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FILE NAME Synkaloid SYN DATE August 31 1984 DOC SYN006 DOCUMENT DESCRIPTION 1984 Legal - Defense response to interrogatories LAW OFFICES BRANSON FITZGERALD & HOWARD A PROFESSIONAL CORPORATION : 500 ALLERTON STREET POST OFFICE BOX 2189 CITY CALIFC OARLN II FOARNIA TELEPHONE 415 365-7710 a Attorneys forSYNKOLOID COMPANY NN _ ee . ee JKC ASBESTOS WPL BKH B___ - 5 ee SUPERIOR COURT STATE OF CALIFORNIA product CITY AND COUNTY OF SANSANFRANCISCO add list to Dougo product product ilst for IN RE SHIPYARD AND APPLICATOR CASES CLAPPER & BRAYTON CNoo nstr8u0c4t4i16on Interview Interview CONSOLIDATED FOR DISCOVERY ANSWERS OF SYNKOLOID , / COMPANY TO | INTERROGATORIES PROPOUNDED BY PLAINTIFFS 14 PROPOUNDING PARTY 15 RESPONDING PARTY 1 16 SET NUMBER : 17 PLAINTIFFS DEFENDANT SYNKOLOID COMPANY TWENTY 18 NEAL BAKER 19 20 V5 V5 V5 PPlalinatiiffntPilainftifff 21 ABEX CORPORATION et al 22 Defendants 23 24 /// No 821066 25 /// 26 /// LOUIS BLEILY Plaintiff 2 VS. 3 ABEX CORPORATION et al Defendants DIVMOLH PAN VINHORETV X 2189 719 BOX 36 VINHORETVE OFICE ALLE 415 FITZGER POST FELPHONE ALLE OFFICE FIEBSCH431 FELEPHONE FIEBESCH431 Branso FRANK BOLDUC vs. Plaintiff ABEX CORPORATION et al Defendants JAMES O. DAVIS VS. Plaintiff al ABEX CORPORATION et al , Defendants Defendants DDefeendfantes ndants vs. ASEX CORPORATION et al Defendants ROBERT EPPERSON 22 22 VS. 23 plaintif 24 25 25 804981 NO 823025 NO 799977 300999 NO 311399 ( DIVMOL DIVMOL DIVMOL DIVMOL - SHIMA g 21829189 CAREGLUNIA 710 BOX CAREGLUNIA 365 CARREGLUNIA 415 FrizGer FrizGer TELPHONE FrizGer ALLERTON FrizGer TELEPHONE Branson GUIDELY Branson Branson Branson Branson JAY WAYNE HARRIS Plaintiff VS. ABEX CORPORATION et al Defendants ELMOND JOHNSON VS. Plaintiff ABEX CORPOPATION et al Defendants PlaintifE et al Defendants JOHNNIE MEACHAM S. Plaintiff ABEN CORPORATION et al Defendants PPllaaiinnttiiffffPlaintif Plaintiff Plaintif Plaintiff Plaintiff Plaintiff Plaintif Plaintif et al Defendants NO NO 800948 NO 803139 NO 304476 HowarD 9404 & tame THE Gia 365-710 THE NOA 365-710 fi CALIFORNANae MOTHELIV 415 FitzGer m1 Aa DMOTH0ELIV m1 CITY TELTEELPEPIIKOKNEONE REDWOD Aeon TELEPIKONE REDWOOD Bhanso PENI TUFONO VS. Plaintiff ABEX CORPORATION et al Defendants CLARENCE TRULL vs. PlaintifPlaintiff , ABEX CORPORATION et al Defendants MOSES PARKER VS. Plaintif ABEX CORPORATION et al NO 818696 NO 800945 NO 802061 305014 305014 LAW OFFICES BRANSON FITZGERALD & HOWARD A PROFESSIONAL CORPORATION 500 ALLERTON STREET POST OFFICE BOX 2189 REDWOOD CITY CALIFORNIA 94064 TELEPHONE 415 365-7710 Attornefyosr SYNKOLOID COMPANY SUPERIOR COURT STATE OF CALIFORNIA COUNTY OF SOLANO IN RE CLAPPER & BRAYTON CONSOLIDATED FOR DISCOVERY SHIPYARD AND APPLICATOR ASBESTOS CASES CONSOLIDATED FOR DISCOVERY PROPOUNDING PARTY RESPONDING PARTY : SET NUMBER : PLAINTIFFS PLAINTIFFS PLAINTIFS PLAINTIFFS PLAINTIFS PLAINTIFFS PLAINTIFFS PLAINTIF S DEFENDANTS DEFENDANTS DEFENDANTS DEFENDANTS DEFENDANTS DEFENDANTS TWENTY MISC NO ANSWERS OF SYNKOLOID COMPANY TO INTERROGATORIES PROPOUNDED BY PLAINTIFFS WILLIAM BOSTIC v ABES CORPORATION et al Defendants 21 21 GEORGE COOK V. 23 23 ABEX CORPORATION et al Defendants NO 86710 85882 HOWARD PINK & " 2189 710 365 BOX VINHAFY PITZUER A TELPHONE L 415 PHOESINAL OLIEDRE VIEL Y G0 PITZUER PHOESINAL nfl TELEPHONE Branso WILEY UNDERWOOD vs. ABEX CORPORATION et al Defendants EARNEST WASHINGTON vs. ABEX CORPORATION et al Defendants JOHN O. TIMM VS. ABEX CORPORATION et al Defendants NO 85883 NO 85637 NO 85911 