Document g225XVaMJjaZ4JDjDwpz7dLee

NO. 99-06508-M THURMAN HARMON, et al., Plaintiffs, vs. OWENS CORNING (a/k/a OWENS CORNING CORPORATION), et al., Defendants. IN THE DISTRICT COURT DALLAS COUNTY, TEXAS 298TH JUDICIAL DISTRICT DEFENDANT CELANESE LTD'S OBJECTIONS AND RESPONSES TO PLAINTIFF FIDENCIO ORTA SANCHEZ'S SECOND SET OF ADMISSIONS AND THIRD SET OF REQUEST FOR PRODUCTION TO DEFENDANT CELANESE, LTD. TO: Plaintiff Fidencio Orta Sanchez, by and through his attorney, Chad Cotten, Baron & Budd, The Centrum, Suite 1100, 3102 Oak Lawn Avenue, Dallas, Texas 75219 Pursuant to the Texas Rules of Civil Procedure (the "Rules"), Defendant Celanese. Ltd. (referenced herein as "Defendant" or "Celanese") submits these Responses to Plaintiff Fidencio Orta Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. as follows: GENERAL RESPONSES. OBJECTIONS AND ASSERTIONS OF PRIVILEGE Celanese makes the following general objections to each and every request directed to it 1. Celanese objects to Plaintiff's Instruction No. 1. Celanese may produce non-privileged responsive documents in the manner in which they are kept in the f Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 1 CEL-1524 98102 ordinary course of business. 2. Celanese objects to the requests to the extent that they seek to compel the disclosure of information specifically exempted from discovery by the privileges afforded in. the Texas Rules of Civil Procedure ("Rules") and Article V. of the Texas Rules of Evidence, including the attorney/client privilege, the joint defense privilege, the attorney work product doctrine, or the investigative privilege. Any withholding of documents or information on the basis of privilege will be specifically noted as part of Celanese's objections and responses after the discovery-request calling for such privileged information and/or documents, if any. 3. Celanese objects to paragraph one of the DEFINITIONS regarding "Defendants," "You," "Your," and "Your Company" and paragraph one regarding "persons" because they are overly broad and unduly burdensome and pertain to corporations other than those who are parties to this suit. Celanese also objects to paragraphs one because it includes Celanese's attorneys; information and things protected by the attorney client privilege and work product doctrine are not discoverable. 4. Celanese objects to any discovery request seeking to charge it with knowledge or information held by its "predecessors or subsidiaries" or requiring it to provide information regarding plants other than the ones at which plaintiff Fidencio Orta Sanchez allegedly worked, to wit, the Celanese Bishop, Texas facility. Accordingly, it is Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 2 98102 unduly burdensome, excessively expensive and harassing to require Celanese to answer these discovery requests as to all plants, and/or any plant at which plaintiff never worked. 5. Celanese objects to plaintiff's discovery requests to the extent they are unlimited in time. ^ 6. Celanese objects to plaintiffs requests to the extent that they necessarily seek disclosure of trade secrets, proprietary material and other confidential information protected from discovery by the Texas Rules of Civil Procedure% ,' 7. The presence of an objection does not mean that Celanese possesses non-privileged information responsive to a discovery request. 8. Celanese objects to paragraph two of the DEFINITIONS because the definition of the word "document" and the instructions regarding "possession, custody or control" are overly broad, seeks information specifically exempted from discovery by the privileges afforded in the Rules and Rule 503 of the Texas Rules of Evidence, including the attorney work product doctrine, and the attorney client privilege. Throughout these responses, Celanese will assume that the word will have its commonly used meaning, as set forth in Rule 192.3(b), and will respond accordingly. 9. Celanese objects to paragraph six of the DEFINITIONS to the extent information is sought concerning asbestos in a non-friable form. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 3 98102 10. Celanese objects to paragraphs 16 and 17 of the DEFINITIONS because the definition of the word "identify" is overly broad, unduly burdensome and harassing. 11. Celanese objects to the definition of the term "Time Period at Issue" contained in paragraph 21 of the DEFINITIONS because it is presently vague, ambiguous and overly broad. Plaintiff testified in lnj deposition that his alleged work at the Celanese Bishop facility occurred between the years of 1961 and 1970. Accordingly, where a request incorporates this term, Celanese will respond for the time period of 1961 through 1970. 12. Celanese objects to plaintiff's requests to the extent that they are duplicative and cumulative of discovery requests previously served by plaintiff upon Celanese and to which Celanese has previously responded. SPECIFIC OBJECTIONS AND RESPONSES TO PLAINTIFFS SECOND REQUEST FOR ADMISSIONS REQUEST FOR ADMISSION NO. 1 Admit that Celanese was a member of the Industrial Hygiene Foundation in 1951. RESPONSE: Denied REQUEST FOR ADMISSION NO. 2 Admit that Celanese was a member of the Industrial Hygiene Foundation in 1952. RESPONSE: Admitted Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 4 98102 REQUEST FOR ADMISSION NO. 3 Admit that Celanese was a member of the Industrial Hygiene Foundation in 1953. RESPONSE: Admitted REQUEST FOR ADMISSION NO. 4 Admit that Celanese was a member of the Industrial Hygiene Foundation in 1954. RESPONSE: Admitted T* REQUEST FOR ADMISSION NO. 5 Admit that Celanese was a member of the Industrial Hygiene Foundation in 1955. RESPONSE: Admitted REQUEST FOR ADMISSION NO. 6 Admit that Celanese was a member of the Industrial Hygiene Foundation in 1956. RESPONSE: Admitted REQUEST FOR ADMISSION NO. 7 Admit that Celanese was a member of the Industrial Hygiene Foundation in 1957. RESPONSE: Admitted Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 5 98102 REQUEST FOR ADMISSION NO. 8 Admit that Celanese was a member of the Industrial Hygiene Foundation in 1958. RESPONSE: Admitted REQUEST FOR ADMISSION NO. 9 ^ Admit that Celanese was a member of the Industrial Hygiene Foundation in 1959. RESPONSE: Admitted REQUEST FOR ADMISSION NO. 10 Admit that Celanese was a member of the Industrial Hygiene Foundation in 1960. RESPONSE: Admitted REQUEST FOR ADMISSION NO. 11 Admit that Celanese was a member of the Industrial Hygiene Foundation in 1961. RESPONSE: Admitted REQUEST FOR ADMISSION NO. 12 Admit that Celanese was a member of the Industrial Hygiene Foundation in 1962. RESPONSE: Admitted Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 6 98102 REQUEST FOR ADMISSION NO. 13 Admit that Celanese was a member of the Industrial Hygiene Foundation in 1963. RESPONSE: Admitted REQUEST FOR ADMISSION NO. 14 Admit that Ceianese was a member of the Industrial Hygiene Foundation in 1964. RESPONSE: Admitted f* REQUEST FOR ADMISSION NO. 15 Admit that Celanese was a member of the Industrial Hygiene Foundation in 1965. RESPONSE: Admitted REQUEST FOR ADMISSION NO. 16 Admit that Celanese was a member of the Industrial Hygiene Foundation in 1966. RESPONSE: Admitted REQUEST FOR ADMISSION NO. 17 Admit that Celanese was a member of the Industrial Hygiene Foundation in 1967. RESPONSE: Admitted Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 7 98102 REQUEST FOR ADMISSION NO. 18 Admit that Celanese was a member of the Industrial Hygiene Foundation in 1968. RESPONSE: Admitted REQUEST FOR ADMISSION NO. 19 Admit that Celanese was a member of the Industrial Hygiene Foundation in 1969. RESPONSE: Admitted ' REQUEST FOR ADMISSION NO .20 Admit that Celanese was a member of the Industrial Hygiene Foundation in 1970. RESPONSE: Admitted REQUEST FOR ADMISSION NO. 21 Admit that Celanese was a member of the Industrial Hygiene Foundation in 1971. RESPONSE: Admitted REQUEST FOR ADMISSION NO. 22 Admit that Celanese was a member of the National Safety Council in 1951. RESPONSE: Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 8 98102 Celanese admits that it has been, and remains, a member of the National Safety Council. Although the beginning date of its membership in that organization is presently unknown, on present information and belief, Celanese was a member by at least some time in the mid-1960s. REQUEST FOR ADMISSION NO. 23 Admit that Celanese was a member of the National Safety Council in 1952. RESPONSE: ^ Celanese admits that it has been, and remains, a member of the National Safety Council. Although the beginning date of its membership in that organization is presently unknown, on present information and belief, Celanese was a member by at least some time in the mid-1960s. REQUEST FOR ADMISSION NO. 24 Admit that Celanese was a member of the National Safety Council in 1953. RESPONSE: Celanese admits that it has been, and remains, a member of the National Safety Council. Although the beginning date of its membership in that organization is presently unknown, on present information and belief, Celanese was a member by at least some time in the mid-1960s. REQUEST FOR ADMISSION NO. 25 Admit that Celanese was a member of the National Safety Council in 1954. RESPONSE: Celanese admits that it has been, and remains, a member of the National Safety Council. Although the beginning date of its membership in that organization is presently unknown, on present information and belief, Celanese was a member by at least some time in the mid-1960s. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 9 98102 REQUEST FOR ADMISSION NO. 26 Admit that Celanese was a member of the National Safety Council in 1955. RESPONSE: Celanese admits that it has been, and remains, a member of the National Safety Council. Although the beginning date of its membership in that organization is presently unknown, on present information and belief, Celanese was a member by at least some time in the mid-1960s. REQUEST FOR ADMISSION NO. 27 Admit that Celanese was a member of the National Safety Council in 1956. RESPONSE: Celanese admits that it has been, and remains, a member of the National Safety Council. Although the beginning date of its membership in that organization is presently unknown, on present information and belief, Celanese was a member by at least some time in the mid-1960s. REQUEST FOR ADMISSION NO. 28 Admit that Celanese was a member of the National Safety Council in 1957. RESPONSE: Celanese admits that it has been, and remains, a member of the National Safety Council. Although the beginning date of its membership in that organization is presently unknown, on present information and belief, Celanese was a member by at least some time in the mid-1960s. REQUEST FOR ADMISSION NO. 29 Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 10 98102 Admit that Celanese was a member of the National Safety Council in 1958. RESPONSE: Celanese admits that it has been, and remains, a member of the National Safety Council. Although the beginning date of its membership in that organization is presently unknown, on present information and belief, Celanese was a member by at least some time in the mid-1960s. REQUEST FOR ADMISSION NO. 30 Admit that Celanese was a member of the National Safety Council in 1959. RESPONSE: * Celanese admits that it has been, and remains, a member of the National Safety Council. Although the beginning date of its membership in that organization is presently unknown, on present information and belief, Celanese was a member by at least some time in the mid-1960s. REQUEST FOR ADMISSION NO. 31 Admit that Celanese was a member of the National Safety Council in 1960. RESPONSE: Celanese admits that it has been, and remains, a member of the National Safety Council. Although the beginning date of its membership in that organization is presently unknown, on present information and belief, Celanese was a member by at least some time in the mid-1960s. REQUEST FOR ADMISSION NO. 32 Admit that Celanese was a member of the National Safety Council in 1961. RESPONSE: Celknese admits that it has. been, and remains, a member of the National Safety Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 11 98102 Council. Although the beginning date of its membership in that organization is presently unknown, on present information and belief, Celanese was a member by at least some time in the mid-1960s. REQUEST FOR ADMISSION NO. 33 Admit that Celanese was a member of the National Safety Council in 1962. RESPONSE: _ Celanese admits that it has been, and remains, a member of the National Safety Council. Although the beginning date of its membership in that organization is presently unknown, on present information and belief, Celanese was a member by at least some time in the mid-1960s. REQUEST FOR ADMISSION NO. 34 Admit that Celanese was a member of the National Safety Council in 1963. RESPONSE: Celanese admits that it has been, and remains, a member of the National Safety Council. Although the beginning date of its membership in that organization is presently unknown, on present information and belief, Celanese was a member by at least some time in the mid-1960s. REQUEST FOR ADMISSION NO, 35 Admit that Celanese was a member of the National Safety Council in 1964. RESPONSE: Celanese admits that it has been, and remains, a member of the National Safety Council. Although the beginning date of its membership in that organization is presently unknown, on present information and belief, Celanese was a member by at least some time in the mid-1960s. REQUEST FOR ADMISSION NO. 36 Admit that Celanese was a member of the National Safety Council in 1965. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 12 98102 RESPONSE: Celanese admits that it has been, and remains, a member of the National Safety Council. Although the beginning date of its membership in that organization is presently unknown, on present information and belief, Admitted. REQUEST FOR ADMISSION NO. 37 Admit that Celanese was a member of the National Safety Council in 1966. RESPONSE: Celanese admits that it has been, and remains, a member of the National Safety Council. Although the beginning date of its membership in that organization is presently unknown, on present information and belief, Admitted. REQUEST FOR ADMISSION NO. 38 Admit that Celanese was a member of the National Safety Council in 1967. RESPONSE: Celanese admits that it has been, and remains, a member of the National Safety Council. Although the beginning date of its membership in that Organization is presently unknown, on present information and belief, Admitted. REQUEST FOR ADMISSION NO. 39 Admit that Celanese was a member of the National Safety Council in 1968. RESPONSE: Celanese admits that it has been, and remains, a member of the National Safety Council. Although the beginning date of its membership in that organization is presently unknown, on present information and belief, Admitted. REQUEST FOR ADMISSION NO. 40 Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 13 98102 Admit that Celanese was a member of the National Safety Council in 1969. RESPONSE: Celanese admits that it has been, and remains, a member of the National Safety Council. Although the beginning date of its membership in that organization is presently unknown, on present information and belief, Admitted. REQUEST FOR ADMISSION NO. 41 Admit that Celanese was a member of the National Safety Council in 1970. RESPONSE: Celanese admits that it has been, and remains, a member of the National Safety Council. Although the beginning date of its membership in that organization is presently unknown, on present information and belief, Admitted. REQUEST FOR ADMISSION NO. 42 Admit that Celanese was a member of the Manufacturing Chemistry Association in 1966. RESPONSE: On present information and belief, Admitted. REQUEST FOR ADMISSION NO, 43 Admit that Celanese was a member of the Manufacturing Chemistry Association in 1967. RESPONSE: On present information and belief, Admitted.. REQUEST FOR ADMISSION NO. 44 Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 14 98102 Admit that Celanese was a member of the Manufacturing Chemistry Association in 1968. RESPONSE: On present information and belief, Admitted. REQUEST FOR ADMISSION NO. 45 Admit that Celanese was a member of the Manufacturing Chemistry Association in 1969. RESPONSE: On present information and belief, Admitted. REQUEST FOR ADMISSION NO. 46 Admit that Celanese was a member of the Manufacturing Chemistry Association in 1970. RESPONSE: On present information and belief, Admitted. REQUEST FOR ADMISSION NO. 47 Admit that a case of pnuemoconiosis was reported by a Celanese employee in 1951. RESPONSE: Celanese admits that in or around 1951 an employee at a plant other than the one at issue in this case did report an alleged dust-related illness, but the specific illness he reported he purportedly had was silicosis and was not an injury in any way related to alleged asbestos exposure. REQUEST FOR ADMISSION NO. 48 Admit that Celanese did not employed any industrial hygienists before 1966. RESPONSE: Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 158} 98102 Celanese objects to this request on the grounds that it is overly broad in that it is not properly limited to the plant at issue in this litigation. Celanese further objects to this request on the grounds that jt seeks information that is irrelevant and not reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing general and specific objections, Celanese admits only that it had an industrial hygienist on its direct company payroll before 1966 although Celanese obtained industrial hygiene services from its insurance carriers prior to that time. ^ REQUEST FOR ADMISSION NO. 49 Admit that Charles Laubly was the only industrial hygienist employed by Celanese from 1966-1970. RESPONSE: Celanese objects to this request on the grounds that it is overly broad in that it is not properly limited to the plant at issue in this litigation. Celanese further objects to this request on the grounds that it seeks information that is irrelevant and not reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing general and specific objections, denied as stated. Although Mr. Laubly was the only individual with the formal title of "industrial hygienist", others within the company performed industrial hygiene related activities during the stated time period. REQUEST FOR ADMISSION NO. 50 Admit that Charles Laubly was the only industrial hygienist employed by Celanese until the mid 1970's. RESPONSE: Celanese objects to this request on the grounds that it is overly broad in that it is not properly limited to the plant at issue in this litigation. Celanese further objects to this request on the grounds that it seeks information that is irrelevant and not reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing general and specific objections, denied as stated. Although Mr. Laubly was the only individual with the formal title of "industrial Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 16 98102 hygienist", others within the company performed industrial hygiene related activities during the stated time period. REQUEST FOR ADMISSION NO. 51 Admit that Charles Laubly provided industrial hygiene services for all Celanese facilities from 1966-1970. RESPONSE: ^ Celanese objects to this request on the grounds that it is overly broad in that it is not properly limited to the plant at issue in this litigation. Celanese further objects to this request on the grounds that it seeks information that is irrelevant and not reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing general and specific objections Celanese admits only that Mr. Laubly performed industrial hygiene services at Celanese's various facilities during the stated time period. REQUEST FOR ADMISSION NO. 52 Admit that Celanese was aware of the 1958 Texas workplace regulations concerning airborne dust in 1960. RESPONSE: Due to the passage of time, Celanese can neither admit or deny this request. REQUEST FOR ADMISSION NO. 53 Admit that Celanese did not have any company-wide policy for handling asbestos from 1959-1.972. RESPONSE: Celanese objects to this request as overly broad in that it is not limited to the time period at issue in this litigation and thus seeks information not relevant to this litigation. Further, Celanese objects to this request as it is based upon an improper premise and in that it assumes facts not in evidence. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 17 98102 Subject to and without waiving this or any other specific or general objection, Celanese admits only that, consistent with medical knowledge and American industry standards at that period, it did not have a company-wide policy for the handling of finished asbestoscontaining products until the time the first OSHA asbestos standards came into effect. REQUEST FOR ADMISSION NO. 54 Admit that Celanese did not have a program to train its employees about airborne dust hazards in 1959. ^ RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside of the time period at issue in this litigation and further in that it is'not limited to the specific Celanese facility at issue in this litigation. The request therefore seeks information that is neither relevant nor reasonable calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 55 Admit that Celanese did not have a program to train its employees about airborne dust hazards in 1960. RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside of the time period at issue in this litigation and further in that it is not limited to the specific Celanese facility at issue in this litigation. The request therefore seeks information that is neither relevant nor reasonable calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 56 Admit that Celanese did not have a program to train its employees about airborne dust hazards in 1961. RESPONSE: Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 18 98102 Celanese objects to this request as overly broad in that it is riot limited to the Celanese facility at issue in this litigation. Furthermore, this request seeks information with regards to programs for Celanese employee and not contractor employees like plaintiff. Subject to and without waiving this or any other specific or general objection, Celanese denies this request as stated. REQUEST FOR ADMISSION NO. 57 Admit that Celanese did not have a program to train its employees about airborne dust hazards in 1962. RESPONSE: Celanese objects to this request as overly broad in that it is not limited to the Celanese facility at issue in this litigation. Furthermore, this request seeks information with regards to programs for Celanese employee and not contractor employees like plaintiff. Subject to and without waiving the foregoing general and specific objections, Celanese denies this request as stated. REQUEST FOR ADMISSION NO. 58 Admit that Celanese did not have a program to train its employees about airborne dust hazards in 1963. RESPONSE: Celanese objects to this request as overly broad in that it is not limited to the Celanese facility at issue in this litigation. Furthermore, this request seeks information with regards to programs for Celanese employee and not contractor employees like plaintiff. Subject to and without waiving this or any other specific or general objection, Celanese denies this request as stated. REQUEST FOR ADMISSION NO. 59 Admit that Celanese did not have a program to train its employees about airborne dust hazards in 1964. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 19 98102 RESPONSE: Celanese objects to this request as overly broad in that it is not limited to the Celanese facility at issue in this litigation. Furthermore, this request seeks information with regards to programs for Celanese employee and not contractor employees like plaintiff. Subject to and without waiving this or any other specific or general objection, Celanese denies this request as stated. REQUEST FOR ADMISSION NO. 60 Admit that Celanese did not have a program to train its employees about airborne dust hazards in 1965. RESPONSE: Celanese objects to this request as overly broad in that it is not limited to the Celanese facility at issue in this litigation. Furthermore, this request seeks information with regards to programs for Celanese employee and not contractor employees like plaintiff. Subject to and without waiving this or any other specific or general objection, Celanese denies this request as stated. REQUEST FOR ADMISSION NO. 61 Admit that Celanese did not have a program to train its employees about airborne dust hazards in 1966. RESPONSE: Celanese objects to this request as overly broad in that it is not limited to the Celanese facility at issue in this litigation. Furthermore, this request seeks information with regards to programs for Celanese employee and not contractor employees like plaintiff. Subject to and without waiving this or any other specific or general objection, Celanese denies this request as stated. RE-QUEST FOR ADMISSION NO. 62 Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 20 98102 Admit that Celanese did not have a program to train its employees about airborne dust hazards in 1967. RESPONSE: Celanese objects to this request as overly broad in that it is not limited to the Celanese facility at issue in this litigation. Furthermore, this request seeks information with regards to programs for Celanese employee and notcontractor employees like plaintiff. Subject to and without waiving this or any other specific or general objection, Celanese denies this request as stated. REQUEST FOR ADMISSION NO. 63 Admit that Celanese did not have a program to train its employees about airborne dust hazards in 1968. RESPONSE: Celanese objects to this request as overly broad in that it is not limited to the Celanese facility at `issue in this litigation. Furthermore, this request seeks, information with regards to programs for Celanese employee and not contractor employees like plaintiff. Subject to and without waiving this or any other specific or general objection, Celanese denies this request as stated. REQUEST FOR ADMISSION NO. 64 Admit that Celanese did not have a program to train its employees about airborne dust hazards in 1969. RESPONSE: Celanese objects to this request as overly broad in that it is not limited to the Celanese facility at issue in this litigation. Furthermore, this request seeks information with regards to programs for Celanese employee and not contractor employees like plaintiff. Subject to and without waiving this or any other specific or general objection, Celanese Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 21 98102 denies this request as stated. REQUEST FOR ADMISSION NO. 65 Admit that Celanese did not have a program to train its employees about airborne dust hazards in 1970. RESPONSE: Celanese objects to this request as overly broad in that it is not limited to the Celanese facility at issue in this litigation. Furthermore, this request seeks information with regards to programs for Celanese employee and not contractor employees like plaintiff. Subject to and without waiving this or any other specific or general objection, Celanese denies this request as stated. . REQUEST FOR ADMISSION NO. 66 Admit that Celanese did not have a program to train its employees about airborne dust hazards in 1971. RESPONSE: Celanese objects to this request as overly broad in that it is not limited to the Celanese facility at issue in this litigation. Furthermore, this request seeks information with regards to programs for Celanese employee and not contractor employees like plaintiff. Subject to and without waiving this or any other specific or general objection, Celanese denies this request as stated. REQUEST FOR ADMISSION NO. 67 Admit that Celanese did not have a program to train its employees about airborne dust hazards in 1972. RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside the time period at issue in this litigation. Further, the request is overly broad in that it is not Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 22 98102 limited to the Celanese facility at issue in this litigation. REQUEST FOR ADMISSION NO. 68 Admit that Celanese did not have a program to train contractor employees about airborne dust hazards in 1959. RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside the time period at issue in this litigation. Further, the request is overly broad in that it is not limited to the Celanese facility at issue in this litigation. REQUEST FOR ADMISSION NO. 69 Admit that Celanese did not have a program to train contractor employees about airborne dust hazards in 1960. RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside the time period at issue in this litigation. Further, the request is overly broad in that it is not limited to the Celanese facility at issue in this litigation. REQUEST FOR ADMISSION NO. 70 Admit that Celanese did not have a program to train contractor employees about airborne dust hazards in 1961. RESPONSE: Celanese objects to this request as overly broad in that it is not limited to the Celanese facility at issue in this litigation and thus seeks information not relevant to this litigation. Subject to and without waiving this or any other specific or general objection, Celanese can neither admit or deny this request as stated. Although Celanese had no duty to provide such training to independent contractor companies, Celanese cannot say what information regarding general dust control it may have passed on to contractor companies although it believes that such contractors, like Celanese, were knowledgeable about using suitable care when working around high concentrations of Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 23 98102 dust, to include the use of respiratory protection and other dust control measures as the contractors deemed appropriate. REQUEST FOR ADMISSION NO. 71 Admit that Celanese did not have a program to train contractor employees about airborne dust hazards in 1962. RESPONSE: ^ Celanese objects to this request as overly broad in that it is not limited to the Celanese facility at issue in this litigation and thus seeks information not relevant to this litigation. Subject to and without waiving this or any other specific or general objection, Celanese can neither admit or deny this, request as stated. Although-Gelanese had no duty to provide such training to independent contractor companies, Celanese cannot say what information regarding general dust control it may have passed on to contractor companies although it believes that such contractors, like Celanese, were knowledgeable about using suitable care when working around high concentrations of dust, to include the use of respiratory protection and other dust control measures as the contractors deemed appropriate. REQUEST FOR ADMISSION NO. 72 Admit that Celanese did not have a program to train contractor employees about airborne dust hazards in 1963. RESPONSE: Celanese objects to this request as overly broad in that it is not limited to the Celanese facility, at issue in this litigation and thus seeks information not relevant to this litigation. Subject to and without waiving this or any other specific or general objection, Celanese can neither admit or deny this request as stated. Although Celanese had no duty to provide such training to independent contractor companies, Celanese cannot say what information regarding general dust control it may have passed on to contractor companies although it believes that such contractors, like Celanese, were knbwledgeable about using suitable care when working around high concentrations of Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 24 98102 dust, to include the use of respiratory protection and other dust control measures as the contractors deemed appropriate. REQUEST FOR ADMISSION NO. 73 Admit that Celanese did not have a program to train contractor employees about airborne dust hazards in 1964. RESPONSE: _ Celanese objects to this request as overly broad in that it is not limited to the Celanese facility at issue in this litigation and thus seeks information not relevant to this litigation. Subject to and without waiving this or any other specific or general objection, Celanese can neither admit or deny this request as stated. Although-Celanese had no duty to provide such training to independent contractor companies, Celanese cannot say what information regarding general dust control it may have passed on to contractor companies although it believes that such contractors, like Celanese, were knowledgeable about using suitable care when working around high concentrations of dust, to include the use of respiratory protection and other dust control measures as the contractors deemed appropriate. REQUEST FOR ADMISSION NO. 74 Admit that Celanese did not have a program to train contractor employees about airborne dust hazards in 1965. RESPONSE: Celanese objects to this request as overly broad in that it is not limited to the Celanese facility at issue in this litigation and thus seeks information not relevant to this litigation. Subject to and without waiving this or any other specific or general objection, Celanese can neither admit or deny this request as stated. Although Celanese had no duty to provide such training to independent contractor companies, Celanese cannot say what information regarding general dust control it may have passed on to contractor companies although it believes that such contractors, like Celanese, were knowledgeable about using suitable care when working around high concentrations of dust, to include the use of respiratory protection and other dust control measures as the Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 25 98102 contractors deemed appropriate. REQUEST FOR ADMISSION NO. 75 Admit that Celanese did not have a program to train contractor employees about airborne dust hazards in 1966. RESPONSE: Celanese objects to this request as overly broad in that it is not limited to the Celanese facility at issue in this litigation and thus seeks information not relevant to this litigation. Subject to and without waiving this or any other specific or general objection, Celanese can neither admit or deny this request as stated. Although Celanese had no duty to provide such training to independent contractor companies, Celanese cannot say what information regarding general dust control it may have passed on to contractor companies although it believes that such contractors, like Celanese, were knowledgeable about using suitable care when working around high concentrations of dust, to include the use of respiratory protection and other dust control measures as the contractors deemed appropriate. REQUEST FOR ADMISSION NO. 76 Admit that Celanese did not have a program to train contractor employees about airborne dust hazards in 1967. RESPONSE: Celanese objects to this request as overly broad in that it is not limited to the Celanese facility at issue in this litigation and thus seeks information not relevant to this litigation. Subject to and without waiving this or any other specific or general objection, Celanese can neither admit or deny this request as stated. Although Celanese had no duty to provide such training to independent contractor companies, Celanese cannot say what information regarding general dust control it may have passed on to contractor companies although it believes that such contractors, like Celanese, were knowledgeable about using suitable care when working around high concentrations of dust, to include the use of respiratory protection and other dust control measures as the contractors deemed appropriate. