 332-9023 On behalf of General Brewing Co./Lucky Lager Brewing Co. . oe St. Clair McFetridge & Griffin One Montgomery St Suite 1400 San Francisco CA 94104 Attn Anthony Griffin Fax 421-2462 421-2462 On behalf of Bank of America NT & SA & St. Peter Cooper Three Embarcadero Center Suite 2900 San Francisco CA 94111 Attn Michael St. Peter Fax 955-0700 955-0711 _ : ___ On behalf of ACandS Inc. Sack and Associates 1433 Webster Street Suite 200 Oakland CA 94612 - Attn William S. Miller . Fax On behalf of Ralph M. Parsons Co./Chicago Bridge & Iron Co. Sainick & Cote 190 Newport Center Drive Suite 100 Newport Beach CA 92660 Attn Frederick B. Sainick Fax + - On behalf of San Joaquin Refining ; Samaha Grogin Stulberg 35 North Lake Avenue Suite Pasadena 91101-1856 Attn Thomas J. Samaha . ._ Fax On behalf of Hood Corporation Sarrail Lynch & Hall 44 Montgomery Street 34th Floor San Francisco CA 94104 Fax Attn Brian D. Harrison 444-6453 444-3753 644-9400 644-1142 584-1388 584-6664 _ 398-2404 391-9076 On behalf of Safeway Inc. Scadden Hamilton & Ryan 580 California St. Suite 1400 San Francisco CA 94104 362-5116 Fax 364-4214 Attn Greg Mitchell . On behalf of Supro Inc./Trans-European Motors Co./Excelsior Inc./Bank of California Dover Resources Sealol Inc./Alfred Conhagen Inc./Foster Wheeler Corp./Riley Stoker Corp./ 3 a Liberty Mutual Insurance Co./Valley Co./Valley Nitrogen Producers Tweed Co./Southern California Jobbers National Auto Parts Heinz Corp./Nestle Food Co./Durametallic Palmolive United Technologies Robertson Clayton Industries Schaffer & Lax 5757 Wilshire Blvd. Suite 600 Los Angeles CA 90036 Attn Kevin J. McNaughton Fax 934-4300 931-5680 On behalf of U.S. Mineral Products Co. Schofield & Schiller 100 Pringle Ave. Suite 510 Walnut Creek CA 94596 934-3600 Attn Carol Meyer 510-934-2257 510-934-2257 On behalf of Moore Paint Regents of the University of California Auto Parts Inc./Farmers . Underwriters Association Jones Construction Co.C.L. Peck Contractor Schuler & Kessel 3435 Wilshire Boulevard Suite 1970 Los Angeles CA 90010-1901 - 365-0924 , Attn Elizabeth M. Kessel Fax 365-0938 a On behalf of Aluma Systems mo, 4 Wyatt " Schwabe Williamson & 1211 SW Fifth Ave. Suites 1600-1950 Portland - - 222-9981 OR 97204-3795 Attn Margaret ee Fax 796-2900 er se _ ga ne omnes ow | Mills On behalf of Oregon Steel ~~ merein memes ramen _ an Sedgwick Detert Moran& Arnold One Embarcadero Center 16th Floor | _ 781-7900 San Francisco CA 94111 Attn HollyA. Harris Ceo SS De ao Fax "= 781-2635 7 - On behalf of Scandura Inc./Hen es y Inc./Hennessy Industries Inc./Ingalls Inc./Ingalls Shipbuilding Oil California - 20... ccs co Shell Oil Co./Soco-Lynch Corp./General Electric Co./Phillips Petroleum Co./Pacific Gas& Electric Co./ Chevron U.S.A. Inc./Glass Containers Corp./ConsolidatedCorp./Consolidated Insulation Electric Pacific International or feo re Sedgwick Detert Moran & Arnold 801 South Figueroa Street 18th Floor Los Angeles 426-6900 90017-5556 Attn John R. Burge Fax 426-6921 _ CA ma On Corp./Newport Shipbuilding Co./Bay behalf of & Dry om. + On Caterpillar Inc. --- - . Ce = \ Seyfarth Shaw Fairweather Geraldson 101 California Street Suite 2900 7" "~~ 397-2823 LL . . San Francisco CA 94111 Attn Peter E.Romo np Fax 5 397-8549 2 = behalf of Corp./NewCporpo./NrewptortNews & Dock Decking Inc. +=  Daniel M. Shapiro Attorney at Law 333 South Grand Ave. Suite ~ ; 90071 On behalf of Calmar Distributing Co. Inc. Shea & Gardner 1800 Massachusetts Avenue N.W. Washington Attn Laura Quinn _ 2850 Los Angeles Fax D.C. 20036 Fax 625-7400 625-0303 828-2000 828-2195 On behalf of Rockwell International . Sheppard Mullin Richter & Hampton Four Embarcadero Center 17th Floor San Francisco CA 94111 Attn Gary J. Nevolo : Fax 434-4914 434-3947 On behalf American Optical Co. Sheppard Mullin Richter & Hampton Four Embarcadero Center 17th Floor San Francisco CA 94111 Attn John F. Runkel Jr. . Fax 434-4914 434-3947 On behalf of American National Can Co. . Sidley & Austin 555 West Fifth Street Los Angeles CA 90013-1010 Attn Alan Au - Fax . 