Defendant SYNKOLOID COMPANY herewith answers plair first set of interrogatories as follows The information provided herein is based upon information presently available to the SUNKOLOID COMPANY Since discovery and our investigation is still continu- ing this information is provided without prejudice to our present- ing at a later time or introducing into evidence information ob- tained subsequent to the date these interrogatory answers are served There are very few records available to SYNKOLOID CO COM MPP ANAY NY at the present present time due not only to its document retention destructio program but also because there have been several sales of the com- pany over the past several years and many of the company's records have either been lost or misplaced or have been transferred to indi- viduals or entities presently unknown - ANSWER TO INTERROGATORY NO 1 John P. Conroy Corporate 2 | Risk Director Artra Group 500 Central Avenue P.O. Box 8903 3 Northfield IL 60093 312 441-6650 William Reidy Artra Group | |4 Lindburgh Wong Control Chemist Synkoloid Company 5928 South Gar- , |5 field Avenue Commerce CA Frank A. Scanland Vice President a Synkoloid Company Henry D. Rome attorney for Synkoloid Company 7 t 8 ANSWER TO INTERROGATORY NO 2 Yes a The Synkoloid Company 9 b Colorado Howard 10 Howard Howard 2016 11 2016 i & | 12 | VINHOATIVO i FrTZGEI NOPELTY 415 FrTZGEI TELPHONE 13 FrTZGEI TELEPHONE 14 . ,A 10W431 Branson 100W431 i 100W431 Branson 15 . Branson Branson 16 c 5928 South Garfield Avenue Commerce CA. d Objection - this question is overbroad and requests information information which is is irrelevant as to our knowledge no kind asbestos of any kind has has been used in in any Synkoloid Synkoloid product since at least June of 1977 and probably earlier Without waiving said ob- jection the answer . is unknown with respect to the time periods that asbestos was utilized 17 e Privately 18 ANSWER TO INTERROGATORY NO 3 N. 19 20 ANSWER TO INTERROGATORY NO 4 ANSWER TO INTERROGATORY NO 5 None to our knowledge None to our knowledge 21 ANSWER TO INTERROGATORY NO : Not to our knowledge 22 ANSWER TO INTERROGATORY NO 7 Objection - overbroad and 2 irrelevant with respect to the time period after asbestos was remove 2 : 25 2 from our no products For the time period prior to that the answer 13 : 25 /// 2 3 DIVMOLI HONG HONG HONG 1 nme VINHOLLY BUZ VINHOLLY VINHOLY 5M S9396El ES VINHOLY SEAT IN^L ALESTON SEAT FITZUER FRIDRIS INDUK FRIDS |||| Branso ANSWER TO INTERROGATORY NO 8 a b c 5928 South Garfield Commerce California Frank A. Scanland Vice President No. ANSWER TO INTERROGATORY NO 9 a i through h - No. Yes - approximately between 1949 and 1977 ANSWER TO INTERROGATORY NO 10 waiving said . b Yes - between approximately 1949 c Objection - vague and ambiguous objections we believe the answer is no e Yes - between approximately 1949 and 1977 Without : and 1977 ANSWER TO INTERROGATORY NO 11 a Wall b Approximately 1949 -icr Without c August 1975 d Objection as calling for trade secret waiving said objection this product utilized 35 asbestos e Unknown except we believe that it was in powder form f Unknown except we believe it was designed to provide texture to walls g h i Unknown The Synkoloid Unknown Company j k None to our knowledge Unknown 1 We believe so i Unknown ii Unknown iii No. mA n Unknown o Yes Approximately August 1975 Synkoloid Company p all Several boxes of records pertaining to the in the possession of John Conroy Conroy Conroy with the the Artra Group in Northfield Illinois a Tex tion Without b Approximately 1949 c Approximately September 1975 d Objection as calling for trade secret informawaiving said objection this product contained approx- imately 4.89 of PF asbestos 5 6 7 8 COD 10 HOWARD 19096 1111 & 9 Alion Eti 2189 101Z 23 598 BOX VINHOATV ... SID 23 ... ...OFICE AFD FITZUE ANOKIZ 13NOMCH ......POST Be ... 