Document e7MRNKMbz4JDmxaV9m8Rq9x3y

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF NORTH CAROLINA IN RE: ASBESTOS-RELATED LITIGATION . ) ) ) MDCP-82-1 DEFENDANT GENERAL ELECTRIC COMPANY'S RESPONSE TO PLAINTIFFS' "SUPPLEMENTAL INTERROGATORIES TO DEFENDANTS" COMES NOW the defendant General Electric Company (hereinafter "General Electric"), and for its response to plaintiffs' "Supplemental Interrogatories to Defendants," dated June 27, 1989, states as follows: PRELIMINARY STATEMENT AND GENERAL OBJECTIONS General Electric has manufactured and continues to manufac ture a great variety of products, concentrating primarily in the area of electrical equipment for both individual consumers and industry, although General Electric's current business extends beyond manufacturing. However, General Electric is not now, nor has it ever been, a manufacturer of "asbestos-containing products" as it understands the meaning of that phrase to be, as used in the plaintiffs' "Supplemental Interrogatories to Defendants." General Electric therefore objects generally to plaintiffs' use of the term "asbestos-containing products" on the grounds that 'it makes the interrogatories overly broad, unduly burdensome, vague, ambiguous, seek irrelevant information, and not reasonably calculated to lead to the discovery of relevant, admissible or discoverable evidence. 1 PLAINTIFF'S t EXHIBIT The broad subject matter and time period addressed in plaintiffs' interrogatories make it impossible to conduct a complete search within General Electric for information necesary to answer these interrogatories. However, in good faith and in the spirit of cooperation, General Electric has responded to these interrogatories with that information presently available which General Electric deems as being potentially relevant to plaintiffs' claims. The following answers are based upon prior and on-going discussions with General Electric personnel and reviews of documents. However, various records of General Electric have from time to time been discarded in the ordinary course of business, so these responses are based upon such information as is presently reasonably available to General Electric and susceptible to retrieval through reasonable efforts. General Electric has directed these interrogatories to .employees whose present duties indicate a reasonable likelihood that they may possess pertinent, discoverable information. As this litigation relates to individuals who allege prior employ ment at Duke Power Company in the vicinity of steam turbinegenerators, the search for information and documentation to answer these interrogatories has been directed to General Electric's Turbine Business Operations in Schenectady, New York. Turbine Business Operations is the General Electric component on whose behalf these interrogatories are answered. General Electric objects to plaintiffs' interrogatories generally to the extent that plaintiffs' "Definitions and -2- Instructions" seek to impose duties upon General Electric beyond those required by the Federal Rules of Civil Procedure or to the extent that those instructions or the interrogatories seek information protected by the attorney-client privilege or attorney work product doctrine. General Electric further objects generally to plaintiffs' interrogatories to the extent that they might be considered to seek the "knowledge" of the corporate entity of General Electric on any subject. General Electric has knowledge only through its employees, and is is impossible to set forth the collective knowledge of all General Electric employees past and present. General Electric reserves the right to supplement or modify these answers to interrogatories at any time should additional information from documents or individuals require such in order to maintain! the accuracy of these responses. ' RESPONSES TO PLAINTIFFS' INTERROGATORIES interrogatory NO. 1: Did you ship any asbestos-containing products to UNITHERM, INC. at any of their North Carolina or South Carolina locations during the period from 1935 through 1980? If so, state: (a) Exact date{s) of said shipments; (b) Point of origin of each shipment; (c) Identity and quantity of products shipped; (d) Locations (addresses) to which products were shipped; . - Ni, and -3- (e) Name