896-6000 896-6600 On behalf of Midwest Power Systems Sinclair & Hill Post Office Box 992710 Redding CA 96099-2710 Attn Craig A. Sinclair 100 e Cypress Ave. Suite 200 226-9700 Fax 226-9481 - On behalf of Mercy Medical Center Hospital of Redding Skeel Henke Evenson & Roberts 900 Fourth Avenue Suite 3801 , Seattle WA 98164 Attn Eric Richter . Fax 623-1031 628-2033 . On behalf of Olympic Steamship Co. Sorem & Pastore 2565 Camino del Rio South Suite 101 San Diego CA 92108 574-1545 Attn Joseph A. Pastore Fax 574-1200 oo On behalf of Knowles Inc. Southern Pacific Transportation Co. Law Department 10860 Gold Center Dr. Suite 410 Rancho Cordova CA 95670 Attn Michael Johnson Fax Stark Wells Rahl Schwartz & Schieffer 1999 Harrison Street Suite 1300 _ _. Oakland CA 94612 Attn May Lee Tong Fax 789-5824 789-5827 834-2200 763-5121 On behalf of Cassiar Mining Corp. Steele & Sales P.C. 700 5th Avenue Suite 5511 Seattle WA 98104 . - . Attn Katherine M. Steele Fax 682-2202 682-1224 On behalf of E.J. Bartells Co. Steefel Levitt & Weiss One Embarcadero Center Suite 2900 San Francisco CA 94111 Attn Barry W. Lee Fax _ 788-0900 788-2019 On behalf of Westbume Supply Inc./Moran Inc./Moran Plumbers Supply Sterling & Clack 101 Howard Street Suite 400 San Francisco CA 94105 Attn Rex M. Clack 543-5300 Fax 543-3335 On behalf of Olympic Steamship Co./Pope & Talbot Inc. Stevens Drummond & Gifford 1910 Olympic Bouleva, rd Suite 250 W, alnut Creek re 944-5550 S227 Burlingame -415692-9144692-9144 Ltd./ .. CA 94596 Attn David A. Gifford Fax 256-9669 On behalf of North American Refractories Co./Aetna Rubber & Asbestos Corporation Ltd./ 2 t. cn! Wagner Electric Corp Asbestos Industries Industries Inc. 00. .:. cee Stillman Attorney ijsis ooo Francis J. at Law 1601 Bayshore Highway Suite 301 - .. 415692-7492 - CA 94010 | Mailing 958S0ui4teAttn Thomas 5-6971-68211 Mailing 415 ., On behalf of Montgomery Ward &Co. | a "5" = Stumbos & Mason 2151 River Plaza Dr. 100 Sacramento CA 95833 =E= 916 P.O. Box 868 Sacramento Brad Swers-s= Fax -916 567-8212 On Co. = On behalf of Fruehauf Corp./Kelsey 670 Francisco ZUR 7 Market Street Francisco Sturgeon Keller Phillips & Gee 388 Suite 670 San 955-0800 Attn CA 94111 Brock D.Phillips D.Phillips S22SE ee ns Fax 415 955-0810 On behalf of Atchison Topeka & Santa Fe Railway Co./Burlington Northem Railroad Co. ; Tarkington O'Connor & O'Neill One Market Plaza Spear Street Tower 41st Floor 777-5501 San Francisco CA 94105 Attn Deborah Lindblom Sugar Fax - 546-4962 . De Inc./Imperial Corp. \' On behalf of Western Friction Inc./Imperial Holly Holly Sugar 523-3300 Fax ie 1. Thayer Harvey Hodder & Gregerson 1100 Fourteenth Street Suite F Modesto CA Box CA Attn CA 95353 Mail 346345 65Modesto 95353 Janet B. Hodder 22. Fax -209 = 523-3399 ~ On behalf of Roseville Telephone Company - ee = --- ut ~- -~ | aoe EEE " ae ee EE __ 9S EH Soc se t ' Sets an | - wert oe oe eee Bett ee Te civre: y: ows oe ; / Thelen Marrin Johnson & Bridges Two Embarcadero Center San Francisco 94111 94111 Attn Jennifer A. Kuenster Fax 392-6320 421-1068 On behalf of Kaiser Aerotech Aluminum & Chemical Bechtel Corp./Sequoia Ventures Inc./ Inc./Mack Inc./Mack Robert E. McKee