15 15 Branso 16 17 17 1818 1919 2020 2121 22 22 23 2424 25 26 powder form e Unknown although it is believed this was in f We believe its purpose was to provide texture for walls g h Unknown The Synkoloid Company i Unknown j None to our knowledge ; k Unknown 1 We believe so i Unknown - ii Unknown iii No. mA n Unknown Yes Approximately August 1975 p Several boxes of records pertaining to the Synkoloid Company all in the possession of John Conroy with the Artra Group in Northfield Illinois a Triple Duty Joint Compound b Approximately 1950 c Approximately December 1975 d Objected to as calling for trade secret infor mation Without waiving said objection this product contained 3.98 02 asbestos e Unknown although we believe that that it was in powder form 5 Unknown although we believe its its purpose was prepare walls of houses g Unknown h The Synkoloid Company i Unknown j k None to our Unknown knowledge 1 we believe so i Unknown ii Unknown iii No. mA n Unknown 0 Yes - see c above SynkoloidSynkoloid Company p all Several boxes of records pertaining to the in the possession of John Conroy with the Artra Artra Group in Northfield Illinois mation Without a Synko Topping b Approximately 1950 c d Approximately July 1975 Objected to as calling for trade secret infor- waiving said objection this product contained 2 3 4 5 6 ii 7 5.98 02 asbestos e Unknown although we believe form , f Unknown although we believe repair walls of houses g Unknown h The Synkoloid Company i Unknown j k None to our knowledge Unknown - 1 We believe so i Unknown ii Unknown it was in powder its purpose was to iii No. 8 mA n Unknown 9 o Yes - see C above . Howard p Several boxes of records pertaining to the Howard 10 Synkoloid Company all in the possession of John Conroy with the Howard Artra Group in Northfield Illinois Howard SEDA 7 & >fl CALIFORNIA f 13 FitzGe FitzGe ; tion tion Without Without a Prime'X'Fill b Approximately 1960 c Approximately September 1975 trade d Objected to as calling for trade secret informa- waiving said objection this product contained FitzGe 4. 14 8 | 4.3 83 RF asbestos Branson HEDWOLERTX Branson 15 form Branson e Unknown E Unknown Branson 16 repair walls of houses although we although we believe believe it was in powder its purpose was t g Unknown 117 7 h The Synkoloid Company i Unknown 18 j None to our knowledge k Unknown 19 1 We believe so i Unknown 20 ii Unknown 222 222 23 NN iii No. mA n Unknown o Yes - see c- above p Several boxes of records pertaining to the Synkoloid Company all in the possession of John Conroy with the Artra Group in Northfield Illinois NN . " 26 a b c d Snohide Approximately 1962 Approximately October 1975 Objected to as calling for trade secret informa- Howard 94NA & FICHE STHLET 2109 CALIFORNASTHLET BOX MENSTINAL ALERTON OFER CALIFORNIA FitzGE MENESTINAL MENSTIAL Branso tion Without waiving said objection this product contained 5.988 | RF asbestos 2 form e Unknown although we believe it was in powder 3 f Unknown although we believe its purpose was to be a roof coating g Unknown h i The Synkoloid Company Unknown j k None to our knowledge Unknown 1 We believe so i Unknown ii Unknown iii No. mA n Unknown o Yes - see c above p Several boxes of records