and position of individual who received each shipment. ANSWER: General Electric objects to Interrogatory No. 1 on the grounds that it is overly broad, unduly burdensome and harassing, seeks irrelevant information, and is not reasonably calculated to lead to the discovery of relevant, admissible or discoverable evidence. Plaintiffs have thus far made no allega tions, either through their pleadings or through discovery conducted thus far, that they were either employed by or in any way exposed to any asbestos-containing products which were shipped by General Electric to the entity identified in this interrogatory. Further, see General Electric's "Preliminary Statement and General Objections." Without waiver of these objections and subject thereto. General Electric states that it has not shipped any steam turbine-generators to the entity identified in this interrogatory. INTERROGATORY._NQ_*___2: Did you ship any asbestos-containing products to United Thermal Systems, Inc. at any of their North Carolina or South Carolina locations during the period from 1935 through 1980? If so, state: (a) Exact date(s) of said shipments; (b) Point of origin of each shipment; (c) Identity and quantity of products shipped; - (d) Locations (addresses) to which products were shipped; ' and -4- (e) Name and position of individual who received each shipment. ANSWER: General Electric objects to Interrogatory No. 2 on the same grounds stated in objection to Interrogatory No. 1. interrogatory NO. 3: Did you ship any asbestos-containing products to Vogt and Company at any of their North Carolina or South Carolina locations during the period from 1935 through 1980? If so, state: (a) Exact date(s) of said shipments? (b) Point of origin of each shipment? (c) Identity and quantity of products shipped? (d) Locations (addresses) to which products were shipped? and (e) Name and position of individual who received each shipment. * ANSWER; General Electric objects to Interrogatory No. 3 on the same grounds stated in objection to Interrogatory No. 1. interrogatory no. 4s Did you ship any asbestos-containing products to PH Sales at any of their North Carolina or South Carolina locations during the period from 1935 through 1980? If so, state: (a) Exact date(s) of said shipments? (b) Point of origin of each shipment? ' (c) Identity and quantity of products shipped? (d) Locations (addresses) to which products were shipped? and -5- (e) Name and position of individual who received each shipment. answer: General Electric objects to Interrogatory No. 4 on the same grounds stated in objection to Interrogatory No. 1, interrogatory NO. 5: Did you ship any asbestos-containing products to Porter Hayden at any of their North Carolina or South Carolina locations during the period from 1935 through 1980? If so, state: (a) Exact date(s) of said shipments; (b) Point of origin of each shipment; (c) Identity and quantity of products shipped; (d) Locations (addresses) to which products were shipped; and (e) Name and position of individual who received each shipment. * ANSWER: General Electric objects to Interrogatory No. 5 on the same grounds stated in objection to Interrogatory No. 1. INTERROGATORY NO. 6: Did you ship any asbestos-containing products to Reid Hayden at any of their North Carolina or South Carolina locations during the period from 1935 through 1980? If so, state: (a) Exact date(s) of said shipments; (b) Point of origin of each shipment; ' (c) Identity and quantity of products shipped; (d) Locations (addresses) to which products were shipped; and -6- (e) Name and position of individual who received each shipment. ANSWER: General Electric objects to Interrogatory No. 6 on the same grounds stated in objection to Interrogatory No. 1. INTERROGATORY NQ.l: Did you ship any asbestos-containing products to National Service Industries at any of their North Carolina or South Carolina locations during the period from 1935 through 1980? If so, state: (a) Exact date(s) of said shipments; (b) Point of origin of each shipment; (c) Identity and quantity of products shipped; (d) Locations (addresses) to which products were shipped; and (e) Name and position of individual who received each shipment. * ANSWER: General Electric objects to Interrogatory No. 7 on the same