Document jmM8o8No45zxv2ge8K61Z4Xnp

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF KENTUCKY AT LOUISVILLE KENNETH PEERENBOOM, ET AL PLAINTIFFS VS ) NO. C-81-0698-L(A) B. F. GOODRICH CHEMICAL COMPANY, ET AL. ) DEFENDANTS RESPONSE OF DEFENDANT, B. F. GOODRICH COMPANY TO PLAINTIFF'S REQUEST FOR PRODUCTION OF DOCUMENTS OF FEBRUARY 25, 1982 1. With respect to requests numbers 1, 3, 4, 5, 6, and 7, this defendant objects to responding to same on the basis that said requests are so overly broad as to be unintelligible and on the further basis that said requests are not reasonably couched to lead to the discovery of admissible evidence. Specifically, the defendant objects on the basis that said requests are not limited either as to location or as to a relevant time. Plaintiff's decedent, for example, ceased working at Goodrich in 1974 and no information obtained by any representative of Goodrich thereafter could possibly* lead to the discovery of information relevant to the subject matter of the complaint herein. 2. With respect to request number 2, if the plaintiffs will clarify which civil action in the State of New Jersey to which they are making reference, the defendant will attempt NGC39166 *>4 to respond to that request; however, with respect to what documen it might possibly offer as evidence in the trial of this case, no determination has been made at this time. _ ' :r';' X X --- ----/ ___________ Stephen F. Schuster Ogden, Robertson & Marshall 1200 One Riverfront Plaza Louisville, Kentucky 40202 (502) 582-1601 Counsel for Defendant, B. F. Goodrich Company CERTIFICATE OF SERVICE It is hereby certified that a true copy of the foregoing document was served this * - day of April, 1982 upon Mr. Fred R. Radolovich, Attorney for Plaintiffs, Suite 200, 440 South Seventh Street, Louisville, Kentucky 40203.and Mr. Walter Sales, Counsel for Union, Third Floor, M. E. Taylor Building, 312 South Fourth Street, Louisville, KY. 40202. Stephen F. Schuster NGC39167