Document jmoZzdB7goy2Ng4XV5GD89zpp

18TH JUDICIAL DISTRICT COURT PARISH OF IBERVILLE , STATE OF LOUISIANA LORRAINE PEGGY WILLIAMS VERSUS MCCARTY CORPORATION, ET AL SUIT NO.: 39,404 DIVISION 'V'D" EXXON CORPORATION'S RESPONSE TO PLAINTIFF'S REQUEST FOR ADMISSIONS_OF_FACT Exxon Corporation ("Exxon") hereby responds to the request for admissions of fact served on it by the plaintiff on or about July 21, 1991, as follows: REQUEST FOR ADMISSION NUMBER 1 The attached copy of the document entitled "Industrial Hygiene Survey of the Baton Rouge Refinery, Louisiana, Division, Esso Standard Oil Company, February, March, and April, 1949", prepared by James Morgan and W.C.L. Hemeon of the Industrial Hygiene Foundation of America, Inc., is authentic. RESPONSE TO REQUEST FOR ADMISSION NUMBER_1 Exxon objects to request for admission number 1 because Exxon does not understand the meaning, within the context of the request for admission, of the word "authentic." Exxon believes, without a word-for-word comparison, that the document entitled "Industrial Hygiene Survey of the Baton Rouge Refinery, Louisiana Division, Esso Standard Oil Company, February, March, and April, 1949" which was attached to the request for admission is an accurate copy of the original of that_document^ Exxon further objects to this request for admission because it does not seek the admission of admissible or relevant fact. The document was not authored nor prepared by Exxon, * but was in fact prepared by Morgan and Hemeon of the Industrial Hygiene Foundation of MTUl8F0/OABCNrft EM002640 America, Inc., an entity which is separate from Exxon. The document does not purport to be, nor can it be construed to be, a statement by Exxon. It is hearsay and, that reason, cannot be introduced in these proceedings. REQUEST FOR ADMISSION NUMBER 2 for The attached copy of the document entitled "Dust Producing Operations in the Production of Petroleum Products and Associated Activities", prepared in July, 1937, by the Chief Safey Inspector of Standard Oil Company, N.J., is authentic. , RESPONSE TO REQUEST FOR ADMISSI0N_NUMBER_2 Exxon objects to this request for admission because it does not understand, within the context of the request for admission, the meaning of the word "authentic.-" Exxon does admit that the document entitled "Dust Producing Operations in the Production of Petroleum Products and Associated Activities", prepared in July, 1937 by t-he Chief Safety Inspector of Standard Oil Company, N.J., is an accurate copy of the original of that document. Beyond that, Exxon denies request for admission number 2. REQUEST FOR ADMISSION NUMBER 3 Exxon Corporation i.s the successor- of standard Oil Company, N.J. RESPONSE TO REQUEST FOR ADMISSION NUMBER 3 Denied. See response to interrogatory number 1 filed by Exxon on or about July 22, 1991. REQUEST FOR ADMISSION NUMBER 4 Exxon Corporation is the successor of Esso Standard Oil Company. RESPONSE TO REQUEST FOR ADMISSION NUMBER 4 Admitted. . REQUEST FOR ADMTSSTOM MTTMPgo a Exxon .Corporation is liable for any tortious conduct of Standard Oil Company, N.J. tfxutesro/oAtozwtft 2- EM002641 RESPONSE TO REQUEST FOR ADMISSION NUMBER 5 Exxon objects to request for admission number 5 because it seeks the admission of a legal conclusion as opposed to a factual or evidentiary matter. REQUEST FOR ADMISSION NUMBER .6 Exxon Corporation is liable for any tortious conduct of Esso Standard Oil Company. RESPONSE TO REQUEST FOR ADMISSION NUMBER 6 Exxon objects to request for admission number 6 for the same reason that it objected to request for admission number 5. whSubmitted by: Gary A. Bezet Bar Roll No. 3036 KEAN, MILLER, HAWTHORNE, D'ARMOND, McCOWAN <6 JARMAN Post Office Box 3513 Baton Rouge, Louisiana 70821 Telephone: (504) 387-0999 David W. Ledyard STRONG, PIPKIN, NELSON & BISSELL 1400 San Jacinto Building 595 Orleans Beaumont, Texas 77701-3255 Telephone: (409) 835-4581 CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing document has been mailed, postage prepaid, to all counsel of record. Baton Rouge, Louisiana , 1991. Gary A. Bezet WtLMSPCfCMOTXE* EHO 02642