grounds stated in objection to Interrogatory No. 1. INTERROGATORY NO. 8: Did you ship any asbestos-containing products to North Brothers Company at any of their North Carolina or South Carolina locations during the period from 1935 through 1980? If so, state: (a) Exact date(s) of said shipments; (b) Point of origin of each shipment; * (c) Identity and quantity of products shipped; (d) Locations (addresses) to which products were shipped; and -7- (e) Name and position of individual who received each shipment. ANSWER; General Electric objects to Interrogatory No. 8 on the same grounds stated in objection to Interrogatory No. 1. interrogatory NO. 9: Did you ship any asbestos-containing products to South Insulation Company at any of their North Carolina or South Carolina locations during the period from 1935 through 1980? If so, state: (a) Exact date(s) of said shipments; (b) Point of origin of each shipment; (c) Identity and quantity of products shipped; (d) Locations (addresses) to which products were shipped; and (e) Name and position of individual who received each shipment. answer: General Electric objects to Interrogatory No. 9 on the same grounds stated in objection to Interrogatory No. 1. INTERROGATORY NO. IQ: Did you ship any asbestos-containing products to Starr Davis Co., Inc. at any of their North Carolina or South Carolina locations during the period from 1935 through 1980? If so, state: (a) Exact date(s) of said shipments; (b) Point of origin of each shipment; . (c) Identity and quantity of products shipped; ' (d) Locations (addresses) to which products were shipped; and -8- (e) Name and position of individual who received each shipment. ANSWER: General Electric objects to Interrogatory No. 10 on the same grounds stated in objection to Interrogatory No. 1. interrogatorY NO. ll: Did you ship any asbestos-containing products to Covil Insulation Co. at any of their North Carolina or South Carolina locations during the period from 1935 through 1980? If so, state: (a) Exact date(s) of said shipments; (b) Point of origin of each shipment; (c) Identity and quantity of products shipped; (d) Locations (addresses) to which products were shipped; and (e) Name and position of individual who received each shipment. answer: General Electric objects to Interrogatory No. 11 on the same grounds stated in objection to Interrogatory No. 1. interrogatory no.12: Did you ship any asbestos-containing products to Great Barrier Insulation at any of their North Carolina or South Carolina locations during the period from 1935 through 1980? If so, state: (a) Exact date(s) of said shipments; (b) Point of origin of each shipment; . (c) Identity and quantity of products shipped; (d) Locations (addresses) to which products were shipped; and -9- (e) Name and position of individual who received each shipment. ANSWER: General Electric objects to Interrogatory No. 12 on the same grounds stated in objection to Interrogatory No. 1. INTERROGATORY NO. 13i Did you ship any asbestos-containing products to Standard Insulation Co. at any of their North Carolina or South Carolina locations during the period from 1935 through 1980? If so, state: (a) Exact date(s) of said shipments; (b) Point of origin of each shipment; (c) Identity and quantity of products shipped; (d) Locations (addresses) to which products were shipped; and (e) Name and position of individual who received each shipment. * ANSWER: General Electric objects to Interrogatory No. 13 on the same grounds stated in objecction to Interrogatory No. 1. INTERROGATQRY NO. 14: Did you ship any asbestos-containing products to Bonitz Insulation Co. at any of their North Carolina or South Carolina locations during the period from 1935 through 1980? If so, state: (a) Exact date(s) of said shipments; (b) Point of origin of each shipment; . (c) Identity and quantity of products shipped; (d) Locations (addresses) to which products were shipped; and -10- (e) Name and position of individual who received each shipment. ANSWER: General Electric objects to Interrogatory No. 14 on the same grounds stated in objection to Interrogatory No. 1. INTERROGATORY NO. 15: Did you ship any asbestos-containing products to Daniel Construction Co. at any of their North Carolina or South Carolina locations during the period