Document ev610bz3Kk67dqZj7oNVGrzjg

/I IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF SOUTH CAROLINA GREENVILLE DIVISION GREENVILLE COUNTY SCHOOL DISTRICT, Plaintiff, -vs- UNITED STATES GYPSUM COMPANY, W. R. GRACE COMPANY, and NATIONAL GYPSUM COMPANY, Defendants. ) ) ) ) ) ) ) ) ) ) ) ) . fct . Civil Action No. 82-3142 AFFIDAVIT OF S. K. TORRE S. K. Torrey, being first duly sworn on oath, dep and states: 1. This Affidavit is filed pursuant to the Cour Order dated April 25, 1984, directing that the defendants s; file a statement dealing with the Plaintiff's Request to ?r Documents, setting forth the "encompassment of the search, person or persons who participated in the search, and the i tification of all documents for which they claim privilege. 2. She is Senior Attorney - Litigation, employe by and representing United States Gypsum Company, one of th defendants herein and has been employed in the same or simi capacity since March, 1979. During the period August, 1977 March, 1979, she held the position of attorney. 3. During the entire period from August, ig"77 t present, she has had primary responsibility for the manager and coordination of all aspects of this defendant's involve in asbestos cases, both personal injury and property damage ^ om. a. v.o. / 5 nr-, c-i_. i r. *4 ror o. c .JZz&fZr..- < c rasbestc? litigation"). Part of these responsibilities ir searching'for documents which were or might be relevant"'to "asbestos litigation." This search for documents was.perfc by her personally or by others under her direction and cont All documents reviewed and/or produced for the "asbestos litigation" were discovered during this time frame. - 4. Said search for documents commenced in appro mately 1978 and has been an on-going procedure. No attempt .. was made to systematically record the identity of each pers consulted or each drawer or box opened. To reconstruct thi process would be difficult at best and bound to result in omissions of names or places. 5. The foregoing notwithstanding, in general th following locations were searched: USG central corporate f (located at 101 South Wacker Drive and 500 Orleans Street, Chicago, Illinois), research department, product management quality department, safety department, secretarial deparrme- personnel department, data processing, architectural servic advertising, various plants, sales and division offices, in ance department, and libraries. Persons affiliated with th departments were consulted and may have participated in the search. Literally_hundreds of current and/or former emplov have been consulted. 6. Plaintiff's Request for Production herein wa filed on or about January 13, 1983, some five years after t search for documents was begun. -2- 7. Obviously, not all document request:: and interrogatories are identical and differing requests may cause different records to be searched. 8. Similarly, if a request for documents or inte rogatory seeks information previously reviewed and gathered, documents are produced from that source of documents and if already complete, no further search is undertaken since it would he needlessly duplicative. 9. At present, no other documents have been loca responsive to Plaintiff's Request to Produce dated January 1 1983, as qualified by outstanding Objections and excluding privileged documents, if any, and as already disclosed in Un. States Gypsum Company's Supplemental Responses or previously produced to plaintiff's counsel without formal Supplementati; other than the attached, which was located recently. 10. Other persons knowledgeable about the searc documents in whole or in part include, but are not limited hi B. L. Arras, Attorney; G. H. Smith, Attorney; E. A. Throop Assistant; L. A. Steskal, Legal Assistant; C. J. Witting, Le Assistant; D. L. Woodruff, (former) Legal Assistant; M. J (former) Legal Assistant; E. A. Griffith, (former) Legal Ass J. H. Robinsori,--Legal Assistant, R. Galqar.ski . (former) Seer J. McCullough, (former) Legal Assistant, E. 0. McCarthy, (fo Attorney; J. F. Hernan, Manager, Corporate Ouality Assurance K. S. Freeman, (former) Manager, Consumer Product Safety; J. D. Cornell, Manager, Corporate Occupational Safety & Heal R. E.-Clark, Records Manager; J. N. Walker, 3- Research & Development, (and various others at Research) * <- c R. L. Russell, Manager, Insurance. FURTHER, THE AFFIANT SAYETH NOT. " 'Subscribed and Sworn to before me this 25th day of May, 1984. ____ 0. MvQj NOT^Y PUBLIC !. i* i i PLAINTIFFS exhibit