pertaining to the Synkoloid Company all in the possession of John Conroy with the Artra Group in Northfield Illinois 23 24 25 26 a Plastibond b Approximately 1950 | c Approximately February 1976 d Objected to as calling for trade secret informa- tion Without waiving said RF asbestos e Unknown Unknown objection this product contained 1.223 | although we believe it it was was in paste | form f Unknown although we believe its purpose was for texturizing and perhaps sealing walls g Unknown h The Synkoloid Company i Unknown j k None to our knowledge Unknown 1 We believe so i Unknown ii Unknown iii No. mA n Unknown o Yes - see c above p Several boxes of records pertaining to the the Synkoloid Company all in the possession of John Conroy with the Artra Group in Northfield Illinois a b c d Surface Conditioner Approximately 1950 Approximately August 1976 Objected to as calling for trade secret informa- DIVMOLI 94014 19 STREET STRET CALIFORNIA ------ B21O8X9 a 415 ALLERTON 7710 7710 365 CALIFORNIA CALIFORNIA FITZUEL TELPHONEOFICE twoja REDWOLETY ALERTON REDWOOLLETTY LIONEA 500 POSE REDWOLETY REDWOLETY Branso 17 17 gion Without waiving said RF asbestos e Unknown objection this product contained 2.24 although we believiet was provided in paste form f Unknown although we believe its purpose was to condition walls for g h i painting Unknown The Synkoloid Unknown Company j k None to our Unknown knowledge - 1 We believe so i Unknown ii Unknown iii No. mA n Unknown o Yes - see c above p Several boxes of records pertaining to the Synkoloid Company all in the possession of John Conroy with the Artra Group in Northfield Illinois - a Vinyl Prep Mix b Approximately 1962 c Approximately June 1977 d Objected to as calling for trade secret informa- tion Without waiving said objection this product contained ap- proximatly .49533 asbestos which was e Unknown although included in a 4 powder base in we believe this was provided paste form f Unknown although we believe its purpose was to repair walls of houses g Unknown h The Synkoloid Company i Unknown j None to our knowledge k Unknown 1 We believe so i Unknown ii Unknown iii No. mA n Unknown o See c above Synkoloid p Several boxes of records pertaining to the Company all in the possession of John Conroy with the Artra Group in Northfield Illinois a Patch b Approximately 1960 c Approximately August 1976 -12- 1 | tion | d Objected to as calling for trade secret informa- Without waiving said objection this product contained .92 i | RF asbestos e Unknown although we believe it was provided in | 3 paste form f Unknown although we believe its purpose was to 4 | repair walls of houses g Unknown 5 h The Synkoloid Company i Unknown 6. _ j None to our knowledge k Unknown 7 1 We believe so i Unknown 8 ii Unknown iii No. 9 mA . n Unknown 10 Howard I SKLA ll! & SKLA ' o Yes - see c above Synkoloid p Several boxes of records pertaining to the Company all in the possession of John Conroy with the Artra Group in Northfield Illinois CALIFORNIA "13, FitzGfa 13 REDWOoksULEY . REDWOoksULEY AH OEUNALU REDWOoksULEY tion a Stucco'N'Cement Patch b Approximately 1950 c Approximately August 1975 d Objected to as calling for trade secret informa- | Without waiving said objection this product contained ap- Branso | REDWOoksULEY 15 proximately .81 of e -35 asbestos Unknown although we believe this was provided 16 in powder form f Unknown although we believe its purpose was [9 17 18 f 19 patch stucco and cement g h i j k Unknown The Synkoloid Company Unknown None to our knowledge Unknown 