from 1935 through 1980? If so, state: (a) Exact date(s) of said shipments; (b) Point of origin of each shipment; (c) Identity and quantity of products shipped; (d) Locations (addresses) to which products were shipped; and (e) Name and position of individual who received each shipment. f ANSWER: General Electric objects to Interrogatory No. 15 on the same grounds stated in objection to Interrogatory No. 1. INTERROGATORY NO. 16: Did you ship any asbestos-containing products to Mill-Power Supply Co. at any of their North Carolina or South Carolina locations during the period from 1935 through 1980? If so, state: (a) Exact date(s) of said shipments; (b) Point of origin of each shipment; - (c) Identity and quantity of products shipped; (d) Locations (addresses) to which products were shipped; and -11- (e) Name and position of individual who received each shipment. answer: General Electric objects to Interrogatory No. 16 on the grounds that it is overly broad and unduly burdensome, and on the grounds stated in its "Preliminary Statement and General Objections." Without waiver of these objections and subject thereto, General Electric states that from time to time in the past, it has done business with Mill-Power Supply Co., it its capacity as the purchasing agent for Duke Power Company, in connection with General Electric's sales to Duke Power Company of steam turbine-generators, and General Electric's service of that equipment. Additionally, see General Electric's response to Interrogatory No. 29. interrogatory NO. 17: Did you ship any asbestos-containing products to Findley Insulation Co. at any of their North Carolina or South Carolina locations during the period from 1935 through 1980? If so, state: (a) Exact date(s) of said shipments; (b) Point of origin of each shipment; (c) Identity and quantity of products shipped; (d) Locations (addresses) to which products were shipped; and (e) Name and position of individual who received each - shipment. ' ANSWER: General Electric objects to Interrogatory No. 17 on the same grounds stated in objection to Interrogatory No. 1. -12- INTERROGATORY NO. 18: Did you ship any asbestos-containing products to Guy M. Beaty Company at any of their North Carolina or South Carolina locations during the period from 1935 through 1980? If so, state: (a) Exact date(s) of said shipments; (b) Point of origin of each shipment; (c) Identity and quantity of products shipped; (d) Locations (addresses) to which products were shipped; and (e) Name and position of individual who received each shipment. answert General Electric objects to Interrogatory No. 18 on the same grounds stated in objection to Interrogatory No. 1. interrogatory NO. 19: Did you ship any asbestos-containing products to Babcock & Wilcox at any of their North Carolina or outh Carolina locations during the period from 1935 through 1980? If so, state: (a) Exact date(s) of said shipments; (b) Point of origin of each shipment; (c) Identity and quantity of products shipped; (d) Locations (addresses) to which products were shipped; and (e) Name and position of individual who received each . shipment. ANSWER: General Electric objects to Interrogatory No. 19 on the same grounds stated in objection to Interrogatory No. 1. -13- INTERROGATORY NO. 20: Did you ship any asbestos-containing products to Flakt Inc. at any of their North Carolina or South Carolina locations during the period from 1935 through 1980? If so, state: (a) Exact date(s) of said shipments; (b) Point of origin of each shipment; (c) Identity and quantity of products shipped; (d) Locations (addresses) to which products were shipped; - and (e) Name and position of individual who received each shipment. answeri General Electric objects to Interrogatory No. 20 on the same grounds stated in objection to Interrogatory No. 1. interrogatory NO. 21s Did you ship any asbestos-containing products to Envirotech Corp. at any of their North Carolina or outh Carolina locations during the period from 1935 through 1980? If so, state: (a) Exact date(s) of said shipments; (b) Point of origin of each shipment; (c) Identity and quantity of products shipped; (d) Locations (addresses) to which products were shipped; and (e) Name and position of individual who received each . shipment. ANSWER: General