Document g2mQqKbB32Bn13kMjnv6XLBD9

FREDER'C* M 8ABCN RUSSEll w BUO0 BRENT m ROSENThAl SARAH J CL>RK -ISA A B.UE. PH O MAP'1' E SKELNIK STEVEN 0 WOLENS 3>anE M ANDREW PETER A KRAUS JANiCE E ROBNSON SAMT RICHARC1' JENNIFER A CURRIE A Mr M B-UMENTHAL Mr. Michael J. Truncate Attorney at Law' 470 Orleans Street Beaumont, Texas 77701 Baron & Budd A PROFESSIONAL CORPORATION ATTORNEYS AMO COUNSELORS THE CENTRUM 3102 OAK LAWN AVENUE Suite i oo Dallas. Texas 75219-4281 521-3005 *ELCCOPIER (2<A>S20*1181 September 21, 1995 * PLAINTIFF'S EXHIBIT KM- 4 USA R KIVE -- _ ANGELYN SCMic StevC BAuG"man JEFFREY B SIMON Patrick n haines Au_CN Ml STefiARi KAY c REEVES LISA JERGC-LESNIAK KAREN M G AMMC N STEVEN M GRUBER KIMBERLY A CASTlES KCiTh k COuE JR MELISSA K HUTS DAVID DENNY * ue* nicd oni.v in ,L Aho mo "klCCNSCO OKI* in OK Via Fax: (409) 638-6959 RE: Kelly-Moore Paint Company's Answers to Plaintiffs' Master Interrogatories; In Re All Asbestos Related Personal Injury or Death Cases Filed or To Be Filed in Dallas County, Texas Dear Mr. Truncale: Based upon our prior telephone conversations, it is my understanding that you have agreed to provide complete answers to the following interrogatories: Interrogatory No. 6(e) {Specifically, Keily-Moore Paint Company will provide the percentage/asbestos content for each Kelly-Moore Paint Company asbestoscontaining product.} 7(a), 22, 23, 38, 39(c), 47, 51 and 54 Moreover, by way of clarification, it is also understood that: 5 Exhibit A is a complete list of Kelly-Moore Paint Company's asbestos-containing products. 10 No tests were performed by Kelly-Moore Paint Company on their asbestos-containing products. . Truncate - Kelly Moore Rule 11 9/21/95 15 Kelly-Moore Paint Company is unaware of any worker compensations claims or personal injury claims prior to 1970. 19 & 20 Kelly-Moore Paint Company is not withholding any answers or documents responsive to these interrogatories based upon privilege. 21 The two locations identified in Kelly-Moore Paint Company's answer are the only locations. 33 Kelly-Moore Paint Company identified all buyers (only three}. 48 Kelly-Moore Paint Company did not do any research on the health effects of asbestos. Finally, it is my understanding that you/your client will fully respond to Plaintiffs' interrogatories in thirty days {October 22, 1995). If this accurately reflects our conversations and agreements, please indicate so by signing below. If I can obtain this signed Rule 11 from you, I can postpone the hearing on the Motion to Compel presently set for tomorrow {Friday, September 22, 1995). If you have any problems with the foregoing, please let me know at your earliest convenience. Kindest regards. Sincerely, BARON & BUDD, P ,LLs20i Melissa K. H AGREED TO AND APPROVED BY: MICHAEL TRUNCALE, Attorney for Kelly-Moore Paint Company  * * Transmission Result Report ( Sep. 21. 1S95 l! nm t .Ji Fiie it:de Option Address (Group] 3849 1 An \r 914099386959 /\ * * BAR3K & 3UDB 4A | i Li wLv Result Page OK P 3 v R * s o n for Error 1) Hans up or linefail 3) N c answer 2) Susy 4) No facsimile connection Baron & Budd A PROFESSIONAL CORPORATION ATTORNEYS AND counselors THE CENTRUM 3102 OAK LAWN AVENUE SUITE 1100 Dallas, Texas 75219-4281 (214) 521-360$ TELECOPIER(214)520-1181 Ma/AsU ____ DATE: 4 / (including cover sheet) ADDITIONAL MESSAGE: Notice of Confidentiality The information contained in and transmitted with thisfacsimile is either subject to the Attorney-Client privilege; Attorney work product; or confidential and is intended only for the individual or entity designated above. You are hereby notified that any dissemination, distribution, copying, or use ofor reliance upon the information contained in and transmitted with thisfacsimile by or to anyone other than the recipient designated above by the sender is unauthorized and strictlyprohibited Ifyou have received this facsimile in error, please notify Baron & Bssdd by telephone at 214-521-3605immediately. Anyfacsimile erroneously SF&stShi&s&S toyou should be im&ed*3ely retim-wA to the sender by U.S.Mail, or ifauthorizafei-.i? gsaaStd ty the sender, destroyed