20 1 We believe so i Unknown 21 ii Unknown iii No. 22 mA n Unknown 23 24 Synkoloid o Yes - see c above p Several boxes of records pertaining to the Company all in the possession of Conroy with with wwith iwitt h h tt he hethe Artra Group in Northfield Illinois 25 a Tex Add 26 b Approximately 1950 c Approximately December 1975 1 d Objected to as calling for trade secret informa- tion Without waiving said objection this product contained 57.143 2 35 asbestos e Unknown although we believe it was provided in 3 powder form f Unknown although we believe its purpose was to 4 | be added to paint for texture g Unknown 5 h The Synkoloid Company i Unknown 6i 7 j None to our knowledge - k Unknown 1 We believe so i Unknown 00 ii Unknown iii No. g mA HowaRD HowaRD 10 HowaRD HowaRD THAI 11 | 12 STREET CALIFORNIA CALIFORNIA | FitzGr | FitzGr ; FitzGr | Branson KEDWAGERA i KEDWAGERA Branson 15 Branson : 15 = 7 . n Unknown o Yes - see c above Synkoloid p Several boxes of records pertaining to the Company all in the possession of John Conroy with the Artra Group in Northfield Illinois tion Without a Prime'N'Seal b Approximately 1952 c Approximately August 1976 d Objected to as calling for trade secret informa waiving said objection this product contained 1.33 1.33 TF asbestos e Unknown although we believe it was provided in paste form f Unknown although we believe its purpose was to 17 prepare 18 i 19 " walls for painting g Unknown h The Synkoloid Company i Unknown j None to our knowledge k Unknown 22 ,, i 22 1 We believe so i Unknown ii Unknown iii No. 22 mA n Unknown 23 o Yes - see c above p Several boxes of records pertaining to the 24 | Synkoloid Company all in the possession of John Conroy with the i Artra Group in Northfield Illinois ; 26 a Kool b Approximately 1965 c Approximately January 1976 10 10 HYMOUL 1111 SHOR BIZZ MCHIVE1 KELZ BAIZMZ 22 CALIFORNAIWHOXOA ALEHIGU CALIFORNIA SERTINORENH 2213 aero ALEHIGU KELAWRAKERN SERTINORENH PIZU KELAWRKEN SERTINOEH aor 900 ISOA 14 14 SERTINORE NH KELAWARARKERN DRANSU 1515 16 17 18 19 20 21 22 23 24 25 26 tion Without d Objected to as calling for trade secret informawaiving said objection this product contained 4.10 RF asbestos e Unknown although we believe it was provided in paste form f Unknown although we believe its purpose was to be a roof coating g h i Unknown The Synkoloid Unknown Company j k None to our Unknown knowledge : 1 We believe so i Unknown ii Unknown iii No. mA n Unknown o Yes - see c above p Several boxes of records pertaining to the Synkoloid Company all in the possession of John Conroy with the Artra Group in Northfield Illinois a Vinyl Wall b Approximately 1972 c Approximately January 1976 d Objected to as calling for trade secret informa- ic Without waiving said objection we do not know what percentage of this product contained asbestos only that this product replaced Plastibond mentioned above e Unknown although we believe it was provided in pastpast form f Unknown although we believe its purpose was to texturize and perhaps seal walls g Unknown h The Synkoloid Company i Unknown j None to our knowledge k Unknown 1 We believe so i Unknown ii Unknown iii No. mA n Unknown ; o Yes - see c above p Several boxes of records pertaining to the John Synkoloid Company all in the possession of Artra Group in Northfield Illinois Conroy with the ANSWER TO INTERROGATORY NO 12 Unknown We believe the company distributed the products themselves with their own sales people ANSWER TO INTERROGATORY NO face to these interrogatory answers 13 As mentioned