Electric objects to Interrogatory No. 21 on the same grounds stated in objection to Interrogatory No. 1. -14- INTERROGATORY NO. 22s Did you ship any asbestos-containing products to Bahnson Co. at any of their North Carolina or South Carolina locations during the period from 1935 through 1980? If so, state: (a) Exact date(s) of said shipments; (b) Point of origin of each shipment; (c) Identity and quantity of products shipped; (d) Locations (addresses) to which products were shipped; and (e) Name and position of individual who received each shipment. answer: General Electric objects to Interrogatory No. 22 on the same grounds stated in objection to Interrogatory No. 1. INTERROGATORY NO. 23: Did you ship any asbestos-containing products to Sanders Brothers, Inc. at any of their North Carolina or South Carolina locations during the period from 1935 through 1980? If so, state: (a) Exact date(s) of said shipments; (b) Point of origin of each shipment; (c) Identity and quantity of products shipped; (d) Locations (addresses) to which products were shipped; and (e) Name and position of individual who received each . shipment. ANSWER; General Electric objects to Interrogatory No. 23 on the same grounds stated in objection to Interrogatory No. 1. -15- INTERROGATORY NO. 24: Did you ship any asbestos-containing products to Teachey Mechanical, Inc. at any of their North Carolina or South Carolina locations during the period from 1935 through 1980? If so, state: (a) Exact date(s) of said shipments; (b) Point of origin of each shipment; (c) Identity and quantity of products shipped; (d) Locations (addresses) to which products were shipped; and (e) Name and position of individual who received each shipment. answer: General Electric objects to Interrogatory No. 24 on the same grounds stated in objection to Interrogatory No. 1. interrogatory NO. 25: Did you ship any asbestos-containing products to Flame Refractories, Inc. at any of their North fCarolina or South Carolina locations during the period from 1935 through 1980? If so, state: (a) Exact date(s) of said shipments; (b) Point of origin of each shipment; (c) Identity and quantity of products shipped; (d) Locations (addresses) to which products were shipped; and (e) Name and position of individual who received each shipment. ANSWER: General Electric objects to Interrogatory No. 25 on the same grounds stated in objection to Interrogatory No. 1. -16- INTERROGATORY no, 26? Did you ship any asbestos-containing products to Carolina Refractories at any of their North Carolina or South Carolina locations during the period from 1935 through 1980? If so, state: (a) Exact date(s) of said shipments; (b) Point of origin of each shipment; (c) Identity and quantity of products shipped; (d) Locations (addresses) to which products were shipped; and (e) Name and position of individual who received each shipment. ANSWERs General Electric objects to Interrogatory No. 26 on the same grounds stated in objection to Interrogatory No. 1. INTERROGATORY NO. 27: Did you ship any asbestos-containing products to C. E. Thurston and Sons, Inc. at any of their North Carolina or South Carolina locations during the period from 1935 through 1980? If so, state: (a) Exact date(s) of said shipments; (b) Point of origin of each shipment; (c) Identity and quantity of products shipped; (d) Locations (addresses) to which products were shipped; and (e) Name and position of individual who received each - shipment. ' ANSWER: General Electric objects to Interrogatory No. 27 on the same grounds stated in objection to Interrogatory No. 1. -17- INTERROGATORY NO. 28: Did you ship any asbestos-containing products to Joe Moore & Co. at any of their North Carolina or South Carolina locations during the period from 1935 through 1980? If so, state: (a) Exact date(s) of said shipments; (b) Point of origin of each shipment; (c) Identity and quantity of products shipped; (d) Locations (addresses) to which products were shipped; and (e) Name and position of individual who received each shipment. answer: General Electric objects to Interrogatory No. 28 on the same grounds stated in objection to Interrogatory No. 1. interrogatory NO. 29: Did you ship any asbestos-containing products to Duke Power Co. at any of their North Carolina or .South Carolina locations during the period from 1935 through 1980? If so, state: (a) Exact date(s) of said shipments; (b) Point of origin of each shipment; (c) Identity and quantity of products shipped; (d) Locations (addresses) to which products were shipped; and (e) Name and position of individual who received each shipment. ANSWER: General Electric objects to Interrogatory No. 29 on the grounds that it is overly broad and unduly burdensome, and on -18- the grounds stated in its "Preliminary Statement and General Objections." Without waiver of these objections and subject thereto. General Electric states that from time to time in the past, it has sold to Duke Power Company steam turbine-generators, related equipment, and replacement parts, some of which may have contained asbestos-containing products manufactured by others. In connection with its sale of this equipment, from time to time General Electric has subcontracted with others for the furnishing of related thermal insulation materials manufactured by others to Duke Power Company, some of which contained asbestos. General Electric's records indicate that the following steam turbinegenerators were sold to Duke Power Company, with each turbinegenerator being shipped from Schenectady, New York, and being delivered to the designated Duke Power Company plant site: 1. Cliffside Unit #2 shipped in 1939. . 2. Cliffside Unit #1 shipped in 1940. 3. Buck Unit #3 shipped in 1941. 4. Buck Unit #4 shipped in 1941. 5. Cliffside Unit #4 shipped in July 1948. 6. Dan River Unit #1 shipped in August 1949. 7. Dan River Unit #2 shipped in October 1949. 8. Lee Unit #1 shipped in October 1950. 9. - Lee Unit #2 shipped in March 1951. 10. Buck Unit #5 shipped in December 1952. 11. Buck Unit #6 shipped in January 1953. 12. Riverbend Unit #6 shipped in March 1954. -19- 13. Riverbend Unit #7 shipped in April 1954. 14. Dan River Unit #3 shipped in March 1955. 15. Allen Unit #1 shipped in October 1956. 16. Allen Unit #2 shipped in November 1956. 17. Lee Unit #3 shipped in March 1958. 18. Allen Unit #3 shipped in January 1959. 19. Allen Unit #4 shipped in July 1959. 20. Allen Unit #5 shipped in December 1960. 21. Marshall Unit #1 shipped in March 1964. 22. Marshall Unit #2 shipped in April 1965. 23. Marshall Unit #3 shipped in June 1968. 24. Marshall Unit #4 shipped in March 1969. 25. Cliffside Unit #5 shipped in January 1972. 26. Oconee Unit #1 shipped in June 1970. 27. Oconee Unit #2 shipped in December 1970. c 28. Oconee Unit #3 shipped in May 1972. 29. Catawba Unit #1 shipped in November 1978. 30. Catawba Unit #2 shipped in July 1979. INTERROGATORY NO. 30; Did you ship any asbestos-containing products to A. P. Green Refractories at any of their North Carolina or South Carolina locations during the period from 1935 through 1980? If so, state: (a) Exact date(s) of said shipments; (b) Point of. origin of each shipment; (c) Identity and quantity of products shipped; -20- (d) Locations (addresses) to which products were shipped; and (e) Name and position of individual who received each shipment. ANSWER; General Electric objects to Interrogatory No. 30 on the same grounds stated in objection to Interrogatory No. 1. INTERROGATORY NO. 31; Did you ship any asbestos-containing products to A. Lynn Thomas Co. Inc. at any of their North Carolina or South Carolina locations during the period from 1935 through 1980? If so, state; (a) Exact date(s) of said shipments; (b) Point of origin of each shipment; (c) Identity and quantity of products shipped; (d) Locations (addresses) to which products were shipped; and t (e) Name and position of individual who received each shipment. ANSWER: General Electric objects to Interrogatory No. 31 on the same grounds stated in objection to Interrogatory No. 1. This the day of August, 1989. Gerard H. Davidson, Jr. (N.C. Bar No. 5132) Timothy Peck (N.C. Bar No. 9991) Attorneys for Defendant General Electric Company -21- OF COUNSELS SMITH HELMS MULLISS & MOORE 500 NCNB Building Post Office Box 21927 Greensboro, North Carolina 27420 Telephones (919) 378-5200 -22- STATE OF NEW YORK " COUNTY OF SCHENECTADY ) ) ) VERIFICATION Bryce MacDonald, being duly sworn, deposes and says that he has read the foregoing "Defendant General Electric Company's Response to Plaintiffs' 