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 26 98102 REQUEST FOR ADMISSION NO. 77 Admit that Celanese did not have a program to train contractor employee's about airborne dust hazards in 1968. RESPONSE: Celanese objects to this request as overly broad iruihat it is not limited to the Celanese facility at issue in this litigation and thus seeks information not relevant to this litigation. Subject to and without waiving this or any other specific or general objection, Celanese can neither admit or deny this request as stated. Although Celanese had no duty to provide such training to independent contractor companies, Celanese cannot say what information regarding general, dust control it may have -passed on to contractor companies although it believes that such contractors, like Celanese, were knowledgeable about using suitable care when working around high concentrations of dust, to include the use of respiratory protection and other dust control measures as the contractors deemed appropriate. REQUEST FOR ADMISSION NO. 78 Admit that Celanese did not have a program to train contractor employees about airborne dust hazards in 1969. RESPONSE: Celanese objects to this request as overly broad in that it is not limited to the Celanese facility at issue in this litigation and thus seeks information not relevant to this litigation. Subject to and without waiving this or any other specific or general objection, Celanese can neither admit or deny this request as stated. Although Celanese had no duty to provide such training to independent contractor companies, Celanese cannot say what information regarding general dust control it may have passed on to contractor companies although it believes that such contractors, like Celanese, were knowledgeable about using suitable care when working around high concentrations of dust, to include the use of respiratory protection and other dust control measures as the contractors deemed appropriate. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 27 98102 REQUEST FOR ADMISSION NO. 79 Admit that Celanese did not have a program to train contractor employees about airborne dust hazards in 1970. RESPONSE: Celanese objects to this request as overly broad icUhat it is not limited to the Celanese facility at issue in this litigation and thus seeks information not relevant to this litigation. Subject to and without waiving this or any other specific or general objection, Celanese can neither admit or deny this request as stated. Although Celanese had no duty to provide such training to independent contractor companies, Celanese cannot say what information regarding general, dust control it may have-passed on to contractor companies although it believes that such contractors, like Celanese, were knowledgeable about using suitable care when working around high concentrations of dust, to include the use of respiratory protection and other dust control measures as the contractors deemed appropriate. REQUEST FOR ADMISSION NO. 80 Admit that Celanese did not have a program to train contractor employees about airborne dust hazards in 1971. RESPONSE: Celanese objects to this request as overly broad in that it is not limited1 to the Celanese facility at issue in this litigation and thus seeks information not relevant to this litigation. Subject to and without waiving this or any other specific or general objection, Celanese can neither admit or deny this request as stated. Although Celanese had no duty to provide such training to independent contractor companies, Celanese cannot say what information regarding general dust control it may have passed on to contractor companies although it believes that such contractors, like Celanese, were knowledgeable about using suitable care when working around high concentrations of dust, to include the use of respiratory protection and other dust control measures as the contractors deemed appropriate. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 28 98102 REQUEST FOR ADMISSION NO. 81 Admit that Celanese did not have a program to train contractor employees about airborne dust hazards in 1972. RESPONSE: Celanese objects to this request as overly broad in-that it seeks information outside the time period at issue in this litigation. Further, the request is overly broad in that it is not limited to the Celanese facility at issue in this litigation. REQUEST FOR ADMISSION NO. 82 Admit that Celanese did not have any x-ray program to monitor pneumoconiosis in its employees in 1959. RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside of the time period at issue in this litigation and further in that it is not limited to the specific Celanese facility at issue in this litigation. The request therefore calls for information not relevant to this litigation. REQUEST FOR ADMISSION NO. 83 Admit that Celanese did not have any x-ray program to monitor pneumoconiosis in its employees in 1960. RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside of the time period at issue in this litigation and further in that it is not limited to the specific Celanese facility at issue in this litigation. The request therefore calls for information not relevant to this litigation. REQUEST FOR ADMISSION NO. 84 Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 29 98102 Admit that Celanese did not have any x-ray program to monitor pneumoconiosis in its employees in 1961. RESPONSE: Celanese objects to this request as overly broad in that it is not limited to the Celanese facility at issue in this litigation and thus seeks information not relevant to this litigation. Further, this request seeks information with regardJp programs for Celanese employees and not as to contractors like plaintiff in this case. Subject to and without waiving this or any other specific or general objection, Celanese denies this request as stated. REQUEST FOR ADMISSION NO. 85 Admit that Celanese did not have any x-ray program to monitor pneumoconiosis in its employees in 1962. RESPONSE: Celanese objects to this request as overly broad in that it is not limited to the Celanese facility at issue in this litigation and thus seeks information not relevant to this litigation. Further, this request seeks information with regard to programs for Celanese employees and not as to contractors like plaintiff in this case. Subject to and without waiving this or any other specific or general objection, Celanese denies this request as stated. REQUEST FOR ADMISSION NO. 86 Admit that Celanese did not have any x-ray program to monitor pneumoconiosis in its employees in 1963. RESPONSE: Cdlanese objects to this request as overly broad in that it is not limited to the Celanese Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 30 98102 facility at issue in this litigation and thus seeks information not relevant to this litigation. Further, this request seeks information with regard to programs for Celanese employees and not as to contractors like.plaintiff in this case. Subject to and without waiving this or any other specific or general objection, Celanese denies this request as stated. REQUEST FOR ADMISSION NO. 87 Admit that'Celanese did not have any x-ray program to monitor pneumoconiosis in its employees in 1964. RESPONSE: Celanese objects to this request as overly broad in that it is not limited to the Celanese facility at issue in this litigation and thus seeks information not relevant to this litigation. Further, this request seeks information with regard to programs for Celanese employees and not as to contractors like plaintiff in this case. Subject to and without waiving this or any other specific or general objection, Celanese denies this request as stated. REQUEST FOR ADMISSION NO. 88 Admit that Celanese did not have any x-ray program to monitor pneumoconiosis in its employees in 1965. RESPONSE: Celanese objects to this request as overly broad in that it is not limited to the Celanese facility, at issue in this litigation and thus seeks information not relevant to this litigation. Further, this request seeks information with regard to programs for Celanese employees and not as to contractors like plaintiff in this case. Subject to and without waiving this or any other specific or general objection, Celanese denies this request as stated. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 31 98102 REQUEST FOR ADMISSION NO. 89 Admit that Ceianese did not have any x-ray program to monitor pneumoconiosis in its employees in 1966. RESPONSE: Ceianese objects to this request as overly broad in that it is not limited to the Ceianese facility at issue in this litigation and thus seeks infojjnation not relevant to this litigation. Further, this request seeks information with regard to programs for Ceianese employees and not as to contractors like plaintiff in this case. Subject to and without waiving this or any other specific or general objection, Ceianese denies this request as stated. REQUEST FOR ADMISSION NO. 90 Admit that Ceianese did not have any x-ray program to monitor pneumoconiosis in its employees in 1967. RESPONSE: Ceianese objects to this request as overly broad in that it is not limited to the Ceianese facility at issue in this litigation and thus seeks information not relevant to this litigation. Further, this request seeks information with regard to programs for Ceianese employees and not as to contractors like plaintiff in this case. Subject to and without waiving this or any other specific or general objection, Ceianese denies this request as stated. REQUEST FOR ADMISSION NO. 91 Admit that Ceianese did not have any x-ray program to monitor pneumoconiosis in its employees in 1968. RESPONSE: Ceianese objects to this request as overly broad in that it is not limited to the Ceianese facility at issue in this litigation and thus seeks information not relevant to this litigation. Ceianese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Ceianese Ltd. 32 98102 Further, this request seeks information with regard to programs for Celanese employees and not as to contractors like plaintiff in this case. Subject to and without waiving this or any other specific or general objection, Celanese denies this request as stated. REQUEST FOR ADMISSION NO. 92 Admit that Celanese did not have any x-ray program to monitor pneumoconiosis in its employees in 1969. RESPONSE: Celanese objects to this request as overly broad in that it is not limited to the Celanese facility at issue in this litigation and thus seeks information not relevant to.this, litigation. Further, this request seeks information with regard to programs for Celanese employees and not as to contractors like plaintiff in this case. Subject to and without waiving this or any other specific or general objection, Celanese denies this request as stated. REQUEST FOR ADMISSION NO. 93 Admit that Celanese did not have any x-ray program to monitor pneumoconiosis in its employees in 1970. RESPONSE: Celanese objects to this request as overly broad in that it is not limited to the Celanese facility at issue in this litigation and thus seeks information not relevant to this litigation. Further, this request seeks information with regard to programs for Celanese employees and not as to contractors like plaintiff in this case. Subject to and without waiving this or any other specific or general objection, Celanese denies this request as stated. REQUEST FOR ADMISSION NO. 94 Admit that Celanese did not have any x-ray program to monitor pneumoconiosis in its Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 33 98102 employees in 1971. RESPONSE: Celanese objects to this request as overly broad in that it is not limited to the Celanese facility at issue in this litigation and thus seeks information not relevant to this litigation. Further, this request seeks information with regard to programs for Celanese employees and not as to contractors like plaintiff in this case. Subject to and without waiving this or any other specific or general objection, Celanese denies this request as stated. REQUEST FOR ADMISSION NO. 95 Admit that Celanese did not have any x-ray program to monitor pneumoconiosis in its employees in 1972. RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside the time period at issue in this litigation. Further, the request is overly broad in that it is not limited to the Celanese facility at issue in this litigation. REQUEST FOR ADMISSION NO. 96 Admit that Celanese did not have any x-ray program to monitor pneumoconiosis in contractor employees in 1959. RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside the time period at issue in this litigation. Further, the request is overly broad in that it is not limited to the Celanese facility at issue in this litigation. REQUEST FOR ADMISSION NO. 97 Admit that Celanese did not have any x-ray program to monitor pneumoconiosis in contractor employees in 1960. RESPONSE: Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 34 98102 Celanese objects to this request as overly broad in that it seeks information outside the time period at issue in this litigation. Further, the request is overly broad in that it is not limited to the Celanese facility at issue in this litigation. REQUEST FOR ADMISSION NO. 98 Admit that Celanese did not have any x-ray program to monitor pneumoconiosis in contractor employees in 1961. ^ RESPONSE: Celanese objects to this request as overly broad in that it is not limited to the Celanese facility at issue in this litigation and thus seeks information not relevant to this litigation. Subject to and without waiving this or any other specific or general objection, Celanese admits this request but denies that it had any duty to provide such services to independent contractor companies. Celanese further states in connection with this response, that the obligation, if any, to provide x-ray programs for independent contractor employees would have rested with the independent contractor companies that employed them. REQUEST FOR ADMISSION NO. 99 > Admit that Celanese did not have any x-ray program to monitor pneumoconiosis in contractor employees in 1962. RESPONSE: Celanese objects to this request as overly broad in that it is not limited to the Celanese facility at issue in this litigation and thus seeks information not relevant to this litigation. Subject to and without waiving this or any other specific or general objection, Celanese admits this request but denies that it had any duty to provide such services to independent contractor companies. Celanese further states in connection with this response, that the obligation, if any, to provide x-ray programs for independent contractor employees would have rested with the independent contractor companies that employed them. REQUEST FOR ADMISSION NO. 100 Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 35 98102 Admit that Celanese did not have any x-ray program to monitor pneumoconiosis in contractor employees in 1963. RESPONSE: Celanese objects to this request as overly broad in that it is not limited to the Celanese facility at issue in this litigation and thus seeks information not relevant to this litigation. Subject to and without waiving this or any other specific or general objection, Celanese admits this request but denies that it had any duty to provide such services to independent contractor companies. Celanese further states in connection with this response, that the obligation, if any, to provide x-ray programs for independent contractor employees would have rested with the independent contractor companies that employed them. I REQUEST FOR ADMISSION NO. 101 Admit that Celanese did not have any x-ray program to monitor pneumoconiosis in contractor employees in 1964. RESPONSE: Celanese objects to this request as overly broad in that it is not limited to the Celanese facility at issue in this litigation and thus seeks information not relevant to this litigation. Subject to and without waiving this or any other specific or general objection, Celanese admits this request but denies that it had any duty to provide such services to independent contractor companies. Celanese further states in connection with this response, that the obligation, if any, to provide x-ray programs for independent contractor employees would have rested with the independent contractor companies that employed them. REQUEST FOR ADMISSION NO. 102 Admit that Celanese did not have any x-ray program to monitor pneumoconiosis in contractor employees in 1965. RESPONSE: Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 36 98102 Celanese objects to this request as overly broad in that it is hot limited to the Celanese facility at issue in this litigation and thus seeks information not relevant to this litigation. Subject to and without waiving this or any other specific or general objection, Celanese admits this request but denies that it had any duty to provide such services to independent contractor companies. Celanese further states in connection with this response, that the obligation, if any, to provide x-ray programs for independent contractor employees would have rested with the independent contractor companies that employed them. REQUEST FOR ADMISSION NO. 103 Admit that Celanese did not have any x-ray program to rhonitor pneumoconiosis in contractor employees in 1966. RESPONSE: Celanese objects to this request as overly broad in that it is not limited to the Celanese facility at issue in this litigation and thus seeks information not relevant to this litigation. Subject to and without waiving this or any other specific or general objection, Celanese admits this request but denies that it had any duty to provide such services to independent contractor companies. Celanese further states in connection with this response, that the obligation, if any, to provide x-ray programs for independent contractor employees would have rested with the independent contractor companies that employed them. REQUEST FOR ADMISSION NO. 104 Admit that Celanese did not have any x-ray program to monitor pneumoconiosis in contractor employees in 1967. * RESPONSE: Celanese objects to this request as overiy broad in that it is not limited to the Celanese facility at issue in this litigation and thus seeks information not relevant to this litigation. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 37 98102 Subject to and without waiving this or any other specific or general objection, Celanese admits this request but denies that it had any duty to provide such services to independent contractor companies. Celanese further states in connection with this response, that the obligation, if any, to provide x-ray programs for independent contractor employees would have rested with the independent contractor companies that employed them. REQUEST FOR ADMISSION NO. 105 ^ Admit that- Celanese did not have any x-ray program to monitor pneumoconiosis in contractor employees in 1968. RESPONSE: Celanese objects to this request as overly broad in that it is not limited to the Celanese facility at issue in this litigation and thus seeks information not relevant to this litigation. Subject to and without waiving this or any other specific or general objection, Celanese admits this request but denies that it had any duty to provide such services to independent contractor companies. Celanese further states in connection with this response, that the obligation, if any, to provide x-ray programs for independent contractor employees would have rested with the independent contractor companies that employed them. REQUEST FOR ADMISSION NO. 106 Admit that Celanese did not have any x-ray program to monitor pneumoconiosis in contractor employees in 1969. RESPONSE: Celanese objects to this request as overly broad in that it is not limited to the Celanese facility at issue in this litigation and thus seeks information not relevant to this litigation. Subject to and without waiving this or any other specific or general objection, Celanese admits this request but denies that it had any duty to provide such services to independent contractor companies. Celanese further states in connection with this response, that the obligation, if any, to provide x-ray programs for independent contractor employees would have rested with the independent contractor companies Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 38 98102 that employed them. REQUEST FOR ADMISSION NO. 107 Admit that Celanese did not have any x-ray program to monitor pneumoconiosis in contractor employees in 1970. RESPONSE: Celanese objects to this request as overly broad in that it is not limited to the Celanese facility at issue in this litigation and thus seeks information not relevant to this litigation. Subject to and without waiving this or any other specific or general objection, Celanese admits this request but denies that it had any duty to provide such services to independent contractor companies. Celanese further states in connection with this response, that the obligation, if any, to provide x-ray programs for independent contractor employees would have rested with the independent contractor companies that employed them. REQUEST FOR ADMISSION NO. 108 Admit that Celanese did not have any x-ray program to monitor pneumoconiosis in. contractor employees in 1971. RESPONSE: Celanese objects to this request as overly broad in that it is not limited to the Celanese facility at issue in this litigation and thus seeks information not relevant to this litigation. Subject to and without waiving this or any other specific or general objection, Celanese admits this request but denies that it had any duty to provide such services to independent contractor companies. Celanese further states in connection with this response, that the obligation, if any, to provide x-ray programs for independent contractor employees would have rested with the independent contractor companies that employed them. REQUEST FOR ADMISSION NO. 109 Admit that Celanese did not have any x-ray program to monitor pneumoconiosis in contractor employees in 1972. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 39 98102 RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside the time period at issue in this litigation. Further, the request is overly broad in that it is not limited to the Celanese facility at issue in this litigation. REQUEST FOR ADMISSION NO. 110 Admit that Celanese did not have any program to prevent employees from contracting asbestosisin 1959. RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside of the time period at issue in this litigation and further in that it i not limited to the specific Celanese facility at issue in this litigation. The request therefore calls for information not relevant to this litigation. REQUEST FOR ADMISSION NO. Ill Admit that Celanese did not have any program to prevent employees from contracting asbestosis in 1960. RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside of the time period at issue in this litigation and further in that it is not limited to the specific Celanese facility at issue in this litigation. The request therefore calls for information not relevant to this litigation. REQUEST FOR ADMISSION NO. 112 Admit that Celanese did not have any program to prevent employees from contracting asbestosis in 1961 RESPONSE: Celanese objects to this request in that it is vague and ambiguous. Further, this request is overly broad in that it is not limited to the Celanese facility at issue in this litigation. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 40 98102 The request also seeks information regarding programs for Ceianese employees as opposed to contractors like plaintiff and thus calls for information not relevant to this litigation. Subject to and without waiving this or any other specific or general objection, Ceianese denies this request as stated. REQUEST FOR ADMISSION NO. 113 Admit that Ceianese did not have any program to prevent employees from contracting asbestosis in 1962 RESPONSE: Ceianese objects to this request in that it is vague and ambiguous. Further, this request is overly broad in that it is not limited to the Ceianese facility at issue in this litigation. The request also seeks information regarding programs for Ceianese employees as opposed to contractors like plaintiff and thus calls for information not relevant to this litigation. Subject to and without waiving this or any other specific or general objection, Ceianese denies this request as stated. REQUEST FOR ADMISSION NO. 114 Admit that Ceianese did not have any program to prevent employees from contracting asbestosis in 1963. RESPONSE: Ceianese objects to this request in that it is vague and ambiguous. Further, this request is overly broad in that it is not limited to the Ceianese facility at issue in this litigation. The request also seeks information regarding programs for Ceianese employees as opposed to contractors like plaintiff and thus calls for information not relevant to this litigation. Subject to and without waiving this or any other specific or general objection, Ceianese denies this request as stated. Ceianese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Ceianese Ltd. 41 98102 REQUEST FOR ADMISSION NO. 115 Admit that Celanese did not have any program to prevent employees from contracting asbestosis in 1964 RESPONSE: Celanese objects to this request in that it is vague and ambiguous. Further, this request is overly broad in that it is not limited to the Celaj^ese facility at issue in this litigation. The request also seeks information regarding programs for Celanese employees as opposed to contractors like plaintiff and thus calls for information not relevant to this litigation. - Subject to and without waiving this or any other specific or general objection, Celanese denies this request as stated. .... REQUEST FOR ADMISSION NO. 116 Admit that Celanese did not have any program to prevent employees from contracting asbestosis in 1965. RESPONSE: Celanese objects to this request in that it is vague and ambiguous. Further, this request is overly broad in that it is not limited to the Celanese facility at issue in this litigation. The request also seeks information regarding programs for Celanese employees as opposed to contractors like plaintiff and thus calls for information not relevant to this litigation. Subject to and without waiving this or any other specific or general objection, Celanese denies this request as stated. REQUEST FOR ADMISSION NO. 117 Admit that Celanese did not have any program to prevent employees from contracting asbestosis in 1966. RESPONSE: Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 42 98102 Celanese objects to this request in that it is vague and ambiguous. Further, this request is overly broad in that it is not limited to the Celanese facility at issue in this litigation. The request also seeks information regarding programs for Celanese employees as opposed to contractors like plaintiff and thus calls for information not relevant to this litigation. Subject to and without waiving this or any other specific or general objection, Celanese denies this request as stated. REQUEST FOR ADMISSION NO. 118 Admit that Celanese did not have any program to prevent employees from contracting asbestosis in 1967. RESPONSE: Celanese objects to this request in that it is vague and ambiguous. Further, this request is overly broad in that it is not limited to the Celanese facility at issue in this litigation. The request also seeks information regarding programs for Celanese employees as opposed to contractors like plaintiff and thus calls for information not relevant to this litigation. Subject to and without waiving this or any other specific or general objection, Celanese denies this request as stated. REQUEST FOR ADMISSION NO. 119 Admit that Celanese did not have any program to prevent employees from contracting asbestosis in 1968. RESPONSE: Celanese objects to this request in that it is vague and ambiguous. Further, this request is overly broad in that it is not limited to the Celanese facility at issue in this litigation. The request also seeks information regarding programs for Celanese employees as opposed to contractors like plaintiff and thus calls for information not relevant to this litigation. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 43 98102 Subject to and without waiving this or any other specific or general objection, Celanese denies this request as stated. REQUEST FOR ADMISSION NO. 120 Admit that Celanese did not have any program to prevent employees from contracting asbestosis in 1969. RESPONSE: _ Celanese objects to this request in that it is vague and ambiguous. Further, this request is overly broad in that it is not limited to the Celanese facility at issue in this litigation. The request also seeks information regarding programs for Celanese employees as opposed to contractors like plaintiff and thus calls for information not relevant to this litigation. Subject to and without waiving this or any other specific or general objection, Celanese denies this request as stated. REQUEST FOR ADMISSION NO. 121 Admit that Celanese did not have any program to prevent employees from contracting asbestosis in 1970. RESPONSE: Celanese objects to this request in that it is vague and ambiguous. Further, this request is overly broad in that it is not limited to the Celanese facility at issue in this litigation. The request also seeks information regarding programs for Celanese employees as opposed to contractors like plaintiff and thus calls for information not relevant to this litigation. Subject to and without waiving this or any other specific or general objection, Celanese denies this request as stated. REQUEST FOR ADMISSION NO. 122 Admit that Celanese did not have any program to prevent employees from contracting Celanese LtcL's Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 44 98102 asbestosis in 1971. RESPONSE: Celanese objects to this request in that it is vague and ambiguous. Further, this request is overly broad in that it is not limited to the Celanese facility at issue in this litigation. The request also seeks information regarding programs for Celanese employees as opposed to contractors like plaintiff and thus calls for information not relevant to this litigation. Subject to and without waiving this or any other specific or general objection, Celanese denies this request as stated. R' EQUEST FOR ADMISSION NO. 123 ?' Admit that Celanese did not have any program to prevent employees from contracting asbestosis in 1972. RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside the time period at issue in this litigation. Further, the request is overly broad in that it is not limited to the Celanese facility at issue in this litigation. REQUEST FOR ADMISSION NO. 124 Admit that Celanese did not have any program to prevent contractor employees from contracting asbestosis in 1959. RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside the time period at issue in this litigation. Further, the request is overly broad in that it is not limited to the Celanese facility at issue in this litigation. REQUEST FOR ADMISSION NO. 125 Admit that Celanese did not have any program to prevent contractor employees from contracting asbestosis in 1960. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 45 98102 RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside the time period at issue in this litigation. Further, the request is overly broad in that it is not limited to the Celanese facility at issue in this litigation. REQUEST FOR ADMISSION NO. 126 Admit that Celanese did not have any program tffprevent contractor employees from contracting asbestosis in 1961. RESPONSE: Celanese objects to this request in that it is vague and ambiguous. Further, this request is overly broad in that it is not limited to the Celanese facility af issue in this litigation. Subject to and without waiving this or any other specific or general objection, Celanese admits this request but denies that it had any duty to provide such program to independent contractor companies. However, Celanese further states in connection with this response that steps would have been taken in its plants that would have been useful in helping to prevent dust-related health problems. See also the responses to Requests for Admission Nos. 70-80, and Nos. 112-124, above. REQUEST FOR ADMISSION NO. 127 Admit that Celanese did not have any program to prevent contractor employees from contracting asbestosis in 1962. RESPONSE: Celanese objects to this request in that it is vague and ambiguous. Further, this request is overly broad in that it is not limited to the Celanese facility at issue in this litigation. Subject to and without waiving this or any other specific or general objection, Celanese admits this request but denies that it had any duty to provide such program to independent contractor companies. However, Celanese further states in connection with this response that steps would have been taken in its plants that would have been useful in helping to prevent dust-related health problems. See also the responses to Requests for Admission Nos. 70-80, and Nos. 112-124, above. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 46 98102 REQUEST FOR ADMISSION NO. 128 Admit that Celanese did not have any program to prevent contractor employees from contracting asbestosis in 1963. RESPONSE: Celanese objects to this request in that it is vague.and ambiguous. Further, this request is overly broad in that it is not limited to the Celanese facility at issue in this litigation. Subject to and without waiving this or any other specific or general objection, Celanese admits this request but denies that it had any duty to provide such program to independent contractor companies. However, Celanese further states in connection with this response that steps would have been taken in its plants that would have been useful in helping to prevent dust-related health problems. See also the responses to Requests for Admission Nos. 70-80, and Nos. 112-124, above. REQUEST FOR ADMISSION NO. 129 Admit that Celanese did not have any program to prevent contractor employees from contracting asbestosis in 1964. RESPONSE: Celanese objects to this request in that it is vague and ambiguous. Further, this request is overly broad in that it is not limited to the Celanese facility at issue in this litigation. Subject to and without waiving this or any other specific or general objection, Celanese admits this request but denies that it had any duty to provide such program to independent contractor companies. However, Celanese further states in connection with this response that steps would have been taken in its plants that would have been useful in helping to prevent dust-related health problems. See also the responses to Requests for Admission Nos. 70-80, and Nos. 112-124, above. REQUEST FOR ADMISSION NO. 130 Admit that Celanese did not have any program to prevent contractor employees from conitracting asbestosis in 1965. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 47 98102 RESPONSE: Celanese objects to this request in that it is vague and ambiguous. Further, this request is overly broad in that it is not limited to the Celanese facility at issue in this litigation. Subject to and without waiving this or any other specific or general objection, Celanese admits this request but denies that it had any duty to provide such program to independent contractor companies. However, Celanese further states in connection with this response that steps would have been taken in its plants that would have been useful in helping to prevent dust-related health p'roblems. See also the responses to Requests for Admission Nos. 70-80, and Nos. 112-124, above. REQUEST FOR ADMISSION NO. 131 Admit that Celanese did not have any program to prevent contractor employees from contracting asbestosis in 1966. ' RESPONSE: Celanese objects to this request in that it is vague and ambiguous. Further, this request is overly broad in that it is not limited to the Celanese facility at issue in this litigation. Subject to and without waiving this or any other specific or general objection, Celanese admits this request but denies that it had any duty to provide such program to independent contractor companies. However, Celanese further states in connection with this response that steps would have been taken in its plants that would have been useful in helping to prevent dust-related health problems. See also the responses to Requests for Admission Nos. 70-80, and Nos. 112-124, above. REQUEST FOR ADMISSION NO. 132 Admit that Celanese did not have any program to prevent contractor employees from contracting asbestosis in 1967. RESPONSE: Celanese objects to this request in that it is vague and ambiguous. Further, this request is overly broad in that it is not limited to the Celanese facility at issue in this litigation. Subject to and without waiving this or any other specific or general objection, Celanese Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 48 98102 admits this request but denies that it had any duty to provide such program to independent contractor companies. However, Celanese further states in connection with this response that steps would have been taken in its plants that would have been useful in helping to prevent dust-related health problems. See also the responses to Requests for Admission Nos. 70-80, and Nos. 112-124, above. REQUEST FOR ADMISSION NO. 133 Admit that Celanese did not have any program to prevent contractor employees from contracting asbestosis in 1968. RESPONSE: Celanese objects to this request in that it is vague and ambiguous. Further, this request is overly broad in that it is not limited to the Celanese facility at issue in this litigation. Subject to and without waiving this or any other specific or general objection, Celanese admits this request but denies that it had any duty to provide such program to independent contractor companies. However, Celanese further states in connection with this response that steps would have been taken in its plants that would have been useful in helping to prevent dust-related health problems. See also the responses to Requests for Admission Nos. 70-80, and Nos. 112-124, above. REQUEST FOR ADMISSION NO. 134 Admit that Celanese did not have any program to prevent contractor employees from contracting asbestosis in 1969. RESPONSE: Celanese objects to this request in that it is vague and ambiguous. Further, this request is overly broad in that it is not limited to the Celanese facility at issue in this litigation. Subject to and without waiving this or any other specific or general objection, Celanese admits this request but denies that it had any duty to provide such program to independent contractor companies. However, Celanese further states in connection with this response that steps would have been taken in its plants that would have been useful in helping to prevent dust-related health problems. See also the responses to Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 49 98102 Requests for Admission Nos. 70-80, and Nos. 112-124, above. REQUEST FOR ADMISSION NO. 135 Admit that Celanese did not have any program to prevent contractor employees from contracting asbestosis in 1970. RESPONSE: Celanese objects to this request in that it is vague and ambiguous. Further, this request is overly broad in that it is not limited to the Celanese facility at issue in this litigation. Subject to and without waiving this or any other specific or general objection, Celanese admits this request but denies that it had any duty to provide such program to independent contractor companies. However, Celanese fufther states in connection with this response that steps would have been taken in its plants that would have been useful in helping to prevent dust-related health problems. See also the responses to Requests for Admission Nos. 70-80, and Nos. 112-124, above. REQUEST FOR ADMISSION NO. 136 Admit that Celanese did not have any program to prevent contractor employees from contracting asbestosis in 1971. RESPONSE: Celanese objects to this request in that it is vague and ambiguous. Further, this request is overly broad in that it is not limited to the Celanese facility at issue in this litigation. Subject to and without waiving this or any other specific or general objection, Celanese admits this request but denies that it had any duty to provide such program to independent contractor companies. However, Celanese further states in connection with this response that steps would have been taken in its plants that would have been useful in helping to prevent dust-related health problems. See also the responses to Requests for Admission Nos. 70-80, and Nos. 112-124, above. REQUEST FOR ADMISSION NO. 137 Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 50 98102 Admit that Celanese did not have any program to prevent contractor employees from contracting asbestosis in 1972. RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside the time period at issue in this litigation. Further, the request is overly broad in that it is not limited to the Celanese facility at issue in this litigation. REQUEST FOR ADMISSION NO. 139 Admit that Celanese employee Dr. Ernest Dixon attended the 1964 New York Academy of Sciences meeting. * RESPONSE: Admitted REQUEST FOR ADMISSION NO. 140 Admit that Celanese employee Dr. Ernest Dixon attended the presentation of Dr. Selikoff on his findings regarding asbestos-related cancer at the 1964 New York Academy of Sciences meeting. RESPONSE: Celanese admits only that Dr. Dixon, who was not its employee at the time, attended some number of the presentations made at the 1964 New York Academy of Sciences meeting. REQUEST FOR ADMISSION NO. 141 Admit that Celanese safety personnel held contractors to the same safety standards to which Celanese employees were held. RESPONSE: Celanese objects to this request as vague and ambiguous. Further, this request is not Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 51 98102 properly limited to the time period or the specific Celanese facility at issue in this litigation. Subject to and without waiving this or any other specific or general objection,, Celanese admits only that independent contractor companies on its premises, as a matter of contract, were obligated to follow all state and federal laws and also to comply with all plant policies and safety rules. At all times, however, ultimate responsibility rested with the independent contractor companies to provide a safe workplace for their own employees. REQUEST FOR ADMISSION NO. 142 Admit that Celanese safety personnel determined which safety equipment contractor employees would be required to utilize. RESPONSE: Celanese objects to this request as vague and ambiguous. Further, this request is not properly limited to the time period or the specific Celanese facility at issue in this litigation. Further, this request is duplicative of Interrogatory No. 11 of plaintiff's First set of Interrogatories to Celanese. Subject to and without waiving this or any other specific or general objection, denied as stated. REQUEST FOR ADMISSION NO. 143 Admit that Celanese employees made contractor employees abide by Celanese safety rules. RESPONSE: Celanese objects to this request as vague and ambiguous. Further, this request is not properly limited to the time period or the specific Celanese facility at issue in this litigation. Subject to and without waiving this or any other specific or general objection, denied as stated. Celanese further states in connection with this response, that if it observed Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 52 98102 independent contractor employees in violation of established safety rules, the matter ordinarily would be reported to the independent contractor's supervisors for them to take appropriate corrective action^ REQUEST FOR ADMISSION NO. 144 Admit that Celanese safety personnel had the power to enforce Celanese safety rules against contractors in the Bishop plant. RESPONSE: Celanese objects to this request as vague and ambiguous. Further, this request is not properly limited to the time period at issue in this litigation. Subject to and without waiving this or any other specific or general objection, admitted with regard to independent contractors at the plant. See alsd, response to Request for Admission No. 143, above. REQUEST FOR ADMISSION NO. 145 Admit that Celanese had the power to expel contractors who did not comply with Celanese's safety rules. RESPONSE: Celanese objects to this request as vague and ambiguous. Further, this request is not properly limited to the time period and/or plant at issue in this litigation. Subject to and without waiving this or any other specific or general objection, admitted. REQUEST FOR ADMISSION NO. 146 Admit that Celanese had the power to shut down the contractors who did not comply with Celanese' safety rules. RESPONSE: Celanese objects to this request as vague and ambiguous. Further, this request is not properly limited to the time period and/or plant at issue in this litigation. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 53 98102 Subject to and without waiving this or any other specific or general objection, admitted. REQUEST FOR ADMISSION NO. 147 Admit that Celanese placed air monitoring equipment on Arthur Brothers, lnc.( ABI) contractor employees at the Bishop facility. RESPONSE: Celanese objects to this request as vague and ambiguous. Further, this request is not properly limited to the time period at issue in this litigation. Subject to and without waiving this or any other specific or general objection, Celanese admits that it from time to time conducted air monitoring of Arthur Brothers employees at the Bishop plant. Celanese further states in connection with'this response that it also helped train Arthur Brothers to do its own air monitoring of Arthur Brothers employees. REQUEST FOR ADMISSION NO. 148 Admit that Celanese did not notify ABI employees of any results of the air monitoring at the Bishop facility. RESPONSE: Celanese objects to this request as vague and ambiguous. Further, this request is not properly limited to the time period at issue in this litigation. Subject to and without waiving this or any other specific or general objection, denied. REQUEST FOR ADMISSION NO. 149 Admit that Celanese placed air monitoring equipment at the contractor work insulation fabrication shop at the Bishop facility. RESPONSE: Celanese objects to this request as vague and ambiguous. Further, this request is outside the relevant time period in this litigation. REQUEST FOR ADMISSION NO. 150 Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 54 98102 Admit that in 1972 a contractor insulation fab shop air monitoring included dust counts that overloaded the sample filters, despite the addition of vacuum equipment. RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside of the time period at issue in this litigation and further in that it is not limited to the specific Celanese facility at issue in this litigation. The request therefore calls for information not relevant to this litigation. REQUEST FOR ADMISSION NO. 151 Admit that Celanese place air monitors on ABI employees who were removing asbestos-containing insulation from pipes. RESPONSE: Celanese objects to this request as vague, ambiguous and overly broad. Further, the request is outside the relevant time period in this litigation and is not limited to the specific Celanese facility at issue in this litigation. Subject to and without waiving this or any other specific or general objection, Celanese admits that from time to time it conducted air monitoring of Arthur Brothers employees removing asbestos-containing insulation form pipes. Celanese further states in connection with this response that it also helped train Arthur Brothers to do its own air monitoring of Arthur Brothers employees. REQUEST FOR ADMISSION NO. 152 Admit that Celanese provided goods and services to the United States government that totaled over $10,000 in value in 1950. RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside of the time period at issue in this litigation and further in that it is not limited to the specific Celanese facility at issue in this litigation. The request therefore calls for information not Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 55 98102 relevant to this litigation. REQUEST FOR ADMISSION NO. 153 Admit that Celanese provided goods and services to the United States government that totaled over $10,000 in value in 1951. RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside of the time period at issue in this litigation and further in that it is not limited to the specific Celanese facility at issue in this litigation. The request therefore calls for information not relevant to this litigation. REQUEST FOR ADMISSION NO. 154 Admit that Celanese provided goods and services to the United States government that totaled over $10,000 in value in 1952. RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside of the time period at issue in this litigation and further in that it is not limited to the specific Celanese facility at issue in this litigation. The request therefore calls for information not relevant to this litigation. REQUEST FOR ADMISSION NO. 155 Admit that Celanese provided goods and services to the United States government that totaled over $10,000 in value in 1953. RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside of the time period at issue in this litigation and further in that it is not limited to the specific Celanese facility at issue in this litigation. The request therefore calls for information not relevant to this litigation. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 56 98102 REQUEST FOR ADMISSION NO, 156 Admit that Celanese provided goods and services to the United States government that totaled over $10,000 in value in 1954. RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside of the time period at issue in this litigation and furtheun that it is not limited to the specific Celanese facility at issue in this litigation. The request therefore calls for information not relevant todhis litigation. REQUEST FOR ADMISSION NO. 157 Admit that Celanese provided goods and sen/ices to the United States government that totaled over $10,000 in value in 1955. RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside of the time period at issue in this litigation and further in that it is not limited to the specific Celanese facility at issue in this litigation. The request therefore calls for information not relevant to this litigation. REQUEST FOR ADMISSION NO. 158 Admit that Celanese provided goods and services to the United States government that totaled over $10,000 in value in 1956. RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside of the time period at issue in this litigation and further in that it is not limited to the specific Celanese facility at issue in this litigation. The request therefore calls for information not relevant to this litigation. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 57 98102 REQUEST FOR ADMISSION NO. 159 Admit that Celanese provided goods and services to the United States government that totaled over $10,000 in value in 1957. RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside of the time period at issue in this litigation and furthejnn that it is not limited to the specific Celanese facility at issue in this litigation. The request therefore calls for information not relevant to this litigation. REQUEST FOR ADMISSION NO. 160 Admit that Celanese provided goods and services to the United States government that totaled over $10,000 in value in 1958. RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside of the time period at issue in this litigation and further in that it is not limited to the specific Celanese facility at issue in this litigation. The request therefore calls for information not relevant to this litigation. REQUEST FOR ADMISSION NO. 161 Admit that Celanese provided goods and services to the United States government that totaled over $10,000 in value in 1959. RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside of the time period at issue in this litigation and further in that it is not limited to the specific Celanese facility at issue in this litigation. The request therefore calls for information not relevant to this litigation. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 58 98102 REQUEST FOR ADMISSION NO. 162 Admit that Celanese provided goods and services to the United States government that totaled over $10,000 in value in 1960. RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside of the time period at issue in this litigation and furthered that it is not limited to the specific Celanese facility at issue in this litigation. The request therefore calls for information not relevant to this litigation. REQUEST FOR ADMISSION NO. 163 Admit that Celanese provided goods and services to the United States government that totaled over $10,000 in value in 1961. RESPONSE: Celanese objects to this request in that it seeks information not relevant to this litigation and not reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving this or any other specific or general objection, Celanese, on present information, can neither admit nor deny this request. REQUEST FOR ADMISSION NO. 164 Admit that Celanese provided goods and services to the United States government that totaled over $10,000 in value in 1962. RESPONSE: Celanese objects to this request in that it seeks information not relevant to this litigation and not reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving this or any other specific or general objection, Celanese, on present information, can neither admit nor deny this request. t Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 59 98102 REQUEST FOR ADMISSION NO. 165 Admit that Celanese provided goods and services to the United States government that totaled over $10,000 in value in 1963. RESPONSE: Celanese objects to this request in that it seeks information not relevant to this litigation and not reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving this or any other specific or general objection, Celanese, on present information, can neither admit nor deny this request. REQUEST FOR ADMISSION NO. 166 Admit that Celanese provided goods and services to the United States government that totaled over $10,000 in value in 1964. RESPONSE: Celanese objects to this request in that it seeks information not relevant to this litigation and not reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving this or any other specific or general objection, Celanese, on present information, can neither admit nor deny this request. REQUEST FOR ADMISSION NO. 167 Admit that Celanese provided goods and services to the United States government that totaled over $10,000 in value in 1965. RESPONSE: Celanese objects to this request in that it seeks information not relevant to this litigation and not reasonably calculated to lead to the discovery of admissible evidence. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 60 98102 Subject to and without waiving this or any other specific or general objection, Celanese, on present information, can neither admit nor deny this request. REQUEST FOR ADMISSION NO. 168 Admit that Celanese provided goods and services to the United States government that totaled over $10,000 in value in 1966. ^ RESPONSE: Celanese objects to this request in that it seeks information not relevant to this litigation and not reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving this or any other specific or general objection, Celanese, on present information, can neither admit nor deny this request. REQUEST FOR ADMISSION NO. 169 Admit that Celanese provided goods and services to the United States government that totaled over $10,000 in value in 1967. RESPONSE: Celanese objects to this request in that it seeks information not relevant to this litigation and not reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving this or any other specific or general objection, Celanese, on present information, can neither admit nor deny this request. REQUEST FOR ADMISSION NO. 170 Admit that Celanese provided goods and services to the United States government that totaled over $10,000 in value in 1968. RESPONSE: Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 61 98102 Celanese objects to this request in that it seeks information not relevant to this litigation and not reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving this or any other specific or general objection, Celanese, on present information, can neither admit nor deny this request. REQUEST FOR ADMISSION NO. 171 Admit that Celanese provided goods and services to the United States government that totaled over $10,000 in value in 1969. RESPONSE: Celanese objects to this request in that it seeks information not relevant to this litigation and not reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving this or any other specific or general objection, Celanese, on present information, can neither admit nor deny this request. REQUEST FOR ADMISSION NO. 172 Admit that Celanese provided goods and services to the United States government that totaled over $10,000 in value in 1970. RESPONSE: Celanese objects to this request in that it seeks information not relevant to this litigation and not reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving this or any other specific or general objection, Celanese, on present information, can neither admit nor deny this request. REQUEST FOR ADMISSION NO. 173 Admit that Celanese owned and operated the facility in Bishop, Texas from 1959-1972. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 62 98102 RESPONSE: Admitted REQUEST FOR ADMISSION NO. 174 Admit that Plaintiff was employed by Arthur Brothers, Inc. (ABI) in 1959. RESPONSE: Celanese objects to this request in that it seeks information that is within the knowledge of plaintiff, not Celanese, and of which Celanese has no independent verification. Further, this request is not limited to the time period at issue in this litigation. Subject to and without waiving this or any other specific or general objection, Celanese denies this request based upon plaintiff's testimony. ' REQUEST FOR ADMISSION NO. 175 Admit that Plaintiff was employed by Arthur Brothers, Inc. (ABI) in 1960. RESPONSE: Celanese objects to this request in that it seeks information that is within the knowledge of plaintiff, not Celanese, and of which Celanese has no independent verification. Further, this request is not limited to the time period at issue in this litigation. Subject to and without waiving this or any other specific or general objection, Celanese denies this request based upon plaintiff's testimony. REQUEST FOR ADMISSION NO. 176 Admit that Plaintiff was employed by Arthur Brothers, Inc. (ABI) in 1961. RESPONSE: Celanese objects to this request in that it seeks information that is within the knowledge of plaintiff, not Celanese, and of which Celanese has no independent verification. Subject to and without waiving this or any other specific or general objection, Celanese Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 63 98102 . admits that plaintiff testified at his deposition that he was employed by Arthur Brothers during the stated time period. REQUEST FOR ADMISSION NO. 177 Admit that Plaintiff was employed by Arthur Brothers, Inc. (ABI) in 1962. RESPONSE: Celanese objects to this request in that it seeks information that is within the knowledge of plaintiff, not Celanese, and of which Celanese has no independent verification. Subject to and without waiving this or any other specific or general objection, Celanese admits that plaintiff testified at his deposition that he was employed by Arthur Brothers during the stated time period. ' REQUEST FOR ADMISSION NO. 178 Admit that Plaintiff was employed by Arthur Brothers, Inc. (ABI) in 1963. RESPONSE: Celanese objects to this request in that it seeks information that is within the knowledge of plaintiff, not Celanese, and of which Celanese has no independent verification. Subject to and without waiving this or any other specific or general objection, Celanese admits that plaintiff testified at his deposition that he was employed by Arthur Brothers during the stated time period. REQUEST FOR ADMISSION NO. 179 Admit that Plaintiff was employed by Arthur Brothers, Inc. (ABI) in 1964. RESPONSE: Celanese objects to this request in that it seeks information that is within the knowledge of plaintiff, not Celanese, and of which Celanese has no independent verification. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 64 98102 Subject to and without waiving this or any other specific or general objection, Celanese admits that plaintiff testified at his deposition that he was employed by Arthur Brothers during the stated time period. REQUEST FOR ADMISSION NO. 180 Admit that Plaintiff was employed by Arthur Brother^ Inc. (ABI) in 1965. RESPONSE: Celanese objects to this request in that it seeks information that is within the knowledge of plaintiff, not Celanese, and of which Celanese has no independent verification. . Subject to and without waiving this or any other specific or general objection, Celanese admits that plaintiff testified at his deposition that he was employed by Arthur Brothers during the stated time period. REQUEST FOR ADMISSION NO. 181 Admit that Plaintiff was employed by Arthur Brothers, Inc. (ABI) in 1966. RESPONSE: Celanese objects to this request in that it seeks information that is within the knowledge of plaintiff, not Celanese, and of which Celanese has no independent verification. Subject to and without waiving this or any other specific or general objection, Celanese admits that plaintiff testified at his deposition that he was employed by Arthur Brothers during the stated time period. REQUEST FOR ADMISSION NO. 182 Admit that Plaintiff was employed by Arthur Brothers, Inc. (ABI) in 1967. RESPONSE: Celanese objects to this request in that it seeks information that is within the knowledge Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 65 98102 of plaintiff, not Celanese, and of which Celanese has no independent verification. Subject to and without waiving this or any other specific or general objection, Celanese admits that plaintiff testified at his deposition that he was employed by Arthur Brothers during the stated time period. REQUEST FOR ADMISSION NO. 183 Admit that Plaintiff was employed by Arthur Brothers, Inc. (ABI) in 1968. RESPONSE: Celanese objects to this request in that it seeks information that is within the knowledge of plaintiff, not Celanese, and of which Celanese has no independent verification. Subject to and without waiving this or any other specific or general objection, Celanese admits that plaintiff testified at his deposition that he was employed by Arthur Brothers during the stated time period. REQUEST FOR ADMISSION NO. 184 Admit that Plaintiff was employed by Arthur Brothers, Inc. (ABI) in 1969. RESPONSE: Celanese objects to this request in that it seeks information that is within the knowledge of plaintiff, not Celanese, and of which Celanese has no independent verification. Subject to and without waiving this or any other specific or general objection, Celanese admits that plaintiff testified at his deposition that he was employed by Arthur Brothers during the stated time period. REQUEST FOR ADMISSION NO. 185 Admit that Plaintiff was employed by Arthur Brothers, Inc. (ABI) in 1970. RESPONSE: Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 66 98102 Celanese objects to this request in that it seeks information that is within the knowledge of plaintiff, not Celanese, and of which Celanese has no independent verification. Subject to and without waiving this or any other specific or general objection, Celanese cannot either admit or deny this request based on the ambiguity and conflict in plaintiff's deposition testimony. REQUEST FOR ADMISSION NO. 186 Admit that Plaintiff was employed by Arthur Brothers, Inc. (ABI) in 1971. RESPONSE: Celanese objects to this request in that it seeks information that is within the knowledge of plaintiff, not Celanese, and of which Celanese has no independent verification. Subject to and without waiving this or any other specific or general objection, Subject to and without waiving this or any other specific or general objection, Celanese cannot either admit or deny this request based on the ambiguity and conflict in plaintiff's deposition testimony. REQUEST FOR ADMISSION NO. 187 Admit that Plaintiff was employed by Arthur Brothers, Inc. (ABI) in 1972. RESPONSE: Celanese objects to this request in that it seeks information that is within the knowledge of plaintiff, not Celanese, and of which Celanese has no independent verification. Further, this request is outside the time period at issue in this litigation. Subject to and without waiving this or any other specific or general objection, Celanese denies this request based upon plaintiff's testimony. REQUEST FOR ADMISSION NO. 188 t Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 67 98102 Admit that Celanese contracted with ABI to provide services at its Bishop, Texas facility in 1959. RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside the time period at issue in this litigation. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. ^ REQUEST FOR ADMISSION NO. 189 Admit that Celanese contracted with ABI to provide services at its Bishop, Texas facility in 1960. RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside the time period at issue in this litigation. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 190 Admit that Celanese contracted with ABI to provide services at its Bishop, Texas facility in 1961. RESPONSE: Celanese objects to this request as vague and ambiguous. Subject to and without waiving this or any other specific or general objection, Celanese admits that it contracted with Arthur Brothers to provide independent contractor services at the Bishop plant during the stated period. REQUEST FOR ADMISSION NO. 191 Admit that Celanese contracted with ABI to provide services at its Bishop, Texas facility in 1962. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 68 98102 RESPONSE: Celanese objects to this request as vague and ambiguous. Subject to and without waiving this or any other specific or general objection, Celanese admits that it contracted with Arthur Brothers to provide independent contractor services at the Bishop plant during the stated period. REQUEST FOR ADMISSION NO. 192 Admit that Celanese contracted with ABI to provide services at its Bishop, Texas facility in 1963. RESPONSE: Celanese objects to this request as vague and ambiguous*. Subject to and without waiving this or any other specific or general objection, Celanese admits that it contracted with Arthur Brothers to provide independent contractor services at the Bishop plant during the stated period. REQUEST FOR ADMISSION NO. 193 Admit that Celanese contracted with ABI to provide services at its Bishop, Texas facility in 1964. . RESPONSE: Celanese objects to this request as vague and ambiguous. Subject to and without waiving this or any other specific or general objection, Celanese admits that it contracted with Arthur Brothers to provide independent contractor services at the Bishop plant during the stated period. REQUEST FOR ADMISSION NO. 194 Admit that Celanese contracted with ABI to provide services at its Bishop, Texas facility in 1965. RESPONSE: Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 69 98102 Celanese objects to this request as vague and ambiguous. Subject to and without waiving this or any other specific or general objection, Celanese admits that it contracted with Arthur Brothers to provide independent contractor services at the Bishop plant during the stated period. REQUEST FOR ADMISSION NO. 195 Admit that Celanese contracted with ABI to provide"services at its Bishop, Texas facility in 1966. RESPONSE: Celanese objects to this request as vague and ambiguous^ Subject to and without waiving this or any other specific or general objection, ' Celanese admits that it contracted with Arthur Brothers to provide independent contractor services at the Bishop plant during the stated period. REQUEST FOR ADMISSION NO. 196 Admit that Celanese contracted with ABI to provide services at its Bishop, Texas facility in 1967. RESPONSE: Celanese objects to this request as vague and ambiguous. Subject to and without waiving this or any other specific or general objection, Celanese admits that it contracted with Arthur Brothers to provide independent contractor services at the Bishop plant during the stated period. REQUEST FOR ADMISSION NO. 197 Admit that Celanese contracted with ABI to provide services at its Bishop, Texas facility in 1968. RESPONSE: Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 98102 Celanese objects to this request as vague and ambiguous. Subject to and without waiving this or any other specific or general objection, Celanese admits that it contracted with Arthur Brothers to provide independent contractor services at the Bishop plant during the stated period. REQUEST FOR ADMISSION NO. 198 Admit that Celanese contracted with ABI to provide services at its Bishop, Texas facility in 1969. RESPONSE: Celanese objects to this request as vague and ambiguous. Subject to and without waiving this or any other specific or general objection, Celanese admits that it contracted with Arthur Brothers to provide independent cbntractor services at the Bishop plant during the stated period. REQUEST FOR ADMISSION NO. 199 Admit that Celanese contracted with ABI to provide services at its Bishop, Texas facility in 1970. RESPONSE: Celanese objects to this request as vague and ambiguous. Subject to and without waiving this or any other specific or general objection, Celanese admits that it contracted with Arthur Brothers to provide independent contractor services at the Bishop plant during the stated period. REQUEST FOR ADMISSION NO. 200 Admit that Celanese contracted with ABI to provide services at its Bishop, Texas facility in 1971. RESPONSE: Celanese objects to this request as vague and ambiguous. Subject to and without Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 71 98102 waiving this or any other specific or general objection, Celanese admits that it contracted with Arthur Brothers to provide independent contractor services at the Bishop plant during the stated period. REQUEST FOR ADMISSION NO. 201 Admit that Celanese contracted with ABI to provide services at its Bishop, Texas facility in 1972. ^ RESPONSE: Celanese objects to this request as vague and ambiguous in that the term "services" is undefined. Celanese further objects to this request as overly broad and harassing in that it is outside the time period at issue in this litigation and it.seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 202 Admit that Plaintiff worked as an employee of ABI at the Celanese Bishop, Texas facility in 1959. RESPONSE: Celanese objects to this request as vague and ambiguous in that the term "services" is undefined. Celanese further objects to this request as overly broad and harassing in that it is outside the time period at issue in this litigation and it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 203 Admit that Plaintiff worked as an employee of ABI at the Celanese Bishop, Texas facility in 1960. RESPONSE: Celanese objects to this request as vague and ambiguous in that the term "services" is undefined. Celanese further objects to this request as overly broad and harassing in Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 72 98102 that it is outside the time period at issue in this litigation and it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 204 Admit that Plaintiff worked as an employee of ABI at the Celanese Bishop, Texas facility in 1961. RESPONSE: See responses to Requests for Admission Nos. 176 -184. REQUEST FOR ADMISSION NO. 205 Admit that Plaintiff worked as an employee of ABI at the Celanese Bishop, Texas facility in 1962. RESPONSE: See responses to Requests for Admission Nos. 176 -184. REQUEST FOR ADMISSION NO. 206 Admit that Plaintiff worked as an employee of ABI at the Celanese Bishop, Texas facility in 1963. RESPONSE: See responses to Requests for Admission Nos. 176 -184. REQUEST FOR ADMISSION NO. 207 Admit that Plaintiff worked as an employee of ABI at the Celanese Bishop, Texas facility in 1964. RESPONSE: See responses to Requests for Admission Nos. 176 -184. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 73 98102 REQUEST FOR ADMISSION NO. 208 Admit that Plaintiff worked as an employee of ABI at the Celanese Bishop, Texas facility in 1965. RESPONSE: See responses to Requests for Admission Nos. 176 -184. REQUEST FOR ADMISSION NO. 209 Admit that Plaintiff worked as an employee of ABI at the Celanese Bishop, Texas facility in 1966. ? RESPONSE: See responses to Requests for Admission Nos. 176-184. REQUEST FOR ADMISSION NO. 210 Admit that Plaintiff worked as an employee of ABI at the Celanese Bishop, Texas facility in 1967. RESPONSE: See responses to Requests for Admission Nos. 176-184. REQUEST FOR ADMISSION NO. 211 Admit that Plaintiff worked as an employee of ABI at the Celanese Bishop, Texas facility in 1968. RESPONSE: See responses to Requests for Admission Nos. 176 -184. REQUEST FOR ADMISSION NO, 212 Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 74 98102 Admit that Plaintiff worked as an employee of ABI at the Celanese Bishop, Texas facility in 1969. RESPONSE: See responses to Requests for Admission Nos. 176 -184. REQUEST FOR ADMISSION NO. 213 _ Admit that Plaintiff worked as an employee of ABI at the Celanese Bishop, Texas facility in 1970. RESPONSE: See responses to Requests for Admission Nos. 185 -186. REQUEST FOR ADMISSION NO. 214 Admit that Plaintiff worked as an employee of ABI at the Celanese Bishop, Texas facility in 1971. RESPONSE: See responses to Requests for Admission Nos. 185 - 186. REQUEST FOR ADMISSION NO. 215 Admit that Plaintiff worked as an employee of ABI at the Celanese Bishop, Texas facility in 1972. RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside the time period at issue in this litigation. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 216 Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 75 98102 Admit that Celanese manufactured Celenex at the Bishop facility in 1959. RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside the time period at issue in this litigation. Subject to and without waiving the foregoing objections, denied REQUEST FOR ADMISSION NO. 217 Admit that Celanese manufactured Celenex at the Bishop facility in 1960. RESPONSE: Celanese objects,to this request as overly broad in that it seeks information outside the time period at issue in this litigation. Subject to and without waiving the foregoing objection, denied. REQUEST FOR ADMISSION NO. 218 Admit that Celanese manufactured Celenex at the Bishop facility in 1961. RESPONSE: Denied. REQUEST FOR ADMISSION NO. 219 Admit that Celanese manufactured Celenex at the Bishop facility in 1962. RESPONSE: Denied. REQUEST FOR ADMISSION NO. 220 Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 76 98102 Admit that Celanese manufactured Celenex at the Bishop facility in 1963. RESPONSE; Denied. REQUEST FOR ADMISSION NO. 221 Admit that Celanese manufactured Celenex at thJ3ishop facility in 1964. RESPONSE: Denied. REQUEST FOR ADMISSION NO. 222 Admit that Celanese manufactured Celenex at the Bishop facility in 1965. RESPONSE: Denied. REQUEST FOR ADMISSION NO. 223 Admit that Celanese manufactured Celenex at the Bishop facility in 1966. RESPONSE: Denied. REQUEST FOR ADMISSION NO. 224 Admit that Celanese manufactured Celenex at the Bishop facility in 1967. RESPONSE: Denied. / Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 77 98102 REQUEST FOR ADMISSION NO. 225 Admit that Celanese manufactured Celenex at the Bishop facility in 1968. RESPONSE: Denied. REQUEST FOR ADMISSION NO. 226 ^ Admit that Celanese manufactured Celenex at the Bishop facility in 1969. RESPONSE: Denied. REQUEST FOR ADMISSION NO. 227 Admit that Celanese manufactured Celenex at the Bishop facility in 1970. RESPONSE: Denied. REQUEST FOR ADMISSION NO. 228 Admit that Celanese manufactured Celenex at the Bishop facility in 1971. RESPONSE: Admitted. REQUEST FOR ADMISSION NO. 229 Admit that Celanese manufactured Celenex at the Bishop facility in 1972. RESPONSE: Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 78 98102 Celanese objects to this request as overly broad in that it seeks information outside the time period at issue in this litigation. Subject to and without waiving the foregoing objections, admitted. REQUEST FOR ADMISSION NO. 230 Admit that raw asbestos fibers were used in the manufacturing of Celenex at the Bishop facility in 1959. ^ RESPONSE: Celanese objects to this request in that it is outside the time period relevant to this litigation. Subject to and without waiving this or any other specific or general objection, denied. REQUEST FOR ADMISSION NO. 231 Admit that raw asbestos fibers were used in the manufacturing of Celenex at the Bishop facility in 1960. RESPONSE: Celanese objects to this request in that it is outside the time period relevant to this litigation. Subject to and without waiving this or any other specific or general objection, Denied. REQUEST FOR ADMISSION NO. 232 Admit that raw asbestos fibers were used in the manufacturing of Celenex at the Bishop facility in 1961. RESPONSE: Celanese objects to this request as duplicative of previous request served upon and answered by Celanese. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 79 98102 Subject to and without waiving this or any other specific or general objection, Denied. REQUEST FOR ADMISSION NO. 233 Admit that raw asbestos fibers were used in the manufacturing of Celenex at the Bishop facility in 1962. RESPONSE: _ Celanese Objects to this request as duplicative of previous request served upon and answered by Celanese. Subject to and without waiving this or any other specific or general objection, Denied. REQUEST FOR ADMISSION NO. 234 Admit that raw asbestos fibers were used in the manufacturing of Celenex at the Bishop facility in 1963. RESPONSE: Celanese objects to this request as duplicative of previous request served upon and answered by Celanese. Subject to and without waiving this or any other specific or general objection, Denied. REQUEST FOR ADMISSION NO. 235 Admit that raw asbestos fibers were used in the manufacturing of Celenex at the Bishop facility in 1964. RESPONSE: Celanese objects to this request as duplicative of previous requests served upon and answered by Celanese. Subject to and without waiving this or any other specific or general objection, Denied. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 80 98102 REQUEST FOR ADMISSION NO. 236 Admit that raw asbestos fibers were used in the manufacturing of Celenex at the Bishop facility in 1965. RESPONSE: Celanese objects to this request as duplicative of previous requests served upon and answered by Celanese. Subject to and without waiving this or any other specific or general objection, Denied. REQUEST FOR ADMISSION NO. 237 Admit that raw asbestos fibers were used in the manufacturing of Celenex at the Bishop facility in 1966. RESPONSE: Celanese objects to this request as duplicative of previous requests served upon and answered by Celanese. Subject to and without waiving this or any other specific or general objection, Denied. REQUEST FOR ADMISSION NO. 238 Admit that raw asbestos fibers were used in the manufacturing of Celenex at the Bishop facility in 1967. RESPONSE: Celanese objects to this request as duplicative of previous requests served upon and answered by Celanese. Subject to and without waiving this or any other specific or general objection, Denied. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 81 98102 REQUEST FOR ADMISSION NO. 239 Admit that raw asbestos fibers were used in the manufacturing of Celenex at the Bishop facility in 1968. RESPONSE: Celanese objects to this request as duplicative of previous requests served upon and answered by Celanese. Subject to and without waiving this or any other specific or general objection, Denied. REQUEST FOR ADMISSION NO. 240 Admit that raw asbestos fibers were used in the manufacturing of Celenex at the Bishop facility in 1969. RESPONSE: Celanese objects to this request as duplicative of previous requests served upon and answered by Celanese. Subject to and without waiving this or any other specific or general objection, Denied. REQUEST FOR ADMISSION NO. 241 Admit that raw asbestos fibers were used in the manufacturing of Celenex at the Bishop facility in 1970. RESPONSE: Celanese objects to this request as duplicative of previous requests served upon and answered by Celanese. Subject to and without waiving this or any other specific or general objection, denied. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 82 98102 REQUEST FOR ADMISSION NO. 242 Admit that raw asbestos fibers were used in the manufacturing of Celenex at the Bishop facility in 1971. RESPONSE; Celanese objects to this request as duplicative ofjgrevious requests served upon and answered by Celanese. Subject to and without waiving this or any other specific or general objection, Admitted. REQUEST FOR ADMISSION NO. 243 Admit that raw asbestos fibers were used in the manufacturing of Celenex at the Bishop facility in 1972. RESPONSE: Celanese objects to this request as it is outside the time period relevant to this litigation. Further, the request is duplicative of previous requests served upon and answered by Celanese. REQUEST FOR ADMISSION NO. 244 Admit that the raw asbestos fiber used in the manufacture of Celenex was "Calidria" brand. RESPONSE: Celanese objects to this request in that it is not limited to the time period and/or plant at issue in this litigation. Subject to and without waiving this or any other specific or general objection, admitted upon present information and belief. REQUEST FOR ADMISSION NO. 245 Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 83 98102 Admit that asbestos containing pipe insulation was in use at the Bishop facility in 1959. RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside the time period at issue in this litigation. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. ^ REQUEST FOR ADMISSION NO, 246 Admit that asbestos containing pipe insulation was in use at the Bishop facility in 1960. RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside the time period at issue in this litigation. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 247 Admit that asbestos containing pipe insulation was in use at the Bishop facility in 1961. RESPONSE: Celanese admits that at various times asbestos-containing pipe covering was utilized at the Bishop Plant. REQUEST FOR ADMISSION NO. 248 Admit that asbestos containing pipe insulation was in use at the Bishop facility in 1962. RESPONSE: Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 84 98102 Celanese admits that at various times asbestos-containing pipe covering was utilized at the Bishop Plant. REQUEST FOR ADMISSION NO. 249 Admit that asbestos containing pipe insulation was in use at the Bishop facility in 1963. RESPONSE: ^ Celanese admits that at various times asbestos-containing pipe covering was utilized at the Bishop Plant. REQUEST FOR ADMISSION NO. 250 Admit that asbestos containing pipe insulation was in use at the Bishop facility in 1964. RESPONSE: Celanese admits that at various times asbestos-containing pipe covering was utilized at the Bishop Plant. REQUEST FOR ADMISSION NO. 251 Admit that asbestos containing pipe insulation was in use at the Bishop facility in 1965; RESPONSE: Celanese admits that at various times asbestos-containing pipe covering was utilized at the Bishop Plant. REQUEST FOR ADMISSION NO. 252 Admit that asbestos containing pipe insulation was in use at the Bishop facility in 1966. RESPONSE: Celanese admits that at various times asbestos-containing pipe covering was utilized at the Bishop Plant. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 85 98102 REQUEST FOR ADMISSION NO. 253 Admit that asbestos containing pipe insulation was in use at the Bishop facility in 1967. RESPONSE: Celanese admits that at various times asbestos-containing pipe covering was utilized at the Bishop Plant. ^ REQUEST FOR ADMISSION NO. 254 Admit that asbestos containing pipe insulation was in use at the Bishop facility in 1968. RESPONSE: Celanese admits that at various times asbestos-containing pipe covering was utilized at the Bishop Plant. REQUEST FOR ADMISSION NO. 255 Admit that asbestos containing pipe insulation was in use at the Bishop facility in 1969. RESPONSE: Celanese admits that at various times asbestos-containing pipe covering was utilized at the Bishop Plant. REQUEST FOR ADMISSION NO. 256 Admit that asbestos containing pipe insulation was in use at the Bishop facility in 1970. RESPONSE: Celanese admits that at various times asbestos-containing pipe covering was utilized at the Bishop Plant. REQUEST FOR ADMISSION NO. 257 j ......... .......... ................................................................................... ........................ Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 86 98102 Admit that asbestos containing pipe insulation was in use at the Bishop facility in 1971. RESPONSE: Celanese admits that at various times asbestos-containing pipe covering was utilized at the Bishop Plant. REQUEST FOR ADMISSION NO. 258 Admit that asbestos containing pipe insulation was in use at the Bishop facility in 1972. RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside the time period at issue in this litigation. Celanese further objectsjo this request because it seeks information that is neither relevant nor reasonably 'calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 259 Admit that asbestos containing insulating cement was in use at the Bishop facility in 1959. RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside the time period at issue in this litigation. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 260 Admit that asbestos containing insulating cement was in use at the Bishop facility in I960.' RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside the time period at issue in this litigation. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 87 98102 discovery of admissible evidence. REQUEST FOR ADMISSION NO. 261 Admit that asbestos containing insulating cement was in use at the Bishop facility in 1961. RESPONSE: Celanese admits that at various times asbestos-containing insulating cement was utilized at the Bishop plant. REQUEST FOR ADMISSION NO. 262 Admit that asbestos containing insulating cement was in use at the Bishop facility in 1962. RESPONSE: Celanese admits that at various times asbestos-containing insulating cement was utilized at the Bishop plant. REQUEST FOR ADMISSION NO. 263 Admit that asbestos containing insulating cement was in use at the Bishop facility in 1963. RESPONSE: Celanese admits that at various times asbestos-containing insulating cement was utilized at the Bishop plant. REQUEST FOR ADMISSION NO. 264 Admit that asbestos containing insulating cement was in use at the Bishop facility in 1964. RESPONSE: Celanese admits that at various times asbestos-containing insulating cement was Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 88 98102 utilized at the Bishop plant. REQUEST FOR ADMISSION NO. 265 Admit that asbestos containing insulating cement was in use at the Bishop facility in 1965. RESPONSE: Celanese admits that at various times asbestos-containing insulating cement was utilized at the Bishop plant. REQUEST FOR ADMISSION NO. 266 Admit that asbestos containing insulating cement was in use. at the Bishop facility in 1966. RESPONSE: Celanese admits that at various times asbestos-containing insulating cement was utilized at the Bishop plant. REQUEST FOR ADMISSION NO. 267. Admit that asbestos containing insulating cement was in use at the Bishop facility in 1967. RESPONSE: Celanese admits that at various times asbestos-containing insulating cement was utilized at the Bishop plant. REQUEST FOR ADMISSION NO. 268 Admit that asbestos containing insulating cement was in use at the Bishop facility in 1968. RESPONSE: Celanese admits that at various times asbestos-containing insulating cement was Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 89 98102 utilized at the Bishop plant. REQUEST FOR ADMISSION NO. 269 Admit that asbestos containing insulating cement was in use at the Bishop facility in 1969. RESPONSE: Celanese admits that at various times asbestos^containing insulating cement was utilized at the Bishop plant. REQUEST FOR ADMISSION NO. 270 Admit that asbestos containing insulating cement was in use at the Bishop facility in 1970. RESPONSE: Celanese admits that at various times asbestos-containing insulating cement was utilized at the Bishop plant. REQUEST FOR ADMISSION NO. 271 Admit that asbestos containing insulating cement was in use at the Bishop facility in 1971. RESPONSE: Celanese admits that at various times asbestos-containing insulating cement was utilized at the Bishop plant. REQUEST FOR ADMISSION NO. 272 Admit that asbestos containing insulating cement was in use at the Bishop facility in 1972. RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside the Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 90 98102 time period at issue in this litigation. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 273 Admit that asbestos containing refractory cement was in use at the Bishop facility in 1959. RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside the time period at issue in this litigation. Celanese further object^-to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 274 Admit that asbestos containing refractory cement was in use at the Bishop facility in 1960. RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside the time period at issue in this litigation. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 275 Admit that asbestos containing refractory cement was in use at the Bishop facility in 1961. RESPONSE: After reasonable inquiry, the information known or reasonably obtainable is insufficient to enable Celanese to admit or deny this request. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 91 98102 REQUEST FOR ADMISSION NO. 276 Admit that asbestos containing refractory cement was in use at the Bishop facility in 1962. RESPONSE: After reasonable inquiry, the information known ojjieasonably obtainable is insufficient to enable Celanese to admit or deny this request. REQUEST FOR ADMISSION NO. 277 Admit that asbestos containing refractory cement was in use at the Bishop facility in 1963. RESPONSE: After reasonable inquiry, the information known or reasonably obtainable is insufficient to enable Celanese to admit or deny this request. REQUEST FOR ADMISSION NO. 278 Admit that asbestos containing refractory cement was in use at the Bishop facility in 1964. RESPONSE: After reasonable inquiry, the information known or reasonably obtainable is insufficient to enable Celanese to admit or deny this request. REQUEST FOR ADMISSION NO. 279 Admit that asbestos containing refractory cement was in use at the Bishop facility in 1965. RESPONSE: After reasonable inquiry, the information known or reasonably obtainable is insufficient Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 92 98102 to enable Celanese to admit or deny this request. REQUEST FOR ADMISSION NO. 280 Admit that asbestos containing refractory cement was in use at the Bishop facility in 1966. RESPONSE: After reasonable inquiry, the information known or reasonably obtainable is insufficient to enable Celanese to admit or deny this request. REQUEST FOR ADMISSION NO. 281 Admit that asbestos containing refractory cement was in use at the Bishop facility in 1967. RESPONSE: After reasonable inquiry, the information known or reasonably obtainable is insufficient to enable Celanese to admit or deny this request. REQUEST FOR ADMISSION NO. 282 Admit that asbestos containing refractory cement was in use at the Bishop facility in 1968. RESPONSE: After reasonable inquiry, the information known or reasonably obtainable is insufficient to enable Celanese to admit or deny this request. REQUEST FOR ADMISSION NO. 283 Admit that asbestos containing refractory cement was in use at the Bishop facility in 1969. RESPONSE: After reasonable inquiry, the information known or reasonably obtainable is insufficient Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 93 98102 to enable Celanese to admit or deny this request. REQUEST FOR ADMISSION NO. 284 Admit that asbestos containing refractory cement was in use at the Bishop facility in 1970. RESPONSE: After reasonable inquiry, the information known or~easonably obtainable is insufficient to enable Gelanese to admit or deny this request. REQUEST FOR ADMISSION NO. 285 Admit that asbestos containing refractory cement was in use at the Bishop facility in 1971. ' RESPONSE: After reasonable inquiry, the information known or reasonably obtainable is insufficient to enable Celanese to admit or deny this request. REQUEST FOR ADMISSION NO. 286 Admit that asbestos containing refractory cement was in use at the Bishop facility in 1972. RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside the time period at issue in this litigation. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 287 Admit that asbestos containing firebrick was in use at the Bishop facility in 1959. RESPONSE: Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 94 98102 Celanese objects to this request as overly broad in that it seeks information outside the time period ait issue in this litigation. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 288 Admit that asbestos containing firebrick was in use at the Bishop facility in 1960. RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside the time period at issue in this litigation. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. T REQUEST FOR ADMISSION NO. 289 Admit that asbestos containing firebrick was in use at the Bishop facility in 1961. RESPONSE: On present information and belief, denied. REQUEST FOR ADMISSION NO. 290 Admit that asbestos containing firebrick was in use at the Bishop facility in 1962. RESPONSE: On present information and belief, denied. REQUEST FOR ADMISSION NO. 291 Admit that asbestos containing firebrick was in use at the Bishop facility in 1963. RESPONSE: On present information and belief, denied. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 95 98102 REQUEST FOR ADMISSION NO. 292 Admit that asbestos containing firebrick was in use at the Bishop facility in 1964. RESPONSE: On present information and belief, denied. REQUEST FOR ADMISSION NO. 293 -- Admit that asbestos containing firebrick was in use at the Bishop facility in 1965. RESPONSE: On present information and belief, denied. REQUEST FOR ADMISSION NO. 294 Admit that asbestos containing firebrick was in use at the Bishop facility in 1966. RESPONSE: On present information and belief, denied. REQUEST FOR ADMISSION NO. 295 Admit that asbestos containing firebrick was in use at the Bishop facility in 1967. RESPONSE: On'present information and belief, denied. REQUEST FOR ADMISSION NO. 296 Admit that asbestos containing firebrick was in use at the Bishop facility in 1968. RESPONSE: On present information and belief, denied. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 96 98102 REQUEST FOR ADMISSION NO. 297 Admit that asbestos containing firebrick was in use at the Bishop facility in 1969. RESPONSE: On present information and belief, denied. REQUEST FOR ADMISSION NO. 298 ^ Admit that asbestos containing firebrick was in use at the Bishop facility in 1970. RESPONSE: On present information and belief, denied. REQUEST FOR ADMISSION NO. 299 Admit that asbestos containing firebrick was in use at the Bishop facility in 1971. RESPONSE: On present information and belief, denied. REQUEST FOR ADMISSION NO. 300 Admit that asbestos containing firebrick was in use at the Bishop facility in 1972. RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside the time period at issue in this litigation. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 301 Admit that asbestos containing gaskets were in use at the Bishop facility in 1959. RESPONSE: Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 97 98102 Celanese objects to this request as overly broad in that it seeks information outside the time period at issue in this litigation. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 302 Admit that asbestos containing gaskets were in uss-at the Bishop facility in 1960. RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside the time period at issue in this litigation. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably-calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 303 Admit that asbestos containing gaskets were in use at the Bishop facility in 1961. RESPONSE: Celanese admits that at various times asbestos-containing gaskets were utilized at the Bishop Plant. REQUEST FOR ADMISSION NO. 304 Admit that asbestos containing gaskets were in use at the Bishop facility in 1962. RESPONSE: Celanese admits that at various times asbestos-containing gaskets were utilized at the Bishop Plant. REQUEST FOR ADMISSION NO. 305 Admit that asbestos containing gaskets were in use at the Bishop facility in 1963. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 98 98102 RESPONSE: Celanese admits that at various times asbestos-containing gaskets were utilized at the Bishop Plant. REQUEST FOR ADMISSION NO. 306 Admit that asbestos containing gaskets were in usg^t the Bishop facility in 1964. RESPONSE: Celanese admits that at various times asbestos-containing gaskets were utilized at the Bishop Plant. REQUEST FOR ADMISSION NO. 307 Admit that asbestos containing gaskets were in use at the Bishop facility in 1965. RESPONSE: Celanese admits that at various times asbestos-containing gaskets were utilized at the Bishop Plant. REQUEST FOR ADMISSION NO. 308 Admit that asbestos containing gaskets were in use at the Bishop facility in 1966. RESPONSE: Celanese admits that at various times asbestos-containing gaskets were utilized at the Bishop Plant. REQUEST FOR ADMISSION NO. 309 Admit that asbestos containing gaskets were in use at the Bishop facility in 1967. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 99 98102 RESPONSE: Celanese admits that at various times asbestos-containing gaskets were utilized at the Bishop Plant. REQUEST FOR ADMISSION NO. 310 Admit that asbestos containing gaskets were in use^at the Bishop facility in 1968. RESPONSE: Celanese admits that at various times asbestos-containing gaskets were utilized at the Bishop Plant. REQUEST FOR ADMISSION NO. 311 Admit that asbestos containing gaskets were in use at the Bishop facility in 1969. RESPONSE: Celanese admits that at various times asbestos-containing gaskets were utilized at the Bishop Plant. REQUEST FOR ADMISSION NO. 312 Admit that asbestos containing gaskets were in use at the Bishop facility in 1970. RESPONSE: Celanese admits that at various times asbestos-containing gaskets were utilized at the Bishop Plant. REQUEST FOR ADMISSION NO. 313 Admit that asbestos containing gaskets were in use at the Bishop facility in 1971. RESPONSE: Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 100 98102 Celanese admits that at various times asbestos-containing gaskets were utilized at the Bishop Plant. REQUEST FOR ADMISSION NO. 314 Admit that asbestos containing gaskets were in use at the Bishop facility in 1972. RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside the time period at issue in this litigation. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 315 Admit that asbestos containing spray-on fireproofing was in use at the Bishop facility in 1959. RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside the time period at issue in this litigation. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 316 Admit.that asbestos containing spray-on fireproofing was in use at the Bishop facility in 1960. RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside the time period at issue in this litigation. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 101 98102 discovery of admissible evidence. REQUEST FOR ADMISSION NO. 317 Admit that asbestos containing spray-on fireproofing was in use at the Bishop facility in 1961. RESPONSE: After reasonable inquiry, the information known or easily obtainable is insufficient to enable Celanese to admit or deny this request. REQUEST FOR ADMISSION NO. 318 Admit that asbestos containing spray-on fireproofing was in use at the Bishop facility in 1962. RESPONSE: After reasonable inquiry, the information known or easily obtainable is insufficient to enable Celanese to admit or deny this request. REQUEST FOR ADMISSION NO. 319 Admit that asbestos containing spray-on fireproofing was in use at the Bishop facility in 1963. RESPONSE: After reasonable inquiry, the information known or easily obtainable is insufficient to enable Celanese to admit or deny this request. REQUEST FOR ADMISSION NO. 320 Admit that asbestos containing spray-on fireproofing was in use at the Bishop facility in 1964. RESPONSE: / Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 102 98102 After reasonable inquiry, the information known or easily obtainable is insufficient to enable Celanese to admit or deny this request. REQUEST FOR ADMISSION NO. 322 Admit that asbestos containing spray-on fireproofing was in use at the Bishop facility in 1965. RESPONSE: ^ After reasonable inquiry, the information known or easily obtainable is insufficient to enable Celanese to admit or deny this request. REQUEST FOR ADMISSION NO. 323 Admit that asbestos containing spray-on fireproofing was in use at the Bishop facility in 1966. RESPONSE: After reasonable inquiry, the information known or easily obtainable is insufficient to enable Celanese to admit or deny this request. REQUEST FOR ADMISSION NO. 324 Admit that asbestos containing spray-on fireproofing was in use at the Bishop facility in 1967. RESPONSE: After reasonable inquiry, the information known or easily obtainable is insufficient to enable Celanese to admit or deny this request. REQUEST FOR ADMISSION NO. 325 Ad'mit that asbestos containing spray-on fireproofing was in use at the Bishop facility in Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 103 98102 1968. RESPONSE: After reasonable inquiry, the information known or easily obtainable is insufficient to enable Celanese to admit or deny this request. REQUEST FOR ADMISSION NO. 326 ^ Admit that asbestos containing spray-on fireproofing was in use at the Bishop facility in 1969. RESPONSE: After reasonable inquiry, the information known or easily obtainable is insufficient to enable Celanese to admit or deny this request. REQUEST FOR ADMISSION NO. 327 Admit that asbestos containing spray-on fireproofing was in use at the Bishop facility in 1970. RESPONSE: After reasonable inquiry, the information known or easily obtainable is insufficient to enable Celanese to admit or deny this request. REQUEST FOR ADMISSION NO. 328 Admit that asbestos containing spray-on fireproofing was in use at the Bishop facility in 1971.. RESPONSE: After reasonable inquiry, the information known or easily obtainable is insufficient to enable Celanese to admit or deny this request. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 104 98102 REQUEST FOR ADMISSION NO. 329 Admit that asbestos containing spray-on fireproofing was in use at the Bishop facility in 1972. RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside the time period at issue in this litigation. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 330 Admit that asbestos containing boiler insulation was in use at {he Bishop facility in 1959. RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside the time period at issue in this litigation. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 331 Admit that asbestos containing boiler insulation was in use at the Bishop facility in 1960. RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside the time period at issue in this litigation. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 332 Admit that asbestos containing boiler insulation was in use at the Bishop facility in 1961. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 105 98102 RESPONSE: Celanese admits that at various times asbestos-containing boiler insulation was utilized at the Bishop Plant. REQUEST FOR ADMISSION NO. 333 Admit that asbestos containing boiler insulation was in use at the Bishop facility in 1962. RESPONSE: Celanese admits that at various times asbestos-containing boiler insulation was utilized at the Bishop Plant. REQUEST FOR ADMISSION NO. 334 Admit that asbestos containing boiler insulation was in use at the Bishop facility in 1963. RESPONSE: Celanese admits that at various times asbestos-containing boiler insulation was utilized at the Bishop Plant. REQUEST FOR ADMISSION NO. 335 Admit that asbestos containing boiler insulation was in use at the Bishop facility in 1964. RESPONSE: Celanese admits that at various times asbestos-containing boiler insulation was utilized at the Bishop Plant. REQUEST FOR ADMISSION NO. 336 Admit that asbestos containing boiler insulation was in use at the Bishop facility in 1965. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 106 98102 RESPONSE: Celanese admits that at various times asbestos-containing boiler insulation was utilized at the Bishop Plant. REQUEST FOR ADMISSION NO. 337 Admit that asbestos containing boiler insulation was in use at the Bishop facility in 1966. RESPONSE: Celanese admits that at various times asbestos-containing bpHer insulation was utilized at the Bishop Plant. REQUEST FOR ADMISSION NO. 338 Admit that asbestos containing boiler insulation was in use at the Bishop facility in 1967. RESPONSE: Celanese admits that at various times asbestos-containing boiler insulation was utilized at the Bishop Plant. REQUEST FOR ADMISSION NO. 339 Admit that asbestos containing boiler insulation was in use at the Bishop facility in 1968. RESPONSE: Celanese admits that at various times asbestos-containing boiler insulation was utilized at the Bishop Plant. REQUEST FOR ADMISSION NO. 340 Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 107 98102 Admit that asbestos containing boiler insulation was in use at the Bishop facility in 1969. RESPONSE: Celanese admits that at various times asbestos-containing boiler insulation was utilized at the Bishop Plant. REQUEST FOR ADMISSION NO. 341 Admit that asbestos containing boiler insulation was in use at the Bishop facility in 1970. RESPONSE: Celanese admits that at various times asbestos-containing boiler insulation was utilized at the Bishop Plant. REQUEST FOR ADMISSION NO. 342 Admit that asbestos containing boiler insulation was in use at the Bishop facility in 1971. RESPONSE: Celanese admits that at various times asbestos-containing boiler insulation was utilized at the Bishop Plant. REQUEST FOR ADMISSION NO. 343 Admit that asbestos containing boiler insulation was in use at the Bishop facility in 1972. RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside the time period at issue in this litigation. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 108 98102 REQUEST FOR ADMISSION NO. 344 Admit that Celanese employees performed insulation using asbestos containing materials at the Bishop facility in 1959. RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside the time period at issue in this litigation. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 345 Admit that Celanese employees performed insulation u^ing asbestos containing materials at the Bishop facility in 1960. RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside the time period at issue in this litigation. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 346 Admit that Celanese employees performed insulation using asbestos containing materials at the Bishop facility in 1961. RESPONSE: Celanese objects to this request on the grounds that the information sought is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, on present information and belief, denied as stated. REQUEST FOR ADMISSION NO. 347 Admit that Celanese employees performed insulation using asbestos containing Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 109 98102 materials at the Bishop facility in 1962. RESPONSE: Celanese objects to this request on the grounds that the information sought is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. On present information and belief, denied as stated. REQUEST FOR ADMISSION NO. 348 Admit that Celanese employees performed insulation using asbestos containing materials at the Bishop facility in 1963. RESPONSE: Celanese objects to this request on the grounds that the information sought is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, on present information and belief, denied as stated. REQUEST FOR ADMISSION NO. 349 Admit that Celanese employees performed insulation using asbestos containing materials at the Bishop facility in 1964. RESPONSE: Celanese objects to this request on the grounds that the information sought is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, on present information and belief, denied as stated. REQUEST FOR ADMISSION NO. 350 Admit that Celanese employees performed insulation using asbestos containing materials at the Bishop facility in 1965. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 110 98102 RESPONSE: Celanese objects to this request on the grounds that the information sought is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, on present information and belief, denied as stated. REQUEST FOR ADMISSION NO. 351 -- Admit that Celanese employees performed insulation using asbestos containing materials at the Bishop facility in 1966. RESPONSE: Celanese objects to this request on the grounds that the information sought is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, on present information and belief, denied as stated. REQUEST FOR ADMISSION NO. 352 Admit that Celanese employees performed insulation using asbestos containing materials at the Bishop facility in 1967. RESPONSE: Celanese objects to this request on the grounds that the information sought is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, on present information and belief; denied as stated. REQUEST FOR ADMISSION NO. 353 Admit that Celanese employees performed insulation using asbestos containing materials at the Bishop facility in 1968. RESPONSE: Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 111 98102 Celanese objects to this request on the grounds that the information sought is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, on present information and belief, denied as stated. REQUEST FOR ADMISSION NO. 354 Admit that Celanese employees performed insulation using asbestos containing materials at the Bishop facility in 1969. RESPONSE: Celanese objects to this request on the grounds that the infprmation sought is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, on present information and belief, denied as stated. REQUEST FOR ADMISSION NO. 355 Admit that Celanese employees performed insulation using asbestos containing materials at the Bishop facility in 1970. RESPONSE: Celanese objects to this request on the grounds that the information sought is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, on present information and belief, denied as stated. REQUEST FOR ADMISSION NO. 356 Admit that Celanese employees performed insulation using asbestos containing materials at the Bishop facility in 1971. RESPONSE: Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 112 98102 Celanese objects to this request on the grounds that the information sought is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, on present information and belief, denied as stated. REQUEST FOR ADMISSION NO. 357 Admit that Celanese employees performed insulation using asbestos containing materials at the Bishop facility in 1972. RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside the time period at issue in this litigation. Celanese further objects'to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 358 Admit that Celanese did not employ any corporate level industrial hygienists before 1966. RESPONSE: Celanese objects to this request as duplicative of Request for Admission Nos. 48. See answer to Request for Admission No. 48. REQUEST FOR ADMISSION NO. 359 Admit that the Celanese Bishop facility first employed an industrial hygienist before 1966. RESPONSE: Celanese admits it did not have an industrial hygienist on the direct company payroll at the Bishop plant before 1966, although on information and belief the Bishop facility obtained industrial hygiene services from Celanese's insurance carriers prior to that time. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 113 98102 REQUEST FOR ADMISSION NO. 360 Admit that no Celanese employee was trained to do airborne dust sampling before 1966. RESPONSE: Celanese objects to this request as vague, ambiguous and overly broad in that it seeks information outside the time period at issue in th&Jitigation. Celanese also objects to this request as overly broad and harassing in that it is not limited to the plant at issue in this case. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, aftpr reasonable inquiry, the information known or reasonably obtainable is insufficient to enable Celanese to admit or deny this request. REQUEST FOR ADMISSION NO. 361 Admit that no Celanese employee was trained to airborne dust monitoring before 1966. RESPONSE: Celanese objects to this request as vague, ambiguous and overly broad in that it seeks information outside the time period at issue in this litigation. Celanese also objects to this request as overly broad and harassing in that it is not limited to the plant at issue in this case. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, after reasonable inquiry, the information known or reasonably obtainable is insufficient to enable Celanese to admit or deny this request. REQUEST FOR ADMISSION NO. 362 Admit that Celanese did not conduct any medical monitoring of contractor boilermakers fof asbestos exposure from 1959-1972. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 114 98102 RESPONSE: Celanese objects to this request as overly broad to the extent that it seeks information outside the time period at issue in this litigation. Celanese also objects to this request as overly broad and harassing in that it is not limited to the plant at issue in this case. Celanese further objects to this request because it is vague and ambiguous, in that the term "medical monitoring" is undefined and it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of-admissible evidence. Subject to and without waiving the foregoing general and specific objections, Celanese on information and belief admits this request, but denies that it had any duty to provide such services to independent contractor companies. Celanese further states in connection with this response that the obligation, if any, to provide medical monitoring to independent contractor employees would have rested with the independent contractor companies that employed them. REQUEST FOR ADMISSION NO. 363 Admit that Celanese did not conduct any medical monitoring of contractor laborers for asbestos exposure from 1959-1972. i RESPONSE: Celanese objects to this request as overly broad to the extent that it seeks information outside the time period at issue in this litigation. Celanese also objects to this request as overly broad and harassing in that it is not limited to the plant at issue in this case. Celanese further objects to this request because it is vague and ambiguous, in that the term "medical monitoring" is undefined and it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing general and specific objections, Celanese on information and belief admits this request, but denies that it had any duty to provide such services to independent contractor companies. Celanese further states in connection with this response that the obligation, if any, to provide medical monitoring to independent contractor employees would have rested with the independent contractor companies that employed them. REQUEST FOR ADMISSION NO. 364 Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 115 98102 Admit that Celanese did not conduct any medical monitoring of contractor insulators for asbestos exposure from 1959-1972. RESPONSE: Celanese objects to this request as overly broad to the extent that it seeks information outside the time period at issue in this litigation. Celanese also objects to this request as overly broad and harassing in that it is not limited to the plant at issue in this case. Celanese further objects to this request because ijtjs vague and ambiguous, in that the term "medical monitoring" is undefined and it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing general and specific objections, Celanese on information and belief admits this request, but denies that it had any duty to provide such services to independent contractor companies. Celanese further states in connection with this response that the obligation, if any, to provide medical monitoring to independent contractor employees would have rested with the independent contractor companies that employed them. REQUEST FOR ADMISSION NO. 365 Admit that Celanese did not conduct any medical monitoring of contractor pipefitters for asbestos exposure from 1959-1972. RESPONSE: Celanese objects to this request as overly broad to the extent that it seeks information outside the time period at issue in this litigation. Celanese also objects to this request as overly broad and harassing in that it is not limited to the plant at issue in this case. Celanese further objects to this request because it is vague and ambiguous, in that the term "medical monitoring" is undefined and it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing general and specific objections, Celanese on information and belief admits this request, but denies that it had any duty to provide such services to independent contractor companies. Celanese further states in connection with this response that the obligation, if any, to provide medical monitoring to independent contractor employees would have rested with the independent contractor companies that employed them. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 116 98102 REQUEST FOR ADMISSION NO. 366 Admit that Celanese did not conduct any medical monitoring of contractor welders for asbestos exposure from 1959-1972. RESPONSE: Celanese objects to this request as overly broad 4cr the extent that it seeks information outside the time period at issue in this litigation. Celanese also objects to this request as overly broad and harassing in that it is not limited to the plant at issue in this case. Celanese further objects to this request because it is vague and ambiguous, in that the term "medical monitoring" is undefined and it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. T* Subject to and without waiving the foregoing general and specific objections, Celanese on information and belief admits this request, but denies that it had any duty to provide such services to independent contractor companies. Celanese further states in connection with this response that the obligation, if any, to provide medical monitoring to independent contractor employees would have rested with the independent contractor companies that employed them. REQUEST FOR ADMISSION NO. 367 Admit that Celanese medical department personnel received the Journal of the American Medical Association in 1959: RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside the time period at issue in this litigation. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 368 Admit that Celanese medical department personnel received the Journal of the American Medical Association in 1960: RESPONSE: Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 117 98102 Celanese objects to this request as overly broad in that it seeks information outside the time period at issue in this litigation. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 369 Admit that Celanese medical department personnel received the Journal of the American Medical Association in 1961: RESPONSE: Celanese objects to this request on the grounds that it seeke,information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, on information and belief, Celanese admits that some personnel in its medical department likely either received or had access to the referenced publication during the stated time period. REQUEST FOR ADMISSION NO. 370 Admit that Celanese medical department personnel received the Journal of the American Medical Association in 1962: RESPONSE: Celanese objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, on information and belief, Celanese admits that some personnel in its medical department likely either received or had access to the referenced publication during the stated time period. REQUEST FOR ADMISSION NO. 371 Admit that Celanese medical department personnel received the Journal of the American Medical Association in 1963: Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 118 98102 RESPONSE: Celanese objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, on information and belief, Celanese admits that some personnel in its medical department likely either received or had access to the referenced publication during the-stated time period. REQUEST FOR ADMISSION NO. 372 Admit that Celanese medical department personnel received the Journal of the American Medical Association in 1964: RESPONSE: Celanese objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, on information and belief, Celanese admits that some personnel in its medical department likely either received or had access to the referenced publication during the stated time period. REQUEST FOR ADMISSION NO. 373 Admit that Celanese medical department personnel received the Journal of the American Medical Association in 1965: RESPONSE: Celanese objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, on information and belief, Celanese admits that some personnel in its medical department likely either received or had access to the referenced publication during the stated time period. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 119 98102 REQUEST FOR ADMISSION NO. 374 Admit that Celanese medical department personnel received the Journal of the American Medical Association in 1966: RESPONSE: Celanese objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, on information and belief, Celanese admits that some personnel in its medical department likely either received or had access to the referenced publication during the stated time period. REQUEST FOR ADMISSION NO. 375 Admit that Celanese medical department personnel received the Journal of the American Medical Association in 1967: RESPONSE: Celanese objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, on information and belief, Celanese admits that some personnel in its medical department likely either received Or had access to the referenced publication during the stated time period. REQUEST FOR ADMISSION NO. 376 Admit that Celanese medical department personnel received the Journal of the American Medical Association in 1968: RESPONSE: Celanese objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, on information and belief, Celanese admits that some personnel in its medical department likely either received or Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 120 98102 had access to the referenced publication during the stated time period. REQUEST FOR ADMISSION NO. 377 Admit that Celanese medical department personnel received the Journal of the American Medical Association in 1969: RESPONSE: Celanese objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, on information and belief, Celanese admits that some personnel in its medical department likely either received or had access to the referenced publication during the stated time-period. REQUEST FOR ADMISSION NO. 378 Admit that Celanese medical department personnel received the Journal of the American Medical Association in 1970: RESPONSE: Celanese objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, on information and belief, Celanese admits that some personnel in its medical department likely either received or had access to the referenced publication during the stated time period. REQUEST FOR ADMISSION NO. 379 Admit that Celanese medical department personnel received the Journal of the American Medical Association in 1971: RESPONSE: Celanese objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 121 98102 Subject to and without waiving the foregoing objections, on information and belief, Celanese admits that some personnel in its medical department likely either received or had access to the referenced publication during the stated time period. REQUEST FOR ADMISSION NO. 380 Admit that Celanese medical department personnel received the Journal of the American Medical Association in 1972: ^ RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside the time period at issue in this litigation. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably .calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 381 Admit that Celanese medical department personnel received the Industrial Medicine publication in 1959: RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside the time period at issue in this litigation. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 382 Admit that Celanese medical department personnel received the Industrial Medicine publication in 1960: RESPONSE: Celanese objects to this request as. overly broad in that it seeks information outside the time period at issue in this litigation. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 122 98102 discovery of admissible evidence. REQUEST FOR ADMISSION NO. 383 Admit that Celanese medical department personnel received the Industrial Medicine publication in 1961: RESPONSE: Celanese objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese can neither admit nor deny this request because the publication at issue is insufficiently identified. r* REQUEST FOR ADMISSION NO. 384 Admit that Celanese medical department personnel received the Industrial Medicine publication in 1962: RESPONSE: Celanese objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese can neither admit nor deny this request because the publication at issue is insufficiently identified. REQUEST FOR ADMISSION NO. 385 Admit that Celanese medical department personnel received the Industrial Medicine publication in 1963: RESPONSE: Celanese objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. < Subject to and without waiving the foregoing objections, Celanese can neither admit nor Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Ceianese Ltd. 123 98102 deny this request because the publication at issue is insufficiently identified. REQUEST FOR ADMISSION NO. 386 Admit that Celanese medical department personnel received the Industrial Medicine publication in 1964: RESPONSE: Celanese objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese can neither admit nor deny this request because the publication at issue is insufficiently identified. T* REQUEST FOR ADMISSION NO. 387 Admit that Celanese medical department personnel received the Industrial Medicine publication in 1965: RESPONSE: Celanese objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese can neither admit nor deny this request because the publication at issue is insufficiently identified. REQUEST FOR ADMISSION NO. 388 Admit that Celanese medical department personnel received the Industrial Medicine publication in 1966: RESPONSE: Celanese objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese can neither admit nor deny this request because the publication at issue is insufficiently identified. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 124 98102 REQUEST FOR ADMISSION NO. 389 Admit that Celanese medical department personnel received the Industrial Medicine publication in 1967: RESPONSE: Celanese objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese can neither admit nor deny this request because the publication at issue is insufficiently identified. REQUEST FOR ADMISSION NO. 390 Admit that Celanese medical department personnel received the Industrial Medicine publication in 1968: RESPONSE: Celanese objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese can neither admit nor deny this request because the publication at issue is insufficiently identified. REQUEST FOR ADMISSION NO. 391 Admit that Celanese medical department personnel received the Industrial Medicine publication in 1969: RESPONSE: Celanese objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese can neither admit nor deny this request because the publication at issue is insufficiently identified. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 125 98102 REQUEST FOR ADMISSION NO. 392 Admit that Celanese medical department personnel received the Industrial Medicine publication in 1970: RESPONSE: Celanese objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese can neither admit nor deny this request because the publication at issue is insufficiently identified. REQUEST FOR ADMISSION NO. 393 Admit that Celanese medical department personnel received the Industrial Medicine publication in 1971: RESPONSE: Celanese objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese can neither admit nor deny this request because the publication at issue is insufficiently identified. REQUEST FOR ADMISSION NO. 394 Admit that Celanese medical department personnel received the Industrial Medicine publication in 1972: RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside the time period at issue in this litigation. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 395 Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 126 98102 Admit that Celanese medical department personnel received the Journal of Industrial Hygiene and Toxicology in 1959: RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside the time period at issue in this litigation. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 396 Admit that Celanese medical department personnel receive^-the Journal of Industrial Hygiene and Toxicology in 1960: RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside the time period at issue in this litigation. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 397 Admit that Celanese medical department personnel received the Journal of Industrial Hygiene and Toxicology in 1961: RESPONSE: Celanese objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, on information and belief, Celanese admits that some personnel in its medical department likely either received or had access to the referenced publication during the stated time period. REQUEST FOR ADMISSION NO. 398 Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 127 98102 Admit that Celanese medical department personnel received the Journal of Industrial Hygiene and Toxicology in 1962: RESPONSE: Celanese objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, on information and belief, Celanese admits that some personnel in its medical department likely either received or had access to the referenced publication during the stated time period. REQUEST FOR ADMISSION NO. 399 Admit that Celanese medical department personnel received the Journal of industrial Hygiene and Toxicology in 1963: RESPONSE: Celanese objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, on information and belief, Celanese admits that some personnel in its medical department likely either received or had access to the referenced publication during the stated time period. REQUEST FOR ADMISSION NO. 400 Admit that Celanese medical department personnel received the Journal of Industrial Hygiene and Toxicology in 1964: RESPONSE: Celanese objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, on information and belief, Celanese admits that some personnel in its medical department likely either received or Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 128 98102 had access to the referenced publication during the stated time period. REQUEST FOR ADMISSION NO. 401 Admit that Celanese medical department personnel received the Journal of Industrial Hygiene and Toxicology in 1965: RESPONSE: ^ Celanese objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, on information and belief, Celanese admits that some personnel in its medical department likely either received or had access to the referenced publication during the stated time period. REQUEST FOR ADMISSION NO. 402 Admit that Celanese medical department personnel received the Journal of Industrial Hygiene and Toxicology in 1966: 1RESP1 ONSE:-- .................... / Celanese objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, on information and belief, Celanese admits that some personnel in its medical department likely either received or had access to the referenced publication during the stated time period. REQUEST FOR ADMISSION NO. 403 Admit that Celanese medical department personnel received the Journal of Industrial Hygiene and Toxicology in 1967: RESPONSE: Celanese objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 129 98102 Subject to and without waiving the foregoing objections, on information and belief, Celanese admits that some personnel in its medical department likely either received or had access to the referenced publication during the stated time period. REQUEST FOR ADMISSION NO. 404 Admit that Celanese medical department personnel received the Journal of Industrial Hygiene and Toxicology in 1968: ^ RESPONSE: Celanese objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, on information and belief, Celanese admits that some personnel in its medical department likely either received or had access to the referenced publication during the stated time period. REQUEST FOR ADMISSION NO. 405 Admit that Celanese medical department personnel received the Journal of Industrial Hygiene and Toxicology in 1969: RESPONSE: Celanese objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, on information and belief, Celanese admits that some personnel in its medical department likely either received or had access to the referenced publication during the stated time period. REQUEST FOR ADMISSION NO. 406 Admit that Celanese medical department personnel received the Journal of Industrial Hygiene and Toxicology in 1970: RESPONSE: i Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 130 98102 Celanese objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, on information and belief, Celanese admits that some personnel in its medical department likely either received or had access to the referenced publication during the stated time period. REQUEST FOR ADMISSION NO. 407 Admit that Celanese medical department personnel received the Journal of Industrial Hygiene and Toxicology in 1971: RESPONSE: Celanese objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, on information and belief, Celanese admits that some personnel in its medical department likely either received or had access to the referenced publication during the stated time period. REQUEST FOR ADMISSION NO. 408 Admit that Celanese medical department personnel received the Journal of Industrial Hygiene and Toxicology in 1972: RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside the time period at issue in this litigation. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 409 Admit that Celanese medical department personnel received the National Safety News in 1959: RESPONSE: Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 131 98102 Celanese objects to this request as overly broad in that it seeks information outside the time period at issue in this litigation. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 410 Admit that Celanese medical department personnel received the National Safety News in 1960: RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside the time period at issue in this litigation. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 411 Admit that Celanese medical department personnel received the National Safety News in 1961: RESPONSE: Celanese objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, on information and belief, Celanese admits that some company personnel likely either received or had access to the referenced publication during the stated period. REQUEST FOR ADMISSION NO. 412 Admit that Celanese medical department personnel received the National Safety News in 1962: RESPONSE: Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 132 98102 Celanese objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, on information and belief, Celanese admits that some company personnel likely either received or had access to the referenced publication during the stated period. REQUEST FOR ADMISSION NO. 413 Admit that Celanese medical department personnel received the National Safety News in 1963: RESPONSE: Celanese objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, on information and belief, Celanese admits that some company personnel likely either received or had access to the referenced publication during the stated period. REQUEST FOR ADMISSION NO. 414 Admit that Celanese medical department personnel received the National Safety News in 1964 RESPONSE: Celanese objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, on information and belief, Celanese admits that some company personnel likely either received or had access to the referenced publication during the stated period. REQUEST FOR ADMISSION NO. 415 Admit that Celanese medical department personnel received the National Safety News in'1965: Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 133 98102 RESPONSE: Celanese objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, on information and belief, Celanese admits that some company personnel likely either received or had access to the referenced publication during the stated period^ REQUEST FOR ADMISSION NO. 416 Admit that Celanese medical department personnel received the National Safety News in 1966: RESPONSE: Celanese objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, on information and belief, Celanese admits that some company personnel likely either received or had access to the referenced publication during the stated period. REQUEST FOR ADMISSION NO. 417 Admit that Celanese medical department personnel received the National Safety News in 1967: RESPONSE: Celanese objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, on information and belief, Celanese admits that some company personnel likely either received or had access to the referenced publication during the stated period. REQUEST FOR ADMISSION NO. 418 Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 134 98102 Admit that Celanese medical department personnel received the National Safety News in 1968: RESPONSE: Celanese objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, on information and belief, Celanese admits that some company personnel likely either received or had access to the referenced publication during the stated period. REQUEST FOR ADMISSION NO. 419 Admit that Celanese medical department personnel receivedrthe National Safety News in 1969: RESPONSE: Celanese objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, on information and belief, Celanese admits that some company personnel likely either received or had access to the referenced publication during the stated period. REQUEST FOR ADMISSION NO. 420 Admit that Celanese medical department personnel received the National Safety News in 1970: RESPONSE: Celanese objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, on information and belief, Celanese admits that some company personnel likely either received or had access to the referenced publication during the stated period. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 135 98102 REQUEST FOR ADMISSION NO. 421 Admit that Celanese medical department personnel received the National Safety News in 1971: RESPONSE: Celanese objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discoveryjaf. admissible evidence. Subject to and without waiving the foregoing objections, on information and belief, Celanese admits that some company personnel likely either received or had access to the referenced publication during the stated period. REQUEST FOR ADMISSION NO. 422 ................................. .................. .....----" ............11 -t Admit that Celanese medical department personnel received the National Safety News in 1972: RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside the time period, at issue in this litigation. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 423 Admit that Celanese medical department personnel received the Industrial Hygiene Foundation Digest in 1959: RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside the time period at issue in this litigation. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 424 / Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 136 98102 Admit that Celanese medical department personnel received the Industrial Hygiene Foundation Digest in 1960: RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside the time period at issue in this litigation. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 425 Admit that Celanese medical department personnel received the Industrial Hygiene Foundation Digest in 1961: RESPONSE: Celanese objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, on information and belief, Celanese admits that some personnel in its medical department likely either received or had access to the referenced publication during the stated time period. REQUEST FOR ADMISSION NO. 426 Admit that Celanese medical department personnel received the Industrial Hygiene Foundation Digest in 1962: RESPONSE: Celanese objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, on information and belief, Celanese admits that some personnel in its medical department likely either received or had access to the referenced publication during the stated time period. REQUEST FOR ADMISSION NO. 427 Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 137 98102 Admit that Celanese medical department personnel received the Industrial Hygiene Foundation Digest in 1963: RESPONSE: Celanese objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing ojajections, on information and belief, Celanese admits that some personnel in its medical department likely either received or had access to the referenced publication during the stated time period. REQUEST FOR ADMISSION NO. 428 Admit that Celanese medical, department personnel received the Industrial Hygiene Foundation Digest in 1964: RESPONSE: Celanese objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, on information and belief, Celanese admits that some personnel in its medical department likely either received or had access to the referenced publication during the stated time period. REQUEST FOR ADMISSION NO. 429 Admit that Celanese medical department personnel received the Industrial Hygiene Foundation Digest in 1965: RESPONSE: Celanese objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, on information and belief, Celanese admits that some personnel in its medical department likely either received or had access to the referenced publication during the stated time period. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 138 98102 REQUEST FOR ADMISSION NO. 430 Admit that Celanese medical department personnel received the Industrial Hygiene Foundation Digest in 1966: RESPONSE: Celanese objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery^ admissible evidence. Subject ta and without waiving the foregoing objections, on information and belief, Celanese admits that some personnel in its medical department likely either received or had access to the referenced publication during the stated time period. REQUEST FOR ADMISSION NO. 431 Admit that Celanese medical department personnel received the Industrial Hygiene Foundation Digest in 1967: RESPONSE: Celanese objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, on information and belief, Celanese admits-that some personnel in its medical department likely either received or had access to the referenced publication during the stated time period. REQUEST FOR ADMISSION NO. 432 Admit that Celanese medical department personnel received the Industrial Hygiene Foundation Digest in 1968: RESPONSE: Celanese objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, on information and belief, Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 139 98102 Celanese admits that some personnel in its medical department likely either received or had access to the referenced publication during the stated time period. REQUEST FOR ADMISSION NO. 433 Admit that Celanese medical department personnel received the Industrial Hygiene Foundation Digest in 1969: RESPONSE: Celanese objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, -9a information and belief, Celanese admits that some personnel in its medical department likely either received or had access to the referenced publication during the stated time period. REQUEST FOR ADMISSION NO. 434 Admit that Celanese medical department personnel received the Industrial Hygiene Foundation Digest in 1970: RESPONSE: Celanese objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, on information and belief, Celanese admits that some personnel in its medical department likely either received or had access to the referenced publication during the stated time period. REQUEST FOR ADMISSION NO. 435 Admit that Celanese medical department personnel received the Industrial Hygiene Foundation Digest in 1971: RESPONSE: Celanese objects to this request because it seeks information that is neither relevant Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 140 98102 nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, on information and belief, Celanese admits that some personnel in its medical department likely either received or had access to the referenced publication during the stated time period. REQUEST FOR ADMISSION NO. 436 Admit that Celanese medical department personnel received the Industrial Hygiene Foundation Digest in 1972: RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside the time period at issue in this litigation. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 437 Admit that Celanese medical department personnel received the Public Health Reports of the United States Public Health Service in 1959: RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside the time period at issue in this litigation. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 438 Admit that Celanese medical department personnel received the Public Health Reports of the United States Public Health Service in 1960: RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside the time period at issue in this litigation. Celanese further objects to this request because it Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 141 98102 seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 439 Admit that Celanese medical department personnel received the Public Health Reports of the United States Public Health Service in 1961. RESPONSE: _ Celanese objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, after reasonable inquiry, the information known or reasonably obtainable is insufficient to-onable Celanese to admit or deny that personnel in its medical department received all USPHS reports generated during the stated period. REQUEST FOR ADMISSION NO. 440 Admit that Celanese medical department personnel received the Public Health Reports of-the United States Public Health Service in 1962. RESPONSE: Celanese objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, after reasonable inquiry, the information known or reasonably obtainable is insufficient to enable Celanese to admit or deny that personnel in its medical department received all USPHS reports generated during the stated period. REQUEST FOR ADMISSION NO. 441 Admit that Celanese medical department personnel received the Public Health Reports of the United States Public Health Service in 1963: RESPONSE: Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 142 98102 Celanese objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, after reasonable inquiry, the information known or reasonably obtainable is insufficient to enable Celanese to admit or deny that personnel in its medical department received all USPHS reports generated during the stated period. REQUEST FOR ADMISSION NO. 442 Admit that Celanese medical department personnel received the Public Health Reports of the United States Public Health Service in 1964: RESPONSE: * Celanese objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, after reasonable inquiry, the information known or reasonably obtainable is insufficient to enable Celanese to admit or deny that personnel in its medical department received all USPHS reports generated during the stated period. REQUEST FOR ADMISSION NO. 443 Admit that Celanese medical department personnel received the Public Health Reports of the United States Public Health Service in 1965: RESPONSE: Celanese objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, after reasonable inquiry, the information known or reasonably obtainable is insufficient to enable Celanese to admit or deny that personnel in its medical department received all USPHS reports generated during the stated period. REQUEST FOR ADMISSION NO. 444 Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 143 98102 Admit that Celanese medical department personnel received Public Health Reports of the United States Public Health Service in 1966 RESPONSE: Celanese objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, after reasonable inquiry, the information known or reasonably obtainable is insufficient to enable Celanese to admit or deny that personnel in its medical department received all USPHS reports generated during the stated period. REQUEST FOR ADMISSION NO. 445 Admit that Celanese medical department personnel received the Public Health Reports of the United States Public Health Service in 1967: RESPONSE: Celanese objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, after reasonable inquiry, the information known or reasonably obtainable is insufficient to enable Celanese to admit or deny that personnel in its medical department"received all USPHS reports generated during the stated period. REQUEST FOR ADMISSION NO. 446 Admit that Celanese medical department personnel received the Public Health Reports of the United States Public Health Service in 1968: RESPONSE: Celanese objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 144 - 98102 Subject to and without waiving the foregoing objections, after reasonable inquiry, the information known or reasonably obtainable is insufficient to enable Celanese to admit or deny that personnel in its medical department received all USPHS reports generated during the stated period. REQUEST FOR ADMISSION NO. 447 Admit that Celanese medical department personneUeceived the Public Health Reports of the United States Public Health Service in 1969: RESPONSE: Celanese objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, after reasonable inquiry, the information known or reasonably obtainable is insufficient to enable Celanese to admit or deny that personnel in its medical department received all USPHS reports generated during the stated period. REQUEST FOR ADMISSION NO. 448 Admit that Celanese medical department personnel received the Public Health Reports of the United States Public Health Service in 1970: RESPONSE: Celanese objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, after reasonable inquiry, the information known or reasonably obtainable is insufficient to enable Celanese to admit or deny that personnel in its medical department received all USPHS reports generated during the stated period. REQUEST FOR ADMISSION NO. 449 Admit that Celanese medical department personnel received the Public Health Reports of the United States Public Health Service in 1971 Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 145 98102 RESPONSE: Celanese objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, after reasonable inquiry, the information known or reasonably obtainable is insufficient to enable Celanese to admit or deny that personnel in its medical department received all USPHS reports generated during the stated period. REQUEST FOR ADMISSION NO. 450 Admit that Celanese medical department personnel received the Public Health Reports of the United States Public Health Service in 1972: l RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside the time period at issue in this litigation. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 466 Admit that Celanese knew pneumoconiosis was a danger in 1951. RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside the time period at issue in this litigation. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, after reasonable inquiry, the information known or reasonably obtainable is insufficient to enable Celanese to admit or deny this request. REQUEST FOR ADMISSION NO. 467 Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 146 98102 Admit that a Celanese employee reported that he had suffered a dust-related injury in 1951. RESPONSE: Celanese objects to this request as overly broad in that it is not properly limited to the time period and/or plant at issue in this case. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. ^ Subject to and without waiving the foregoing objections, on present information, Celanese is aware of nothing to suggest that an employee dust-related injury was reported in 1951, that such injury was reported to it or that any such injury related to asbestos dust, and thus must deny this request. REQUEST FOR ADMISSION NO. 468 Admit that Celanese did not institute a program to train it's employees about airborne dust hazards before 1966. RESPONSE: Celanese objects to this request on the grounds that it is vague, ambiguous, and overly broad in that it is not properly limited to the time period and/or plant at issue. Celanese further objects to this request on the grounds that it seeks information that is irrelevant and not reasonable calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese denies the request as stated. REQUEST FOR ADMISSION NO. 469 Admit that Celanese did not have an x-ray program for pneumoconiosis screening while Plaintiff was working at the site. RESPONSE: Celanese objects to this request on the grounds that it is vague and ambiguous in that the term "x-ray program" is undefined. Celanese further objects to this request on the grounds that it seeks information that is irrelevant and not reasonable calculated to lead Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 147 98102 to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese denies the request as stated. REQUEST FOR ADMISSION NO. 470 Admit that Celanese had no program to prevent employees from being exposed to pneumoconiosis causing dusts in 1959. RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside the time period at issue in this litigation and it is not limited to the plant at issue. r* REQUEST FOR ADMISSION NO. 471 Admit that Celanese had no program to prevent employees from being exposed to pneumoconiosis causing dusts in 1960. RESPONSE: Celanese objects to this request as overly broad in that it seeks information outside the time period at issue in this litigation and it is not limited to the plant at issue. REQUEST FOR ADMISSION NO. 472 Admit that Celanese had no program to prevent employees from being exposed to pneumoconiosis causing dusts in 1961. RESPONSE: Celanese objects to this request on the grounds that it is vague, ambiguous, and overly broad in that it is not properly limited to the time period and/or plant at issue. Celanese further objects to this request on the grounds that it seeks information that is irrelevant and not reasonable calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese denies the request as stated. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 148 98102 REQUEST FOR ADMISSION NO. 473 Admit that Celanese had no program to prevent employees from being exposed to pneumoconiosis causing dusts in 1962. RESPONSE: Celanese objects to this request on the grounds tb#t it is vague, ambiguous, and overly broad in that it is not properly limited to the time period and/or plant at issue. Celanese further objects to this request on the grounds that it seeks information that is irrelevant and not reasonable calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese denies the request as stated. REQUEST FOR ADMISSION NO. 474 Admit that Celanese had no program to prevent employees from being exposed to pneumoconiosis causing dusts in 1963. RESPONSE: Celanese objects to this request on the grounds that it is vague, ambiguous, and overly broad in that it is not properly limited to the time period and/or plant at issue. Celanese further objects to this request on the grounds that it seeks information that is irrelevant and not reasonable calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese denies the request as stated. REQUEST FOR ADMISSION NO. 475 Admit that Celanese had no program to prevent employees from being exposed to pneumoconiosis causing dusts in 1964. RESPONSE: C6lanese objects to this request on the grounds that it is vague, ambiguous, and overly Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 149 98102 broad in that it is not properly limited to the time period and/or plant at issue. Celanese further objects to this request on the grounds that it seeks information that is irrelevant and not reasonable calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese denies the request as stated. REQUEST FOR ADMISSION NO. 476 Admit that Celanese had no program to prevent employees from being exposed to pneumoconiosis causing dusts in 1965. RESPONSE: Celanese objects to this request on the grounds that it is vague, ambiguous, and overly broad in that it is not properly limited to the time period and/or plant at issue. Celanese further objects to this request on the grounds that it seeks information that is irrelevant and not reasonable calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese denies the request as stated. REQUEST FOR ADMISSION NO. 477 Admit that Celanese had no program to prevent employees from being exposed to pneumoconiosis causing dusts in 1966. RESPONSE: Celanese objects to this request on the grounds that it is vague, ambiguous, and overly broad in that it is not properly limited to the time period and/or plant at issue. Celanese further objects to this request on the grounds that it seeks information that is irrelevant and not reasonable calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese denies the request as stated. REQUEST FOR ADMISSION NO. 478 Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 150 98102 Admit that Celanese had no program to prevent employees from being exposed to pneumoconiosis causing dusts in 1967. RESPONSE: Celanese objects to this request on the grounds that it is vague, ambiguous, and overly broad in that it is not properly limited to the time period and/or plant at issue. Celanese further objects to this request on the grounds thatJJ.seeks information that is irrelevant and not reasonable calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese denies the request as stated. REQUEST FOR ADMISSION NO. 479 Admit that Celanese had no program to prevent employees from being exposed to pneumoconiosis causing dusts in 1968. RESPONSE: Celanese objects to this request on the grounds that it is vague, ambiguous, and overly broad in that it is not properly limited to the time period and/or plant at issue. Celanese further objects to this request on the grounds that it seeks information that is irrelevant and not reasonable calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese denies the request as stated. REQUEST FOR ADMISSION NO. 480 Admit that Celanese had no program to prevent employees from being exposed to pneumoconiosis causing dusts in 1969. RESPONSE: Celanese objects to this request on the grounds that it is vague, ambiguous, and overly broad in that it is not properly limited to the time period and/or plant at issue. Celanese Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 151 98102 further objects to this request on the grounds that it seeks information that is irrelevant and not reasonable calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese denies the request as stated. REQUEST FOR ADMISSION NO. 481 Admit that Celanese had no program to prevent employees from being exposed to pneumoconiosis causing dusts in 1970. RESPONSE: Celanese objects to this request on the grounds that it is vague, ambiguous, and overly broad in that it is not properly limited to the time period and/or plant at issue. Celanese further objects to this request on the grounds that it seeks information that is irrelevant and not reasonable calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese denies the request as stated. REQUEST FOR ADMISSION NO. 482 Admit that Celanese had no program to prevent employees from being exposed to pneumoconiosis causing dusts in 1971. RESPONSE: Celanese objects to this request on the grounds that it is vague, ambiguous, and overly broad in that it is not properly limited to the time period and/or plant at issue. Celanese further objects to this request on the grounds that it seeks information that is irrelevant and not reasonable calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese denies the request as stated. REQUEST FOR ADMISSION NO. 483 Admit that Celanese had no program to prevent employees from being exposed to Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 152 98102 pneumoconiosis causing dusts in 1972. RESPONSE: Celanese objects to this request as overly broad in that it is not properly limited to the time period and/or plant at issue in this case. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 484 ^ Admit that Celanese did not have any program to prevent employees of independent contractors from being exposed to pneumoconiosis causing dusts in 1959. RESPONSE: Celanese objects to this request as vague, ambiguous and overly broad in that it is not properly limited to the time period and/or plant at issue in this case. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 485 Admit that Celanese did not have any program to prevent employees of independent contractors from being exposed to pneumoconiosis causing dusts in 1960. RESPONSE: Celanese objects to this request as vague, ambiguous and overly broad in that it is not properly limited to the time period and/or plant at issue in this case. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 486 Admit that Celanese did not have any program to prevent employees of independent contractors from being exposed to pneumoconiosis causing dusts in 1961. RESPONSE: Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 153 98102 See responses to Request for Admission Nos. 70 - 80,112 -124, and 126 -137. REQUEST FOR ADMISSION NO. 487 Admit that Celanese did not have any program to prevent employees of independent contractors from being exposed to pneumoconiosis causing dusts in 1962. RESPONSE: ^ See responses to Request for Admission Nos. 70-80,112 - 124, and 126 -137. REQUEST FOR ADMISSION NO. 488 Admit that Celanese did not have any program to prevent employees of independent contractors from being exposed to pneumoconiosis causing dusts in 1963. RESPONSE: See responses to Request for Admission Nos. 70-80, 112 - 124, and 126 -137. REQUEST FOR ADMISSION NO. 489 Admit that Celanese did not have any program to prevent employees of independent contractors from being exposed to pneumoconiosis causing dusts in 1964. RESPONSE: See responses to Request for Admission Nos. 70 - 80, 112 -124, and 126 -137. REQUEST FOR ADMISSION NO. 490 Admit that Celanese did not have any program to prevent employees of independent contractors from being exposed to pneumoconiosis causing dusts in 1965. RESPONSE: See responses to Request for Admission Nos. 70-80, 112 - 124, and 126 -137. REQUEST FOR ADMISSION NO. 491 Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 154 98102 Admit that Celanese did not have any program to prevent employees of independent contractors from being exposed to pneumoconiosis causing dusts in 1966. RESPONSE: See responses to Request for Admission Nos. 70-80, 112 -124, and 126 -137. REQUEST FOR ADMISSION NO. 492 ^ Admit that Celanese did not have any program to prevent employees of independent contractors from being exposed to pneumoconiosis causing dusts in 1967. RESPONSE: See responses to Request for Admission Nos. 70 - 80,112 - 124, and 126 -137. REQUEST FOR ADMISSION NO. 493 Admit that Celanese did not have any program to prevent employees of independent contractors from being exposed to pneumoconiosis causing dusts in 1968. RESPONSE: See responses to Request for Admission Nos. 70 - 80, 112 -124, and 126 -137. REQUEST FOR ADMISSION NO. 494 Admit that Celanese did not have any program to prevent employees of independent contractors from being exposed to pneumoconiosis causing dusts in 1969. RESPONSE: See responses to Request for Admission Nos. 70-80, 112 -124, and 126 -137. REQUEST FOR ADMISSION NO. 495 Admit that Celanese did not have any program to prevent employees of independent contractors from being exposed to pneumoconiosis causing dusts in 1970. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 155 98102 RESPONSE: See responses to Request for Admission Nos. 70-80,112 -124, and 126 -137. REQUEST FOR ADMISSION NO. 496 Admit that Celanese did not have any program to prevent employees of independent contractors from being exposed to pneumoconiosis causing dusts in 1971. RESPONSE: See responses to Request for Admission Nos. 70-80, 112 -124, and 126 -137. REQUEST FOR ADMISSION NO. 497 Admit that Celanese did not have any program to prevent employees of independent contractors from being exposed to pneumoconiosis causing dusts in 1972. RESPONSE: Celanese objects to this request as vague, ambiguous and overly broad in that it is not properly limited to the time period and/or plant at issue in this case. Celanese further objects to. this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 498 Admit that Celanese provided plans to its Bishop facility construction contractor in 1959. RESPONSE: Celanese objects to this request as vague, ambiguous and overly broad in that it is not properly limited to the time period and/or plant at issue in this case. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 499 Admit that Celanese provided plans to its Bishop facility construction contractor in 1960. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 156 98102 RESPONSE: Celanese objects to this request as vague, ambiguous and overly broad in that it is not properly limited to the time period and/or plant at issue in this case. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 500 Admit that Celanese provided plans to its Bishop facility construction contractor in 1961. RESPONSE: Celanese objects to this request on the grounds that it is vague and ambiguous in that the term "plan" is undefined. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. REQUEST FOR ADMISSION NO. 501 Admit that Celanese provided plans to its Bishop facility construction, contractor in 1962. RESPONSE: Celanese objects to this request on the grounds that it is vague and ambiguous in that the term "plan" is undefined. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 157 98102 Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. REQUEST FOR ADMISSION NO. 502 Admit that Celanese provided plans to its Bishop facility construction contractor in 1963. RESPONSE: Celanese objects to this request on the grounds that it is vague and ambiguous in that the term "plan" is undefined. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. REQUEST FOR ADMISSION NO. 503 Admit that Celanese provided plans to its Bishop facility construction contractor in 1964. RESPONSE: Celanese objects to this request on the grounds that it is vague and ambiguous in that the term "plan" is undefined. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 158 98102 REQUEST FOR ADMISSION NO. 504 Admit that Celanese provided plans to its Bishop facility construction contractor in 1965. RESPONSE; Celanese objects to this request on the grounds that it is vague and ambiguous in that the term "plan" is undefined. Celanese further otyects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. REQUEST FOR ADMISSION NO. 505 Admit that Celanese provided plans to its Bishop facility construction contractor in 1966. RESPONSE: Celanese objects to this request on the grounds that it is vague and ambiguous in that the term "plan" is undefined. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. REQUEST FOR ADMISSION NO. 506 Admit that Celanese provided plans to its Bishop facility construction contractor in 1967. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 159 98102 RESPONSE: Celanese objects to this request on the grounds that it is vague and ambiguous in that the term "plan" is undefined. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. REQUEST FOR ADMISSION NO. 507 .............. .............. ",l 1 """ Admit that Celanese provided plans to its Bishop facility construction contractor in 1968. RESPONSE: Celanese objects to this request on the grounds that it is vague and ambiguous in that the term "plan" is undefined. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. REQUEST FOR ADMISSION NO. 508 Admit that Celanese provided plans to its Bishop facility construction contractor in 1969. RESPONSE: Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 160 98102 Celanese objects to this request on the grounds that it is vague and ambiguous in that the term "plan" is undefined. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during t{3 stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. REQUEST FOR ADMISSION NO. 509 Admit that Celanese provided plans to its Bishop facility'construction contractor in 1970. RESPONSE: Celanese objects to this request on the grounds that it is vague and ambiguous in that the term "plan" is undefined. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. REQUEST FOR ADMISSION NO. 510 Admit that Celanese provided plans to its Bishop facility construction contractor in 1971. RESPONSE: Celanese objects to this request on the grounds that it is vague and ambiguous in that Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 161 98102 the term "plan" is undefined. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. REQUEST FOR ADMISSION NO. 511 Admit that Celanese provided plans to its Bishop facility construction contractor in 1972. RESPONSE: Celanese objects to this request as vague and ambiguous in that the term "plan" is undefined. Celanese also objects to this request as overly broad in that it is not properly limited to the time period at issue in this case. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 512 Admit that Celanese provided specifications to its Bishop facility construction contractor in 1959. RESPONSE: Celanese objects to this request as vague and ambiguous in that the term "plan" is undefined. Celanese also objects to this request as overly broad in that it is not properly limited to the time period at issue in this case. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 513 Admit that Celanese provided specifications to its Bishop facility construction contractor in 1960. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 162 98102 RESPONSE: Celanese objects to this request as vague and ambiguous in that the term "plan" is undefined. Celanese also objects to this request as overly broad in that it is not properly limited to the time period at issue in this case. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 514 Admit that Celanese provided specifications to its Bishop facility construction contractor in 1961. RESPONSE: Celanese objects to this request on the grounds that it is vague and ambiguous. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. REQUEST FOR ADMISSION NO. 515 Admit that Celanese provided specifications to its Bishop facility construction contractor in 1962. RESPONSE: Celanese objects to this request on the grounds that it is vague and ambiguous. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 163 98102 inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. REQUEST FOR ADMISSION NO. 516 Admit that Celanese provided specifications to its Bishop facility construction contractor in 1963. RESPONSE: Celanese objects to this request on the grounds that it is vague and ambiguous. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the' discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. REQUEST FOR ADMISSION NO. 517 Admit that Celanese provided specifications to its Bishop facility construction contractor in 1964. RESPONSE: Celanese objects to this request on the grounds that it is vague and ambiguous. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 164 98102 REQUEST FOR ADMISSION NO. 518 Admit that Celanese provided specifications to its Bishop facility construction contractor in 1965. RESPONSE: Celanese objects to this request on the grounds that it is vague and ambiguous. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or*-maintenance work it hired plaintiffs employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. REQUEST FOR ADMISSION NO. 519 Admit that Celanese provided specifications to its Bishop facility construction contractor in 1966. . RESPONSE: Celanese objects to this request ,on the grounds that it is vague and ambiguous. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. REQUEST FOR ADMISSION NO. 520 Admit that Celanese provided specifications to its Bishop facility construction contractor Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 165 98102 in 1967. RESPONSE: Celanese objects to this request on the grounds that it is vague and ambiguous. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. REQUEST FOR ADMISSION NO. 521 Admit that Celanese provided specifications to its Bishop facility construction contractor in 1968. RESPONSE: Celanese objects to this request on the grounds that it is vague and ambiguous. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. REQUEST FOR ADMISSION NO. 522 Admit that Celanese provided specifications to its Bishop facility construction contractor in 1969. RE(SPONSE: Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 166 98102 Celanese objects to this request on the grounds that it is vague and ambiguous. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. REQUEST FOR ADMISSION NO. 523 Admit that Celanese provided specifications to its Bishop facility construction contractor in 1970. * RESPONSE: Celanese objects to this request on the grounds that it is vague and ambiguous. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. REQUEST FOR ADMISSION NO. 524 Admit that Celanese provided specifications to its Bishop facility construction contractor in 1971. RESPONSE: Celanese objects to this request on the grounds that it is vague and ambiguous. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 167 98102 Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. REQUEST FOR ADMISSION NO. 525 Admit that Celanese provided specifications to its Bishop facility construction contractor in 1972. RESPONSE: Celanese objects to this request as vague, ambiguous and overly broad in that it is not properly limited to the time period at issue in this case. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 526 Admit that Celanese provided drawings to- its Bishop facility construction contractor in 1959. RESPONSE: Celanese objects to this request as vague, ambiguous and overly broad in that it is not properly limited to the time period at issue in this case. Celanese further objects `to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 527 Admit that Celanese provided drawings to its Bishop facility construction contractor in 1960. RESPONSE: Celanese objects to this request as vague, ambiguous and overly broad in that it is not properly limited to the time period at issue in this case. Celanese further objects to this Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 168 98102 request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 528 Admit that Celanese provided drawings to its Bishop facility construction contractor in 1961. RESPONSE: Celanese objects to this request on the grounds that it is vague and ambiguous, in that the term "drawings" is undefined. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. T* Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. REQUEST FOR ADMISSION NO. 529 Admit that Celanese provided drawings to its Bishop facility construction contractor in 1962. RESPONSE: Celanese objects to this request on the grounds that it is vague and ambiguous, in that the term "drawings" is undefined. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 169 98102 REQUEST FOR ADMISSION NO. 530 Admit that Celanese provided drawings to its Bishop facility construction contractor in 1963. ,,* - - -? RESPONSE: Celanese objects to this request on the grounds that it is vague and ambiguous, in that the term "drawings" is undefined. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or,-maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. REQUEST FOR ADMISSION NO. 531 Admit that Celanese provided drawings to its Bishop facility construction contractor in 1964. RESPONSE: Celanese objects to this request on the grounds that it is vague and ambiguous, in that the term "drawings" is undefined. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. REQUEST FOR ADMISSION NO. 532 Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 170 98102 Admit that Celanese provided drawings to its Bishop facility construction contractor in 1965. RESPONSE: Celanese objects to this request on the grounds that it is vague and ambiguous, in that the term "drawings" is undefined. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. w REQUEST FOR ADMISSION NO. 533 Admit that Celanese provided drawings to its Bishop facility construction contractor in 1966. RESPONSE: Celanese objects to this request on the grounds that it is vague and ambiguous, in that the term, "drawings" is undefined. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. REQUEST FOR ADMISSION NO. 534 Admit that Celanese provided drawings to its Bishop facility construction contractor in 1967. RESPONSE: Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 171 98102 Celanese objects to this request on the grounds that it is vague and ambiguous, in that the term "drawings" is undefined. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. REQUEST FOR ADMISSION NO. 535 V' Admit that Celanese provided drawings to its Bishop facility construction contractor in 1968. RESPONSE: Celanese objects to this request on the grounds that it is vague and ambiguous, in that the term "drawings" is undefined. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. REQUEST FOR ADMISSION NO. 536 Admit that Celanese provided drawings to its Bishop facility construction contractor in 1969. RESPONSE: Celanese objects to this request on the grounds that it is vague and ambiguous, in that the term "drawings" is undefined. Celanese further objects to this request on the Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 172 98102 grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. REQUEST FOR ADMISSION NO. 537 ^ Admit that Celanese provided drawings to its Bishop facility construction contractor in 1970. RESPONSE: - ....... . - ............. Celanese objects to this request on the grounds that it is vague and ambiguous, in that the term "drawings" is undefined. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can-neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. REQUEST FOR ADMISSION NO. 538 Admit that Celanese provided drawings to its Bishop facility construction contractor in 1971. RESPONSE: Celanese objects to this request on the grounds that it is vague and ambiguous, in that the term "drawings" is undefined. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 173 98102 inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. REQUEST FOB ADMISSION NO. 539 Admit that Celanese provided drawings to its Bishop facility construction contractor in 1972. -- RESPONSE; Celanese objects to this request as vague, ambiguous and overly broad in that it is not properly limited to the time period at issue in this case. Celanese further objects to this request because it seeks information that is neither relevant,nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 540 Admit that Celanese provided plans to its Bishop facility maintenance contractor in 1959. RESPONSE: Celanese objects to this request as vague, ambiguous and overly broad in that it is not properly limited to the time period at issue in this case. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 541 Admit that Celanese provided plans to its Bishop facility maintenance contractor in I960.- RESPONSE: Celanese objects to this request as vague, ambiguous and overly broad in that it is not properly limited to the time period at issue in this case. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 174 98102 REQUEST FOR ADMISSION NO. 542 Admit that Celanese provided plans to its Bishop facility maintenance contractor in 1961. RESPONSE: Celanese objects to this request on the grounds tj^t it is vague and ambiguous, in that the term "plans" is undefined. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or-maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. REQUEST FOR ADMISSION NO. 543 Admit that Celanese provided plans to its Bishop facility maintenance contractor in 1962. RESPONSE: Celanese objects to this request on the grounds that it is vague and ambiguous, in that the term "plans" is undefined. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. REQUEST FOR ADMISSION NO. 544 Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 175 98102 Admit that Celanese provided plans to its Bishop facility maintenance contractor in 1963. RESPONSE: Celanese objects to this request on the grounds that it is vague and ambiguous, in that the term "plans" is undefined. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. ^ Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. REQUEST FOR ADMISSION NO. 545 Celanese objects to this request on the grounds that it is vague and ambiguous, in that the term "plans" is undefined. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. RESPONSE: Celanese objects to this request on the grounds that it is vague and ambiguous, in that the term "plans" is undefined. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 176 98102 work that might have involved such materials. REQUEST FOR ADMISSION NO. 546 Admit that Celanese provided plans to its Bishop facility maintenance contractor in 1965. RESPONSE: Celanese objects to this request on the grounds that it is vague and ambiguous, in that the term "plans" is undefined. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. I Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. REQUEST FOR ADMISSION NO. 547 Admit that Celanese provided plans to its Bishop facility maintenance contractor in 1966. RESPONSE: Celanese objects to this request on the grounds that it is vague and ambiguous, in that the term "plans" is undefined. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. REQUEST FOR ADMISSION NO. 548 Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 177 98102 Admit that Celanese provided plans to its Bishop facility maintenance contractor in 1967. RESPONSE: Celanese objects to this request on the grounds that it is vague and ambiguous, in that the term "plans" is undefined. Celanese further oljiects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the* stated period required it to provide Arthur Brothers with plans, specifications or drawings, or tliat plaintiff performed any work that might have involved such materials. REQUEST FOR ADMISSION NO. 549 Admit that Celanese provided plans to its Bishop facility maintenance contractor in 1968. RESPONSE: Celanese objects to this request on the grounds that it is vague and ambiguous, in that the term "plans" is undefined. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. REQUEST FOR ADMISSION NO. 550 Admit that Celanese provided plans to its Bishop facility maintenance contractor in 1969. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 178 98102 RESPONSE: Celanese objects to this request on the grounds that it is vague and ambiguous, in that the term "plans" is undefined. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. REQUEST FOR ADMISSION NO. 551 Admit that Celanese provided plans to its Bishop facility maintenance contractor in 1970. RESPONSE: Celanese objects to this request on the grounds that it is vague and ambiguous, in that the term "plans" is undefined. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. REQUEST FOR ADMISSION NO. 552 Admit that Celanese provided plans to its Bishop facility maintenance contractor in 1971. RESPONSE: Celanese objects to this request on the grounds that it is vague and ambiguous, in that Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 179 98102 the term "plans" is undefined. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. REQUEST FOR ADMISSION NO. 553 Admit that Celanese provided plans to its Bishop facility maintenance contractor in 1972. RESPONSE: Celanese objects to this request as vague, ambiguous and overly broad in that it is not properly limited to the time period at issue in this case. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 554 Admit that Celanese provided specifications to its Bishop facility maintenance contractor in 1959. RESPONSE: Celanese objects to this request as vague, ambiguous and overly broad in that it is not properly limited to the time period at issue in this case. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 555 Admit that Celanese provided specifications to its Bishop facility maintenance contractor in 1960. RESPONSE: Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 180 98102 Celanese objects to this request as vague, ambiguous and overly broad in that it is not properly limited to the time period at issue in this case. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 556 Admit that Celanese provided specifications to its-Bishop facility maintenance contractor in 1961. RESPONSE: Celanese objects to this request on the grounds that it is vague and ambiguous. Celanese further objects to this request on the grounds that~rt* seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. REQUEST FOR ADMISSION NO. 557 Admit that Celanese provided specifications to its Bishop facility maintenance contractor in 1962. RESPONSE: Celanese objects to this request on the grounds that it is vague and ambiguous. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 181 98102 work that might have involved such materials. REQUEST FOR ADMISSION NO. 558 Admit that Celanese provided specifications to its Bishop facility maintenance contractor in 1963. RESPONSE: Celanese objects to this request on the grounds that it is vague and ambiguous. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. REQUEST FOR ADMISSION NO. 559 Admit that Celanese provided specifications to its Bishop facility maintenance contractor in 1964. RESPONSE: Celanese objects to this request on the grounds that it is vague and ambiguous. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. REQUEST FOR ADMISSION NO. 560 Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 182 98102 Admit that Celanese provided specifications to its Bishop facility maintenance contractor in 1965. RESPONSE: Celanese objects to this request on the grounds that it is vague and ambiguous. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to i$d to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. REQUEST FOR ADMISSION NO. 561 Admit that Celanese provided specifications to its Bishop facility maintenance contractor in 1966. RESPONSE: Celanese objects to this request on the grounds that it is vague and ambiguous. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur-Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. REQUEST FOR ADMISSION NO. 562 Admit that Celanese provided specifications to its Bishop facility maintenance contractor in 1967. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 183 98102 RESPONSE: Celanese objects to this request on the grounds that it is vague and ambiguous. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. REQUEST FOR ADMISSION NO. 563 Admit, that Celanese provided specifications to its Bishop facility maintenance contractor in 1968. RESPONSE: Celanese objects to this request on the grounds that it is vague and ambiguous. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. REQUEST FOR ADMISSION NO. 564 Admit that Celanese provided specifications to its Bishop facility maintenance contractor in 1969. RESPONSE: Celanese objects to this request on the grounds that it is vague and ambiguous. Celanese further objects to this request on the grounds that it seeks information that is Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 184 98102 neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. REQUEST FOB ADMISSION NO. 565 " Admit that Celanese provided specifications to its Bishop facility maintenance contractor in 1970. RESPONSE: Celanese objects to this request on the grounds that it is vague and ambiguous. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. REQUEST FOR ADMISSION NO. 566 Admit that Celanese provided specifications to its Bishop facility maintenance contractor in 1971. RESPONSE: Celanese objects to this request on the grounds that it is vague and ambiguous. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 185 98102 inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. BEQUEST FOR ADMISSION NO. 567 Admit that Celanese provided specifications to its Bishop facility maintenance contractor in 1972. ^ RESPONSE: Celanese objects to this request as vague, ambiguous and overly broad in that it is not properly limited to the time period at issue in this case. Celanese further objects to this request because it seeks information that is neither relevant,-nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 568 Admit that Celanese provided drawings to its Bishop facility maintenance contractor in 1959. RESPONSE: Celanese objects to this request as vague, ambiguous and overly broad in that it is not properly limited to the time period at issue in this case. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 569 Admit that Celanese provided drawings to its Bishop facility maintenance contractor in 1960. RESPONSE: Celanese objects to this request as vague, ambiguous and overly broad in that it is not properly limited to the time period at issue in this case. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 186 98102 REQUEST FOR ADMISSION NO. 570 Admit that Celanese provided drawings to its Bishop facility maintenance contractor in 1961. RESPONSE: Celanese objects to this request on the grounds that it is vague and ambiguous, in that the term '`drawings1' is undefined. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or-,-maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. REQUEST FOR ADMISSION NO. 571 Admit that Celanese provided drawings to its Bishop facility maintenance contractor in 1962. RESPONSE: Celanese objects to this request on the grounds that it is vague and ambiguous, in that the term "drawings" is undefined. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. REQUEST FOR ADMISSION NO. 572 Admit that Celanese provided drawings to its Bishop facility maintenance contractor in Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 187 98102 1963. RESPONSE: Celanese objects to this request on the grounds that it is vague and ambiguous, in that the term "drawings" is undefined. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. REQUEST FOR ADMISSION NO. 573 Admit that Celanese provided drawings to its Bishop facility maintenance contractor in 1964. RESPONSE: Celanese objects to this request on the grounds that it is vague and ambiguous, in that the term "drawings" is undefined. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. REQUEST FOR ADMISSION NO. 574 Admit that Celanese provided drawings to its Bishop facility maintenance contractor in 1965. RESPONSE: Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 188 98102 Celanese objects to this request on the grounds that it is vague and ambiguous, in that the term "drawings" is undefined. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. REQUEST FOR ADMISSION NO. 575 Admit that Celanese provided drawings to its Bishop facility maintenance contractor in 1966. RESPONSE: Celanese objects to this request on the grounds that it is vague and ambiguous, in that the term "drawings" is undefined. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that jojaintiff performed any work that might have involved such materials. REQUEST FOR ADMISSION NO. 576 Admit that Celanese provided drawings to its Bishop facility maintenance contractor in 1967.- RESPONSE: Celanese objects to this request on the grounds that it is vague and ambiguous, in that the term "drawings" is undefined. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 189 98102 Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. REQUEST FOR ADMISSION NO. 577 Admit that Celanese provided drawings to its Bishop facility maintenance contractor in 1968. RESPONSE: Celanese objects to this request on the grounds that it is vaiglie and ambiguous, in that the term "drawings" is undefined. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. REQUEST FOR ADMISSION NO. 578 Admit that Celanese provided drawings to its Bishop facility maintenance contractor in 1969. RESPONSE: Celariese objects to this request on the grounds that it is vague and ambiguous, in that the term "drawings" is undefined. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 190 98102 Arthur Brothers with plans, specifications or drawings, or that plaintiff- performed any work that might have involved such materials. REQUEST FOR ADMISSION NO. 579 Admit that Celanese provided drawings to its Bishop facility maintenance contractor in 1970. RESPONSE: Celanese objects to this request on the grounds that it is vague and ambiguous, in that the term "drawings" is undefined. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. T Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. REQUEST FOR ADMISSION NO. 580 Admit that Celanese provided drawings to its Bishop facility maintenance contractor in 1971. RESPONSE: Celanese objects to this request on the grounds that it is vague and ambiguous, in that the term "drawings" is undefined. Celanese further objects to this request on the grounds that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese after reasonable inquiry can neither admit or deny that the construction and/or maintenance work it hired plaintiff's employer Arthur Brothers to do during the stated period required it to provide Arthur Brothers with plans, specifications or drawings, or that plaintiff performed any work that might have involved such materials. REQUEST FOR ADMISSION NO. 581 Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 191 98102 Admit that Celanese provided drawings to its Bishop facility maintenance contractor in 1972. RESPONSE: Celanese objects to this request as vague, ambiguous and overly broad in that it is not properly limited to the time period at issue in this case. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 582 Admit that Brown & Root was the primary construction contractor for the Bishop facility in 1959. RESPONSE: Celanese objects to this request as vague, ambiguous and overly broad in that it is not properly limited to the time period at issue in this case. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 583 Admit that Brown & Root was the primary construction contractor for the Bishop facility in 1960. RESPONSE: Celanese objects to this request as vague, ambiguous and overly broad in that it is not properly limited to the time period at issue in this case. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 584 Admit that Brown & Root was the primary construction contractor for the Bishop facility in 1961. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 192 98102 RESPONSE: Celanese objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese admits that Brown & Root was the primary independent construction contractor to the extent capital improvement projects occurred during the stated period. REQUEST FOR ADMISSION NO. 585 Admit that Brown & Root was the primary construction contractor for the Bishop facility in 1962. RESPONSE: Celanese objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese admits that Brown & Root was the primary independent construction contractor to the extent capital improvement projects occurred during the stated period. REQUEST FOR ADMISSION NO. 586 Admit that Brown & Root was the primary construction contractor for the Bishop facility in 1963. RESPONSE: Celanese objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese admits that Brown & Root was the primary independent construction contractor to the extent capital improvement projects occurred during the stated period. REQUEST FOR ADMISSION NO. 587 Admit that Brown & Root was the primary construction contractor for the Bishop facility Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 193 98102 in 1964. RESPONSE: Celanese objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese admits that Brown & Root was the primary independent construction contractor to the extent capital improvement projects occurred during the stated period. REQUEST FOR ADMISSION NO. 588 Admit that Brown & Root was the primary construction contractor for the Bishop facility in 1965. RESPONSE: Celanese objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. . Subject to and without waiving the foregoing objections, Celanese admits that Brown 81Root was the primary independent construction contractor to the extent capital improvement projects occurred during the stated period. REQUEST FOR ADMISSION NO. 589 Admit that Brown &. Root was the primary construction contractor for the Bishop facility in 1966. RESPONSE: Celanese objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese admits that Brown & Root was the primary independent construction contractor to the extent capital improvement projects occurred during the stated period. REQUEST FOR ADMISSION NO. 590 Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 194 98102 Admit that Brown & Root was the primary construction contractor for the Bishop facility in 1967. RESPONSE: Celanese objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese admits that Brown & Root was the primary independent construction contractor to the extent capital improvement projects occurred during the stated period. REQUEST FOR ADMISSION NO. 591 v Admit that Brown & Root was the primary construction contractor for the Bishop facility in 1968. RESPONSE: Celanese objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese admits that Brown & Root was the primary independent construction contractor to the extent capital improvement projects occurred during the stated period. REQUEST FOR ADMISSION NO. 592 Admit that Brown & Root was the primary construction contractor for the Bishop facility in 1969. RESPONSE: Celanese objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese admits that Brown & Root was the primary independent construction contractor to the extent capital improvement projects occurred during the stated period. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 195 98102 REQUEST FOR ADMISSION NO. 593 Admit that Brown & Root was the primary construction contractor for the Bishop facility in 1970. RESPONSE: Celanese objects to this request because it seektr information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese admits that Brown & Root was the primary independent construction contractor to the extent capital improvement projects occurred during the stated period. REQUEST FOR ADMISSION NO. 594 Admit that Brown & Root was the primary construction contractor for the Bishop facility in 1971. RESPONSE: Celanese objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese admits that Brown & Root was the primary independent construction contractor to the extent capital improvement projects occurred during the stated period. REQUEST FOR ADMISSION NO. 595 Admit that Brown & Root was the primary construction contractor for the Bishop facility in 1972. RESPONSE: Celanese objects to this request as vague, ambiguous and overly broad in that it is not properly limited to the time period at issue in this case. Celanese fqrther objects to this request because it seeks information that is neither relevant nor reasonably calculated Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 196 98102 to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 596 Admit that ABI was the primary maintenance contractor for the Bishop facility in 1959. RESPONSE: Celanese objects to this request as vague, ambigypus and overly broad in that it is not properly limited to the time period at issue in this case. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 597 Admit that ABI was the primary maintenance contractor for the Bishop facility in 1960. RESPONSE: Celanese objects to this request as vague, ambiguous and overly broad in that it is not properly limited to the time period at issue in this case. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 598 Admit that ABI was the primary maintenance contractor for the Bishop facility in 1961. RESPONSE: Celanese admits that Arthur Brothers was the primary independent maintenance contractor for the Bishop plant during the stated period. REQUEST FOR ADMISSION NO. 599 Admit that ABI was the primary maintenance contractor for the Bishop facility in 1962. RESPONSE: Celanese LtcL's Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 197 98102 Celanese admits that Arthur Brothers was the primary independent maintenance contractor for the Bishop plant during the stated period. REQUEST FOR ADMISSION NO. 600 Admit that ABI was the primary maintenance contractor for the Bishop facility in 1963. RESPONSE: Celanese admits that Arthur Brothers was the primary independent maintenance contractor for the Bishop plant during the stated period. REQUEST FOR ADMISSION NO. 601 Admit that ABI was the primary maintenance contractor for the'Bishop facility in 1964. RESPONSE: Celanese admits that Arthur Brothers was the primary independent maintenance contractor for the Bishop plant during the stated period. REQUEST FOR ADMISSION NO. 602 Admit that ABI was the primary maintenance contractor for the Bishop facility in 1965. RESPONSE: Celanese admits that Arthur Brothers was the primary independent maintenance contractor for the Bishop plant during the stated period. REQUEST FOR ADMISSION NO. 603 Admit that ABI was the primary maintenance contractor for the Bishop facility in 1966. RESPONSE: Celanese admits that Arthur Brothers was the primary independent maintenance contractor for the Bishop plant during the stated period. REQUEST FOR ADMISSION NO. 604 Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 198 98102 Admit that ABI was the primary maintenance contractor for the Bishop facility in 1967. RESPONSE: Celanese admits that Arthur Brothers was the primary independent maintenance contractor for the Bishop plant during the stated period. REQUEST FOR ADMISSION NO. 605 -- Admit that ABI was the primary maintenance contractor for the Bishop facility in 1968. RESPONSE: Celanese admits that Arthur Brothers was the primary independent maintenance contractor for the Bishop plant during the stated period. REQUEST FOR ADMISSION NO. 606 Admit that ABI was the primary maintenance contractor for the Bishop facility in 1969. RESPONSE: Celanese admits that Arthur Brothers was the primary independent maintenance contractor for the Bishop plant during the stated period. REQUEST FOR ADMISSION NO. 607 Admit that ABI was the primary maintenance contractor for the Bishop facility in 1970. RESPONSE: Celanese admits that Arthur Brothers was the primary independent maintenance contractor for the Bishop plant during the stated period. REQUEST FOR ADMISSION NO. 608 Admit that ABI was the primary maintenance contractor for the Bishop facility in 1971. RESPONSE: Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 199 98102 Celanese admits that Arthur Brothers was the primary independent maintenance contractor for the Bishop plant during the stated period. REQUEST FOR ADMISSION NO. 609 Admit that ABI was the primary maintenance contractor for the Bishop facility in 1972. RESPONSE: -- Celanese objects to this request as vague, ambiguous and overly broad in that it is not properly limited to the time period at issue in this case. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. " * REQUEST FOR ADMISSION NO. 610 Admit that Celanese employees purchased asbestos containing insulation materials that were installed by contractor employees in 1959. RESPONSE: Celanese objects to this request as vague, ambiguous and overly broad in that it is not properly limited to the time period and/or plant at issue in this case. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 611 Admit that Celanese employees purchased asbestos containing insulation materials that were installed by contractor employees in 1960. RESPONSE: Celanese objects to this request as vague, ambiguous and overly broad in that it is not properly limited to the time period and/or plant at issue in this case. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 612 Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 200 98102 Admit that Celanese employees purchased asbestos containing insulation materials that were installed by contractor employees in 1961. RESPONSE: Celanese objects to this request as vague, ambiguous and overly broad in that it is not properly plant at issue in this case. Celanese also objects to this request on the grounds that it is overly broad and harassing in that it is not properly limited as to scope and it seeks information regarding contractors other than the independent contractor for whom plaintiff claims to have worked, Arthur Brother, Inc. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Cejanese on information and belief admits that it ultimately paid for insulation materials, gaskets and packings used by the independent contractors it hired, but believes such materials were generally selected, estimated and ordered by the independent contractors themselves. REQUEST FOR ADMISSION NO. 613 Admit that Celanese employees purchased asbestos containing insulation materials that were installed by contractor employees in 1962. RESPONSE: Celanese objects to this request as vague, ambiguous and overly broad in that it is not properly plant at issue in this case. Celanese also objects to this request on the grounds that it is overly broad and harassing in that it is not properly limited as to scope and it seeks information regarding contractors other than the independent contractor for whom plaintiff claims to have worked, Arthur Brother, Inc. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese on information and belief admits that it ultimately paid for insulation materials, gaskets and packings used by the independent contractors it hired, but believes such materials were generally selected, estimated and ordered by the independent contractors themselves. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 201 98102 REQUEST FOR ADMISSION NO. 614 Admit that Celanese employees purchased asbestos containing insulation materials that were installed by contractor employees in 1963. RESPONSE: Celanese objects to this request as vague, ambiguous and overly broad in that it is not properly plant at issue in this case. Celanese alscrCbjects to this request on the grounds that it is overly broad and harassing in that it is not properly limited as to scope and it seeks information regarding contractors other than the independent contractor for whom plaintiff claims to have worked, Arthur Brother, Inc. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese on information and belief admits that it ultimately paid for insulation materials, gaskets and packings used by the independent contractors it hired, but believes such materials were generally selected, estimated and ordered by the independent contractors themselves. REQUEST FOR ADMISSION NO. 615 Admit that Celanese employees purchased asbestos containing insulation materials that were installed by contractor employees in 1964. RESPONSE: Celanese objects to this request as vague, ambiguous and overly broad in that it is not properly plant at issue in this case. Celanese also objects to this request on the grounds that it is overly broad and harassing in that it is not properly limited as to scope and it seeks information regarding contractors other than the independent contractor for whom plaintiff claims to have worked, Arthur Brother, Inc. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese on information and belief admits that it ultimately paid for insulation materials, gaskets and packings used by the independent contractors it hired, but believes such materials were generally selected, estimated and ordered by the independent contractors themselves. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 202 98102 REQUEST FOR ADMISSION NO. 616 Admit that Celanese employees purchased asbestos containing insulation materials that were installed by contractor employees in 1965. RESPONSE: Celanese objects to this request as vague, ambiguous and overly broad in that it is not properly plant at issue in this case. Celanese also objects to this request on the grounds that it is overly broad and harassing in that it is not properly limited as to scope and it seeks information regarding contractors other than the independent contractor for whom plaintiff claims to have worked, Arthur Brother, Inc. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. ' Subject to and without waiving the foregoing objections, Celanese on information and belief admits that it ultimately paid for insulation materials, gaskets and packings used by the independent contractors it hired, but believes such materials were generally selected, estimated and ordered by the independent contractors themselves. REQUEST FOR ADMISSION NO. 617 Admit that Celanese employees purchased asbestos containing insulation materials that were installed by contractor employees in 1966. RESPONSE: Celanese objects to this request as vague, ambiguous and overly broad in that it is not properly plant at issue in this case. Celanese also objects to this request on the grounds that it is overly- broad and harassing in that it is not properly limited as to scope and it seeks information regarding contractors .other than the independent contractor for whom plaintiff claims to have worked, Arthur Brother, Inc. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese on information and belief admits that it ultimately paid for insulation materials, gaskets and packings used by the independent contractors it hired, but believes such materials were generally selected, estimated and ordered by the independent contractors themselves. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 203 98102 REQUEST FOR ADMISSION NO. 618 Admit that Celanese employees purchased asbestos containing insulation materials that were installed by contractor employees in 1967. RESPONSE: Celanese objects to this request as vague, ambiguous and overly broad in that it is not properly plant at issue in this case. Celanese also objects to this request on the grounds that it is overly broad and harassing in that it is not properly limited as to scope and it seeks information regarding contractors other than the independent contractor for whom plaintiff claims to have worked, Arthur Brother, Inc. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. ' Subject to and without waiving the foregoing objections, Celanese on information and belief admits that it ultimately paid for insulation materials, gaskets and packings used by the independent contractors it hired, but believes such materials were generally selected, estimated and ordered by the independent contractors themselves. REQUEST FOR ADMISSION NO. 619 Admit that Celanese employees purchased asbestos containing insulation materials that were installed by contractor employees in 1968. RESPONSE: Celanese objects to this request as vague, ambiguous and overly broad in that it is not properly plant at issue in this case. Celanese also objects to this request on the grounds that it is overly broad and harassing in that it is not properly limited as to scope and it seeks information regarding contractors other than the independent contractor for whom plaintiff claims to have worked, Arthur Brother, Inc. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese on information and belief admits that it ultimately paid for insulation materials, gaskets and packings used by the independent contractors it hired, but believes such materials were generally selected, estimated and ordered by the independent contractors themselves. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 204 98102 REQUEST FOR ADMISSION NO. 620 Admit that Celanese employees purchased asbestos containing insulation materials that were installed by contractor employees in 1969. RESPONSE: Celanese objects to this request as vague, ambiguous and overly broad in that it is not properly plant at issue in this case. Celanese also objects to this request on the grounds that it is overly broad and harassing in that it is not properly limited as to scope and it seeks information regarding contractors other than the independent contractor for whom plaintiff claims to have worked, Arthur Brother, Inc. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese on information and belief admits that it ultimately paid for insulation materials, gaskets and packings used by the independent contractors it hired, but believes such materials were generally selected, estimated and ordered by the independent contractors themselves. REQUEST FOR ADMISSION NO. 621 Admit that Celanese employees purchased asbestos containing insulation materials that were installed by contractor employees in 1970. RESPONSE: Celanese objects to this request as vague, ambiguous and overly broad in that it is not properly plant at issue in this case. Celanese also objects to this request on the grounds that it is overly broad and harassing in that it is not properly limited as to scope and it seeks information regarding contractors other than the independent contractor for whom plaintiff claims to have worked, Arthur Brother, Inc. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese on information and belief admits that it ultimately paid for insulation materials, gaskets and packings used by the independent contractors it hired, but believes such materials were generally Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 205 98102 selected, estimated and ordered by the independent contractors themselves. REQUEST FOR ADMISSION NO. 622 Admit that Celanese employees purchased asbestos containing insulation materials that were installed by contractor employees in 1971. RESPONSE: Celanese objects to this request as vague, ambiguous and overly broad in that it is not properly plant at issue in this case. Celanese also objects to this request on the grounds that it is overly broad and harassing in that it is not properly limited as to scope and it seeks information regarding contractors other than the independent contractor for whom plaintiff claims to have worked, Arthur Brother, Inc. Celanese further objects to this request because it seeks information that is neither relevant'nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese on information and belief admits that it ultimately paid for insulation materials, gaskets and packings used by the independent contractors it hired, but believes such materials were generally selected, estimated and ordered by the independent contractors themselves. REQUEST FOR ADMISSION NO. 623 Admit that Celanese employees purchased asbestos containing insulation materials that were installed by contractor employees in 1972. RESPONSE: Celanese objects to this request as vague, ambiguous and overly broad in that it is not properly limited to the time period at issue in this case. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO, 624 Admit that Celanese purchased asbestos containing insulation for use by contractor employees at the Bishop facility between the years of 1959-72. / RESPONSE: Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 206 98102 Celanese objects to this request overly broad to the extent that it is not properly limited to the time period at issue in this case. Celanese also objects to this request on the grounds that it is overly broad and harassing in that it is not properly limited as to scope and it seeks information regarding contractors other than the independent contractor for whom plaintiff claims to have worked, Arthur Brother, Inc. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, see the responses to Request for Admission Nos. 610 - 623 above. REQUEST FOR ADMISSION NO. 625 Admit that Celanese purchased asbestos containing gasket materials for use by contractor employees at the Bishop facility between the years of 1959-72. RESPONSE: Celanese objects to this request overly broad to the extent that it is not properly limited to the time period at issue in this case. Celanese also objects to this request on the grounds that it is overly broad and harassing in that it is not properly limited as to scope and it seeks information regarding contractors other than the independent contractor for whom plaintiff claims to have worked, Arthur Brother, Inc. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, see the responses to Request for Admission Nos. 610 - 623 above. REQUEST FOR ADMISSION NO. 626 Admit that Celanese purchased asbestos containing packing materials for use by contractor employees at the Bishop facility between the years of 1959-72. RESPONSE: Celanese objects to this request overly broad to the extent that it is not properly limited to the time period at issue in this case. Celanese also objects to this request on the Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 207 98102 grounds that it is overly broad and harassing in that it is not properly limited as to scope and it seeks information regarding contractors other than the independent contractor for whom plaintiff claims to have worked, Arthur Brother, Inc. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, see the responses to Request for Admission Nos. 610 - 623 above. REQUEST FOR ADMISSION NO. 627 Admit that Celanese purchased asbestos containing pipe covering, including Owens- Coming and Kaylo, for use by contractor employees at the Bishop facility between the years of 1959-72. ; . l RESPONSE: Celanese objects to this request overly broad to the extent that it is not properly limited to the time period at issue in this case. Celanese also objects to this request on the grounds that it is overly broad and harassing in that it is not properly limited as to scope and it seeks information regarding contractors other than the independent contractor for whom plaintiff claims to have worked, Arthur Brother, Inc. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, see the responses to Request for Admission Nos. 610 - 623 above. REQUEST FOR ADMISSION NO. 628 Admit that after purchase by Celanese, asbestos containing materials for use by contractors would be placed in the contractor warehouse. RESPONSE: Celanese objects to this request vague, ambiguous and overly broad to the extent that it is not properly limited to the time period and/or plant at issue in this case. Celanese also objects to this request on the grounds that it is overly broad and harassing in that it is not properly limited as to scope and it seeks information regarding contractors other than the independent contractor for whom plaintiff claims to have worked, Arthur Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 208 98102 Brother, Inc. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Furthermore, this request is based on an improper premise and assumes facts not in evidence. Subject to and without waiving the foregoing objections, after reasonable inquiry, the information known or reasonably obtainable is insufficient to enable Celanese to admit or deny this request. REQUEST FOR ADMISSION NO. 629 Admit that safety equipment was a reimbursable item in contracts made with independent contractors at the Bishop facility. v RESPONSE: Celanese objects to this request vague, ambiguous and overly broad to the extent that it is not properly limited to the time period at issue in this case. Celanese also objects to this request on the grounds that it is overly broad and harassing in that it is not properly limited as to scope and it seeks information regarding contractors other than the independent contractor for whom plaintiff claims to have worked, Arthur Brother, Inc. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, denied. REQUEST FOR ADMISSION NO. 630 Admit that design engineering specifications were provided by Celanese to construction and maintenance contractors at the Bishop facility. RESPONSE: See responses to Request for Admission Nos. 500 - 510, 514 - 524, 528 - 538, 542 552, 556 - 566, 570 - 580, above. REQUEST FOR ADMISSION NO. 631 Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 209 98102 Admit that Celanese obtained asbestos containing materials from Industrial Insulators for use by ABI employees. RESPONSE: Celanese objects to this request vague, ambiguous and overly broad to the extent that it is not properly limited to the time period and/or plant at issue in this case. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese admits that the insulation materials selected, estimated and ordered by Arthur Brothers for use at the Bishop facility during the time period relevant to this case were generally obtained by them from Industrial Insulators, often with direct advice on selection and estimation by Industrial Insulators. REQUEST FOR ADMISSION NO. 632 Admit that Celanese furnished all insulation materials to ABI for use the Bishop facility from 1961-70. RESPONSE: See responses to Requests for Admission Nos. 610 - 623, above. REQUEST FOR ADMISSION NO. 633 Admit that ABI provided day to day maintenance for the Bishop facility from 1959-1972. RESPONSE: See responses to Request for Admission Nos. 596 - 609, above. REQUEST FOR ADMISSION NO. 634 Admit that between the years of 1959-1972, Celanese project managers and project engineers would have overall responsibility for getting contractor new construction projects completed. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 210 98102 RESPONSE: Celanese objects to this request vague, ambiguous and overly broad to the extent that it is not properly limited to the time period and/or plant at issue in this case. Celanese also objects to this request on the grounds that it is overly broad and harassing in that it is not properly limited as to scope and it seeks information regarding contractors other than the independent contractor for whom plaintiff claims to have worked, Arthur Brother, Inc. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to-iBad to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celanese admits only that its project managers were ultimately responsible for seeing that projects undertaken by independent contractors were performed on schedule, within budget and completed in a satisfactory manner. Celanese states in connection with thisresponse that the manner, method and operative detail of accomplishing such work would have been left up to the independent contractors. REQUEST FOR ADMISSION NO. 635 Admit that Celanese project managers and project engineers would have meeting with contractors to review construction and maintenance schedules between the years of 1969 and 1972. RESPONSE: Celanese objects to this request vague, ambiguous and overly broad to the extent that it is not properly limited to the time period and/or plant at issue in this case. Celanese also objects to this request on the grounds that it is overly broad and harassing in that it is not properly limited as to scope and it seeks information regarding contractors other than the independent contractor for whom plaintiff claims to have worked, Arthur Brother, Inc. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections and subject to its response to Request for Admission No. 634, above, Celanese admits that its representatives would meet from time to time with upper level management of independent contractors to review scheduling matters. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 211 98102 REQUEST FOR ADMISSION NO. 636 Admit that Celanese project managers and project engineers would have meetings with contractors to determine when each part of a maintenance or new construction ' schedule would be completed. RESPONSE: Celanese objects to this request vague, ambiguous'&nd overly broad to the extent that it is not properly limited to the time period and/or plant at issue in this case. Celanese also objects to this request on the grounds that it is overly broad and harassing in that it is not properly limited as to scope and it seeks information regarding contractors other than the independent contractor for whom plaintiff claims to have worked, Arthur Brother, Inc. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the`discovery of admissible evidence. Subject to and without waiving the foregoing objections and subject to its response to Request for Admission No. 634, above, Celanese admits that its representatives would meet from time to time with upper level management of independent contractors to review scheduling matters. REQUEST FOR ADMISSION NO. 637 Admit that Celanese project managers and/or and project engineers retained the power to change contractor construction and maintenance schedules. RESPONSE: Celanese objects to this request vague, ambiguous and overly broad to the extent that it is not properly limited to the time period and/or plant at issue in this case. Celanese also objects to this request on the grounds that it is overly broad and harassing in that it is not properly limited as to scope and it seeks information regarding contractors other than the independent contractor for whom plaintiff claims to have worked, Arthur Brother, Inc. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. r Subject to and without waiving the foregoing objections and subject to its response to Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 212 98102 Request for Admission Nos. 634 and 635, above, Celanese admits that as a matter of contract its representatives could implement overall scheduling changes applicable to projects being undertaken by. independent contractors. REQUEST FOR ADMISSION NO. 638 Admit there was no Celanese employee who was responsible for evaluating the safety of products being put into service on its facilities in 1959. ***** RESPONSE: Celanese objects to this request as vague, ambiguous and overly broad in that it is not properly limited to the time period and/or plant at issue in this case. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 639 Admit there was no Celanese employee who was responsible for evaluating the safety of products being put into service on its facilities in 1960. RESPONSE: Celanese objects to this request as vague, ambiguous and overly broad in that it is not properly limited to the time period and/or plant at issue in this case. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 640 Admit there was no Celanese employee who was responsible for evaluating the safety of products being put into service on its facilities in 1961. RESPONSE: Celanese objects to this request as vague, ambiguous and overly broad in that it is not properly limited to the plant at issue in this case. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 213 98102 Subject to and without waiving the foregoing objections, denied as stated. REQUEST FOR ADMISSION NO. 641 Admit there was no Celanese employee who was responsible for evaluating the safety of products being put into service on its facilities in 1962. RESPONSE: Celanese objects to this request as vague, ambiguous and overly broad in that it is not properly limited to the plant at issue in this case. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving.the foregoing objections, deniqd as stated. REQUEST FOR ADMISSION NO. 642 Admit there was no Celanese employee who was responsible for evaluating the safety of products being put into service on its facilities in 1963. RESPONSE: Celanese objects to this request as vague, ambiguous and overly broad in that it is not properly limited to the plant at issue in this case. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, denied as stated. REQUEST FOR ADMISSION NO. 643 Admit there was no Celanese employee who was responsible for evaluating the safety of products being put into service on its facilities in 1964. RESPONSE: Celanese objects to this request as vague, ambiguous and overly broad in that it is not properly limited to the plant at issue in this case. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 214 98102 the discovery of admissible evidence. Subject to and without waiving the foregoing objections, denied as stated. REQUEST FOR ADMISSION NO. 644 Admit there was no Celanese employee who was responsible for evaluating the safety of products being put into service on its facilities in 1965. RESPONSE: Celanese objects to this request as vague, ambiguous and overly broad in that it is not properly limited to the plant at issue in this case. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, denied as stated. REQUEST FOR ADMISSION NO. 645 Admit there was no Celanese employee who was responsible for evaluating the safety of products being put into service on its facilities in 1966. RESPONSE: Celanese objects to this request as vague, ambiguous and overly broad in that it is not properly limited to the plant at issue in this case. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, denied as stated. REQUEST FOR ADMISSION NO. 646 Admit there was no Celanese employee who was responsible for evaluating the safety of products being put into service on its facilities in 1967. RESPONSE: t Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 215 98102 Celanese objects to this request as vague, ambiguous and overly broad in that it is not properly limited to the plant at issue in this case. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, denied as stated. REQUEST FOR ADMISSION NO. 647 ^ Admit there was no Celanese employee who was responsible for evaluating the safety of products being put into service on its facilities in 1968. RESPONSE: Celanese objects to this request as vague, ambiguous and overly broad in that it is not properly limited to the plant at issue in this case. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, denied as stated. REQUEST FOR ADMISSION NO. 648 Admit there was no Celanese employee who was responsible for evaluating the safety of products being put into service on its facilities in 1969. RESPONSE: Celanese objects to this request as vague, ambiguous and overly broad in that it is not properly limited to the plant at issue in this case. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, denied as stated. REQUEST FOR ADMISSION NO. 649 Admit there was no Celanese employee who was responsible for evaluating the safety of products being put into service on its facilities in 1970. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 216 98102 RESPONSE: Celanese objects to this request as vague, ambiguous and overly broad in that it is not properly limited to the plant at issue in this case. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, denied as stated. REQUEST FOR ADMISSION NO. 650 Admit there was no Celanese employee who was responsible for evaluating the safety of products being put into service on its facilities in 1971. RESPONSE: I Celanese objects to this request as vague, ambiguous and overly broad in that it is not properly limited to the plant at issue in this case. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, denied as stated. REQUEST FOR ADMISSION NO. 651 Admit there was no Celanese employee who was responsible for evaluating the safety of products being put into service on its facilities in 1972. RESPONSE: Celanese objects to this request as vague, ambiguous and overly broad in that it is not properly limited to the time period and/or plant at issue in this case. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR ADMISSION NO. 652 Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 217 98102 Admit that Celanese personnel had the right to terminate contractor work if they observed an eminent hazard .at the Bishop facility. RESPONSE: Celanese objects to this request vague, ambiguous and overly broad to the extent that it is not properly limited to the time period at issue in this case. Celanese also objects to this request on the grounds that it is overly broad and harassing in that it is not properly limited as to scope and it seeks information regarding contractors other than the independent contractor for whom plaintiff claims to have worked, Arthur Brother, Inc. Celanese further objects to this request because it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the foregoing objections, Celaqese admits that it could ask independent contractors to cease work if they were observed engaging in activities that posed an imminent and substantial risk of serious harm to person or property, but states that wherever possible it reported unsafe practices to the independent contractor's supervisors for them to take appropriate corrective action. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 218 98102 SPECIFIC RESPONSES TO PLAINTIFF'S SECOND SET OF REQUESTS FOR PRODUCTION REQUEST FOR PRODUCTION NO. 1 Produce all surveys, inspection reports, or data compilations concerning the Bishop facility done by David Barrett. RESPONSE Celanese additionally objects to this request because: 1. It fails to describe with reasonable particularity the item or category of items sought to be inspected, as required byrRule 196.1 of the Texas Rules of Civil Procedure; 2. It seeks matters that are not relevant to the subject matter of this lawsuit or reasonably calculated to lead to the discovery of admissible evidence; 3. It is unlimited as to time and/or scope; 4. It is vague, ambiguous, overly broad and unduly burdensome; and 5. It is duplicative of information sought in Plaintiff's First and Second Sets of Requests for Production. REQUEST FOR PRODUCTION NO. 2 Produce all receiving reports for asbestos containing materials at the Bishop facility. RESPONSE Celanese additionally objects to this request because: 1. It fails to describe with reasonable particularity the item or category of items sought to be inspected, as required by Rule 196.1 of the Texas Rules of Civil Procedure; Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 219 98102 2. It seeks matters that are not relevant to the subject matter of this lawsuit or reasonably calculated to lead to the discovery of admissible evidence; 3. It is not properly limited to the time period at issue; 4. It is vague, ambiguous, overly broad and unduly burdensome; and 5. It is duplicative and duplicative of information sought in Plaintiff's First and Second Sets of Requests for Production. Subject to and without waiving these objections, see the documents previously produced to you on July 13, 1999, in Cause No. 97-8-50930-B, Arthur Dominguez, et ai v. Owens-Coming Fiberglas, et ai, in the 135th Judicial District Court of Victoria County, Texas, bates-labeled 000001-006430. See also the documents previously produced on September 29, 2000, in Cause No. 90G2055, Weldon R^Moake, et ai v. Owens Corning Fiberglas, et .ai, in the 239th Judicial District Court of Brazoria County, Texas, bates-labeled 9220-10363. REQUEST FOR PRODUCTION NO. 3 Produce all requisition orders for asbestos containing materials at the Bishop facility. RESPONSE Celanese additionally objects to this request because: 1. It fails to describe with reasonable particularity the item or category of items sought to be inspected, as required by Rule 196.1 of the Texas Rules of Civil Procedure; 2. It seeks matters that are not relevant to the subject matter of this lawsuit or reasonably calculated to lead to the discovery of admissible evidence; 3. It is not properly limited to the time period at issue; 4. It is vague, ambiguous, overly broad and unduly burdensome; and 5. It is duplicative and duplicative of information sought in Plaintiff's First and Second Sets of Requests for Production. Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 220 98102 Subject to and without waiving these objections, see the documents previously produced to you on July 13, 1999, in Cause No. 97-8-50930-B, Arthur Dominguez, etal. v. Owens-Corning Fiberglas, et ai, in the 135th Judicial District Court of Victoria County, Texas, bates-labeled 000001-006430. See also the documents previously produced on September 29, 2000, in Cause No. 90G2055, Weldon R. Moake, et ai. v. Owens Corning Fiberglas, et ai., in the 239th Judicial District Court of Brazoria County, Texas, bates-labeled 9220-10363. REQUEST FOR PRODUCTION NO. 4 ^ Produce all purchase orders for asbestos containing materials at the Bishop facility. RESPONSE Celanese additionally objects to this request because: 1. It fails to describe with reasonable particularity the item or category of items sought to be inspected, as required by Rule 196.1 of the Texas Rules of Civil Procedure; 2. It seeks matters that are not relevant to the subject matter of this lawsuit or reasonably calculated to lead to the discovery of admissible evidence; 3. It is not properly limited to the time period at issue; 4. It is vague, ambiguous, overly broad and unduly burdensome; and 5. It is duplicative and duplicative of information sought in Plaintiff's First and Second Sets of Requests for Production. Subject to and without waiving these objections, see the documents previously produced to you on July 13, 1999, in Cause No. 97-8-50930-B, Arthur Dominguez, et ai. /. Owens-Corning Fiberglas, etal., in the 135th Judicial District Court of Victoria County, Texas, bates-labeled 000001-006430. See also the documents previously produced on September 29, 2000, in Cause No. 90G2055, Weldon R. Moake, et ai. v. Owens Corning Fiberglas, et ai, in the 239th Judicial District Court of Brazoria County, Texas, bates-labeled 9220-10363. REQUEST FOR PRODUCTION NO. 5 Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 221 98102 Produce all gate logs for the main gate for the Bishop facility for 1959-1972. RESPONSE Celanese additionally objects to this request because: 1. It fails to describe with reasonable particularity the item or category of items sought to be inspected, as required by Rule 196.1 of the Texas Rules of Civil Procedure; 2. It seeks matters that are not relevant to the subject matter of this lawsuit or reasonably calculated to lead to the discovery of admissible evidence; 3. It is not properly limited to the time period at issue; y 4. It is vague, ambiguous, overly broad and unduly burdensome; and 5. It is duplicative and duplicative of information sought in Plaintiff's First and Second Sets of Requests for Production. REQUEST FOR PRODUCTION NO. 6 Produce all gate logs for the ABI contractor gates for the Bishop facility for 1959-1972. RESPONSE Celanese additionally objects to this request because: 1. It fails to describe with reasonable particularity the item or category of items sought to be inspected, as required by Rule 196.1 of the Texas Rules of Civil Procedure; 2. It seeks matters that are not relevant to the subject matter of this lawsuit or reasonably calculated to lead to the discovery of admissible evidence; 3. It is not properly limited to the time period at issue; 4. It is vague, ambiguous, overly broad and unduly burdensome; Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 222 98102 5. It is duplicative and duplicative of information sought in Plaintiff's First and Second Sets of Requests for Production; and 6. It is based on an improper premise and assumes facts not in evidence. Subject to these objections, see the documents previously produced to you on July 13, 1999 in Cause No. 97-8-50,930-B, Arthur Dominguez, et al. v. Owens-Coming Fiberglas, et al., in the 135th Judicial District Court of Victoria County, Texas, bateslabeled 000001-006430. See also the Arthur Brothers' contracts produced on April 14, 2000 in the Dolezal case. REQUEST FOR PRODUCTION NO. 7 Produce all accounting records -- including, but not limited to invoices -- regarding trade organizations. RESPONSE: Celanese additionally objects to this request because: 1. It fails to describe with reasonable particularity the item or category of items sought to be inspected, as required by Rule 196.1 of the Texas Rules of Civil Procedure; 2. It seeks matters that are not relevant to the subject matter of this lawsuit or reasonably calculated to lead to the discovery of admissible evidence; 3. It is unlimited in time and scope; and 4. It is vague, ambiguous, overly broad and unduly burdensome. REQUEST FOR PRODUCTION NO. 8 Produce all surveys, notes, or documents related to Kemper insurance visits to the Bishop facility. RESPONSE Celanese additionally objects to this request because: Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 223 98102 1. It fails to describe with reasonable particularity the item or category of items sought to be inspected, as required by Rule 196.1 of the Texas Rules of Civil Procedure; 2. It seeks matters that are not relevant to the subject matter of this lawsuit or reasonably calculated to lead to the discovery of admissible evidence; 3. It is unlimited in time and scope; and 4. It is vague, ambiguous, overly broad and unduly burdensome. Subject to and without waiving the foregoing objections, any responsive still in existence and located via a reasonably diligent search have already been produced to Plaintiff - see documents bates labeled, 000242-243; 001046-1047; 001304-1305; 001388-1389. REQUEST FOR PRODUCTION NO. 9 Produce all epidemiology studies, whether internal or published involving Celanese employees. RESPONSE Celanese additionally objects to this request because: 1. It fails to describe with reasonable particularity the item or category of items sought to be inspected, as required by Rule 196.1 of the Texas Rules of Civil Procedure; 2. It seeks matters that are not relevant to the subject matter of this lawsuit or reasonably calculated to lead to the discovery of admissible evidence; 3. It is unlimited in time and scope; and 4. It is vague, ambiguous, overly broad and unduly burdensome. REQUEST FOR PRODUCTION NO. 10 Produce all studies or compilations of Celanese employees death certificates Celanese Ltd.'s Responses to Plaintiff Fidencio Sanchez's Second Set of Requests for Admission and Third Set of Requests for Production to Defendant Celanese Ltd. 224 98102