in the pre- this company has been sold on several occasions over the years and there are only several boxes of documents to our knowledge in existence pertaining to the company's period when it manufactured and sold containing products Those documents are in the custody of John Conroy with the Artra Group in Northfield Illinois 10 HOWARD 11 YOUN 13 &D mate 0Ebh KOLZ CALIFOILNIA 736105 >fl teden. VFUOJANO CALIFOLNIA 415 13 140,7 ALE FUJAO LLEY TELEPHONE FitzG liWol 409 SOU 150A TELPHONE 14 14 Ich Branso ANSWER TO INTERROGATORY NO 14 ANSWER TO INTERROGATORY NO 15 None to our knowledge None to our knowledge ANSWER TO INTERROGATORY NO 16 None known although we believe it must have been sometime in 1949 as that is when the first containing product was manufactured by this company accord- ing to the information we have ANSWER TO INTERROGATORY NO 17 Objection - this question is vague arbiguous and unintelligible Without waiving said ob- jection this defendant did purchase a type of asbestos described in response to Interrogatory No. 11 above from unknown suppliers That asbestos was utilized as indicated in our response to Interrogatory No. 11 ANSWER TO INTERROGATORY NO 18 Unknown ANSWER TO INTERROGATORY NO 19 Unknown with the exception that all products listed in our answer to identified as a powder we believe to have Interrogatory been packaged No. 11 in bags while those described as being in paste form we believe to have been pro- -16- vided in cans ANSWER TO INTERROGATORY NO 20 No. ANSWER TO INTERROGATORY NO 21 Unknown ANSWER TO INTERROGATORY NO 22 ANSWER TO INTERROGATORY NO 23 A Although we assume that Synkoloid's name was on the products it manufactured we cannot state that for a fact as we do not know ANSWER TO INTERROGATORY NO 24 - Objection assumes facts HowarD STRET & MAININ "MAININ 11 11 SHUM 612 OLZ 22 591. t^i CALIFORNA 1916 PROFESIONAL 174K 1313 ALERTONPROFESIONAL 174K CITY FitzGr 4371 PROFESINAL 500 Ind _ a A REDWO 1515 Branso 1616 17 17 18 18 19 19 2020 21 21 2222 2323 2424 not in evidence Without waiving said objection the response is unknown at the present time due to the lack of records turnover of personnel and sales of company over the past twenty years ANSWER TO INTERROGATORY NO 25 Unknown at the present time due to the lack of records turnover of personnel and sales of com- pany over the past twenty years ANSWER TO INTERROGATORY NO 26 Objection - assumes facts not in evidence Without waiving said objection unknown at the present time due to the lack of records turnover of personnel and | sales of company over the past twenty years ANSWER TO INTERROGATORY NO 27 Objection - assumes facts not in evidence Without waiving said objection unknown at the present time due to the lack of records turnover of personnel and sales of company over the past twenty years ANSWER TO INTERROGATORY NO 28 Unknown at the present time due to the lack of records turnover of personnel and sales of 25 25 company over the past twenty years 26 26 ANSWER TO INTERROGATORY NO 29 Please see response to ue Interrogatory No. 28 above 2 ANSWER TO INTERROGATORY NO 30 Same answer as set forth 3 in response to Interrogatory No. 28 above ANSWER TO INTERROGATORY NO 31 Same answer as set forth in response to Interrogatory No. 28 above 6 ANSWER TO INTERROGATORY NO 32 None to our knowledge 7 ANSWETRO INTERROGATORY NO 33 Not to our knowledge 8 ANSWER TO INTERROGATORY NO 34 Same answer as set forth 9 10 HowarD MH 1110 & 365-710 v STRET 2189 CALIFHNIA365-7710 23 MOX ALERTON OFRE CALIFHNIA 415 2323 PREKINUD ALERTON