'Supplemental Interrogatories to Defen dants'" and is familiar with the contents thereof; that the deponent is without personal knowledge of the matters stated in the foregoing "Defendant General Electric Company's Response to Plaintiffs' 'Supplemental Interrogatories to Defendants'" and is informed and believes that no officer or employee of General Electric Company has personal knowledge of all such matters; that the foregoing "Defendant General Electric Company's Response to Plaintiffs' 'Supplemental Interrogatories to Defendants'" has been assembled by authorized employees and counsel of General Electric Company who have informed deponent that the foregoing "Defendant General Electric Company's Response to Plaintiffs' 'Supplemental Interrogatories to Defendants'" is true; and that to the best of deponent's knowledge this "Defendant General Electric Company's Response to Plaintiffs' 'Supplemental Inter rogatories to Defendants'" is true. Sryca MacDonald Cmmsel, General Electric Company Subscribed and sworn to before me thisday of August, 1989. Notary Public in and for said County and State My Commission Expires: -23- CERTIFICATE OF SERVICE The undersigned hereby certifies that the foregoing "Defendant General Electric Company's Response to Plaintiffs' 'Supplemental Interrogatories to Defendants'" has been served upon the following known counsel for the various parties by mailing copies thereof via first-class mail, postage prepaid, addressed as follows: Ms. Mona Lisa Wallace Wallace and Pope 301 North Main Street Salisbury, North Carolina 28144 Mr. Michael Brickman Ness, Motley, Loadholt, Richardson & Poole, P.A. Post Office Box 1137 Charleston, South Carolina 29402 Mr. Donald E. Britt, Jr. Poisson, Barnhill & Britt Post Office Box 807 Wilmington, North Carolina 28402 Mr. Alexander M. Bullock Haynsworth, Marion, McKay & Guerard Post Office Box 2048 Greenville, South Carolina 29602 Mr. David G. Traylor, Jr. Nelson, Mullins, Riley & Scarborough 1301 Lady Street Post Office Box 11070 Columbia, South Carolina 29211 _ Mr. Robert F. Baker Spears, Barnes, Baker, Hoof, Wanio & Holeman Post Office Box 981 Durham, North Carolina 27702 Mr. Mark S. Thomas ' Maupin Taylor Ellis & Adams, P.A. Post Office Box 19764 Raleigh, North Carolina 27619-9764 -24- Mr. William C. Brewer, Jr. -Speight, Watson & Brewer Post Office Drawer 99 Greenville, North Carolina 27834 Mr. William D. Vines, III Butler, Vines, Bass and Threadgill Eighth Floor, First American Center Post Office Box 2649 Knoxville, Tennessee 37901-2649 Mr. Richard L. Huffman Waggoner, Hamrick, Hasty, Cobb & McDonnell 2500 First Union Plaza Charlotte, North Carolina Monteith, 28282 Kratt, Mr. Robert H. Hood Mr. Francis L. P. Barnwell Mr. Mark V. Evans Robert H. Hood & Associates Post Office Box 1508 Charleston, South Carolina 29402 Mr. William F. Maready Mr. J. Anthony Penry Petree Stockton & Robinson Post Office Box 300004 Raleigh, North Carolina 27622 Mr. Stanley M. Sams Mr. Gwynett Hilbum Browning, Sams, Poole, Hill & Hilbum Post Office Box 859 Greenville, North Carolina 27835-0859 Mr. Perry C. Henson Mr. Gary K. Sue Henson, Henson, Bayliss & Teague Post Office Box 3525 Greensboro, North Carolina 27402 Mr. Kenneth Kyre, Jr. Nichols, Caffrey, Hill, Evans & Murrelle Post Office Box 939 Greensboro, North Carolina 27402 Mr. John F. Mitchell Mr. James P. Cain Petree Stockton & Robinson Post Office Box 300004 Raleigh, North Carolina 27622 -25- Mr. C. Michael Evert, Jr. Fortson & White 300 Atlanta Financial South 3333 Peachtree Road, N.E. Atlanta, Georgia 30326 Mr. Louis Close, Jr. Whiteford, Taylor & Preston 7 St. Paul Street, Suite 1400 Baltimore, Maryland 21202-1626 Mr. Sanford W. Thompson, IV Mr. Buxton S. Copeland Patterson, Dilthey, Clay, Cranfill Sumner & Hartzog Post Office Box 310 Raleigh, North Carolina 27602-0310 Mr. John A. Gardner, III Hedrick, Eatman, Gardner & Kincheloe Post Office Box 30397 Charlotte, North Carolina 28204 Mr. Gary Parsons Mr. Carson Carmichael, III Ms. Dorothy V. Kibler Bailey & Dixon Post Office Box 12865 Raleigh, North Carolina 27605-2865 Mr. Robert Thackston McGuire, Woods, Battle & One James Center Richmond, Virginia 23219 Boothe This the day of August, 1989. Timothy Peck (N.C. Bar No. 9991) Attorney for Defendant General Electric Company -26-