Inc./Kaiser Center Trucks Inc./Fremont Group Inc. Thelen Marrin Johnson & Bridges 333 South Grand Avenue 34th Floor - 213621-9800 Los Angeles CA 90071 Attn Paul Lax Fax 623-4742 On behalf of M.W. Dresser Industries Inc. Thompson & Heller 400 Capitol Mall 26th Floor Sacramento CA 95814 498-7300 Attn Phillip Bonotto Fax 498-7350 Vellumoid On behalf of Vellumoid Inc./Hopeman Brothers Lakes Carbon Ticor Title Insurance Co./ . Dravo Corporation Department Stores : Suite 800 Tilly & Graves 500 Washington St. Attn Patrick O'Keefe San Francisco CA 94111 Fax 955-8925 955-8933 On behalf of Coming Fiberglas Corp. Time Oil Company P.O. Box 2447 Seattle WA 98124 Altn Ron Kokesh . Fax TIMEC Company 155 Corporate Place Vallejo CA 94590 Attn BrentA. Babow The Industrial Maintenance Engineering Co. Fax Titchell Maltzman Mark Bass Ohleyer & Mishel 650 California St. 29th Floor San Francisco CA 94108 Attn Philip B. Richard C. Insafaco oo Fax 285-2400 286-4488 642-2222 648-2719 392-5600 981-5027 On behalf of American Brass & Iron Foundry Vogl & Meredith 456 Montgomery St 20th Floor San Francisco CA 94104 . Attn Jean Yeh 398-0200 Fax 398-2820 On behalf of American Asbestos Co./Pacific Pipe San Mateo Lumber Co./Avocet Enterprises Inc./ Pacific Supply Co.W.E. Mushet Co. Walsworth Franklin Bevins & McCall 580 California Street Suite 1335 San Francisco CA 94104 Attn Robert M. Channel Fax 781-7072 391-6258 On behalf of Bishop Wholesale Inc./Friction Materials California Builders Hardware Products Pacific Holiday Towers Ltd./Hamilton Materials Battersby & Co./Daniel Smith Plastering Inc./ _ Western Water Southern California Edison Thomas Dee Engineering Quintec Industries Foundry Rite Engineering Manufacturing Inc./K.R Anderson Chemet Corp./Supreme Auto Saberhagen Holdings Inc. The Brower Carter Co./San Diego Gas & Bondex - International Building Products Madsen Co./Baltimore Ennis Land Co.MacAulay . Inc.W.W. Henry Co. Walsworth Franklin Bevins & McCall 1 City Boulevard West Suite 308 Orange CA 92668-3604 Attn Michael T. McCall 634-2522 Fax 634-0686 On behalf of Homans - White Gorman & Baker One Market Plaza Spear Street Tower 8th Floor . 541-3720 San Francisco CA 94105 Attn Margaret T. Gorman _ Fax 541-3738 On behalf of 870 Market Street Associates Brewing Co.Diana Fruit Co./American Energy . Romanski Polverari Inc./Elliott Products & Symons Corp./Big Corp./Big B Lumberteria International Inc./Structural - " _. Coating Glove Co./George Reintjes Co. Inc. see _* 9 Williams & Skelton 152 North ThirdSt. Suite 600 | 275-8262 7 Corp./Bay Corp./Bay Jose Attn Alan San CA 95112 On behalfof Epoxylite |... J. Zapala <-- ~2 sea Painting Fax 294-6707 Rubber Co./Yrueta Drywall & Painting Drywall & Painting Co. 14th Floor 2.124_= Wilson Elser Moskowitz Edelman & Dicker 650 California Street : -San Francisco CA 94108 Attn Colleen A. Peck Inc./Asbestos Products .. 433-0990 ~ .. ~. Fax 434-1370 _ On behalfof Kubota Corp./Durabla Corp./Durabla Mfg Co. Inc./Asbestos Products Mfg Corp Construction Corp./ 0 . 2 Asbestospray _ - : .. Eesti BED a _.. Law Offices ofRobert K. Wright 301 N. Lake Ave. Suite 700 Pasadena OO 796-2664 On behalf of The Budd Company Fax 796-1601 oe Wright Robinson McCammon Osthimer & Tatum 44 Montgomery St. 18th Floor 391-7111 7-7 ge, 7 7 San Francisco CA 94104 Attn Mark P. Krinsky =~ -7-S0S Fax 391-8766 ~ OSn o On behalf of San Francisco Gravel Co./J.S Guerin Co. = ae Jo. - 0 Floor = 391-7111 2 Robin Wrigs ht Ro obinn son McCammon Osth& iTamtuem r 44 Montgomery St. 18th Fax 391-8766 San Francisco CA 94104 Attn Myles E. Fladager een eee New" TTT. On behalf of Freightliner Corp. -~ -- os