OFFRE REDWODOLY TELEPHONE FitzG PREKINUD 500 POST REDWO D OL Y TELPHONE ee REDWOLY 15 Branson 1616 in response to Interrogatory No. 28 above We do believe however that the company has belonged in the past to the National Paint and Association which may or may not have had anything to do with this subject ANSWER TO INTERROGATORY NO 35 Not to our knowledge ANSWER TO INTERROGATORY NO NO 36 Not to our knowledge ANSWER TO INTERROGATORY NO 37 Not to our knowledge ANSWER TO INTERROGATORY NO 38 Not to our knowledge 17 17 1818 1919 ANSWER TO INTERROGATORY NO 39 Same answer as set forth forth forth forth in response to Interrogatory No. 28 above ANSWER TO INTERROGATORY NO 40 Same answer as set forth 2020 in response to Interrogatory No. 28 above 2121 ANSWER TO INTERROGATORY NO 41 Same answer as set forth 2222 2323 2424 2522 2222 in response to Interrogatory No. 28 above ANSWER TO INTERROGATORY NO 42 Same answer as set forth in response to Interrogatory No. 28 above ANSWER TO INTERROGATORY NO 43 Yes ANSWER TO INTERROGATORY NO 44 To the extent that we have -10- such information the same is included on attached Exhibit A. 2 ANSWER TO INTERROGATORY NO 45 Unknown 3 ANSWER TO INTERROGATORY NO 46 Unknown A ANSWER TO INTERROGATORY NO 47 Same answer as set forth 5 in response to Interrogatory No. 23 above ANSWER TO INTERROGATORY NO 48 Same answer as set forth in response to Interrogatory No. 28 above 10 HowaRD 2.16 1 & STREET 7/10 AKAN" 2189 365 2 STRET BOX FIV.1 415 ALERTON 2 OFICE A.10 S L ALERTON FitzGF TELPHONE AFUE 500 POST 1 ATLN 15 Branso 16 217 18 19 2020 2121 222222222 222222222 22222 2 2 222222 222222222 BRANSON FITZGERALD & HOWARD Henry D. Rome By Henry D. Rome Attorneys for SYNKOLOID COMPANY -19- PROOF OF SERVICE BY MAIL - C.C.P. 51013a I the undersigned declare under penalty That I am a United States citizen over the age of ei S a party to the within cause or proceeding that my bu is 500 Allerton Street Redwood City CA 94053 that forth below I served a true copy of 7' to Plaintiffs Synkoloid Compa 8 9 HOWARD 10 8683 10 11 CALIFORN& ) ORATION OTHENT 86-716 1212 1313 FITZGEI TYNGIORUAS 6AI.0LEN0TO CITY TELPHON 1i 51ep5 BRANSO REDWO | 17 by depositing said copy in the United States mail in California in a sealed envelope postage prepaid ad Jack K. Alan R. Clapper 250 Bel Novato Clapper Esq Brayton Esq & Brayton Marin Keys Blvd. CA 94947 18 19 22222 22222 22222 22222 22222 25 26 At said time there was regular delivery of the United between said places of deposit and address Executed California on August 31 1984 = Cx Regina Feitell PROOF OF SERVICE BY MAIL - C.C.P. 51013a 2 I the undersigned declare under penalty of perjury 3 That I am a United States citizen over the age of eightee annd not 4 a party to the within cause or proceeding that my business address 5 is 500 Allerton Street Redwood City CA 94063 that on the date set 6 forth below I served a true copy of 5 to Plaintiffs Interrogatories 9 Synkoloid Company's answers HOWARD 2222 94083 2222 CALIFORN 2& CCOO..RARTAITOINON 8TRKET 86-710 2222 2222 FITZGER PROFESINAL 6AL0KH0TON CITY TELPHON 22 BRANSO REDWO 153 A | by depositing said copy California in a sealed in the United States mail envelope postage prepaid Jack K. Alan R. Clapper 250 Bel Novato Clapper Esq Brayton Esq & Brayton Marin Keys Blvd. CA 94947 in Redwood City addressed to 22 22 22 22 23 24 At said time there was regular delivery of the United States mail 25 | between said places of deposit and address Executed at Redwood Cit 26 California on August 31 1984 ( Regina Feitelberg