Document jnozdyZzra0eq6kmaxOd2MO2

PLAINTIFF'S EXHIBIT UPRC-108 NO. 99C0297-005 HARVEY ANDERS; EARL BELL; VERNELL BURLESON; SAMMIE CAROLTON BYARS; MARK W. LATHAM; ROY GWENLYN MCCORD; EDWARD PUMPHREY JIMMY RAY SMITH; AND JEWEL WILLIAMS VS. OWENS CORNING, ET AL IN THE DISTRICT COURT BOWIE COUNTY, TEXAS 5TM JUDICIAL DISTRICT DEFENDANT. CITGO PETROLEUM COMPANY'S ANSWERS AND RESPONSES TO PLAINTIFF. HARVEY ANDERS' FIRST SET OF INTERROGATORIES. FIRST REQUEST FOR PRODUCTION AND FIRST REQUEST FOR ADMISSIONS TO Plaintiff, Harvey Anders, et al by and through his attorney ofrecord, William Tapscott, Baron & Budd, A Professional Corporation, The Centrum, 3102 Oak Lawn Avenue, Suite 1100, Dallas, TX 75219. COMES NOW, CITGO PETROLEUM CORPORATION, one of the Defendants in the above styled cause, and makes and files its Objections and Responses to Plaintiffs First Set of Interrogatories, Request for Production, and Request for Admissions Propounded to Premises Defendants. Respectfully submitted, STRONG, PIPKIN, NELSON, BISSELL & LEDYARD, LLP. DNOC49S9G 84578 David W. Ledyard State Bar No. 121094(50 14th Floor, San Jacinto Building Beaumont, Texas 77701-3255 (409)981-1000 FAX(409)981-1010 ] ATTORNEYS FOR DEFENDANT, CITGO PETROLEUM CORPORATION CERTIFICATE OF SERVICE This will verify that a true and correct copy of Defendant Citgo Petroleum Corporation's Response to Plaintiffs' Interrogatories, Request for Admissions and Request for Production has been furnished to counsel for plaintiff, by certified mail, return receipt requested, and to all other known counsel of record by regular U.S. Mail, on this 3 T1 day of October, 2000. Da' yard' 1 ,s'4<7K 2 DEFENDANT'S OBJECTIONS AND ANSWERS TO DISCOVERY INTERROGATORY NO. 1: For each person who has supplied any information used in answering these interrogatories, state the name, address, job title, length of time employed by Defendant, and a year-by-year list of all other positions, titles, or jobs held when working for Defendant. ANSWER: Defendant objects to this interrogatory to the extent it seeks information the subject of which is protected from disclosure by the attorney work product privilege, the attorney/client privilege, the investigative privilege, the party communication privilege, or any other applicable privilege or immunity from discovery provided by TRCP 192.5. Without waiving the foregoing objections, Defendant responds as follows: These responses were prepared based on information gathered by defense counsel along with assistance of in-house counsel and other legal staff. REQUEST FOR ADMISSION NO. I: Admit that Defendant ordered, purchased or otherwise acquired asbestos-containing products, asbestos-containing friction products, and/or machinery requiring the use of asbestos or asbestos-containing products. RESPONSE: Defendant objects to this request as vague, ambiguous, and subject to multiple interpretations. Defendant further objects to this request as it is overly broad in that it is not limited in time nor scope either to time periods when Plaintiff allegedly worked on this Defendant's premises, to the premises on which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. _>V 2-WX9 IK4571!! 5 Without waiving the foregoing objections, Defendant denies this request. REQUEST FOR PRODUCTION NO. 1: Ifyou deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: Defendant objects to this request as vague, ambiguous, and subject to multiple interpretations. Defendant further objects to this request as it is overly broad in that it is not limited in time nor scope either to time periods when Plaintiffallegedly worked on this Defendant's premises, to the premises on which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR ADMISSION NO. 2: Admit that asbestos-containing products, asbestos-containing friction products, and/or machinery requiring the use ofasbestos or asbestos-containing products were utilized on Defendant's Premises between the years at issue. RESPONSE: Defendant objects to this request as vague, ambiguous and overly broad and to the extent it is not limited in time nor scope to time periods when Plaintiffwas allegedly on Defendant's premises, to the premises on which Plaintiffwas allegedly present, nor the area(s)within any ofDefendant's premises where Plaintiffallegedly present. Defendant objects to this request as the term "utilized" is vague, ambiguous and subject to multiple interpretations in the context of this suit. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August31,1983, V M`SV S4<\v 6 Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections, after reasonable inquiry, Defendant is unable to admit or deny at this time. INTERROGATORY NO. 2: If you admit the foregoing request, please list all asbestos-containing products used at Defendant's Premises and for each product state the following: a. What these products were used for b. From whom these products were purchased c. Where these products were installed d. Specific persons or contractors who install these products e. The first year each product was no longer purchased and installed on Defendant's premises. ANSWER: Defendant objects to this interrogatory as overly broad and burdensome and calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. This request is overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly was present on Defendant's premises, nor limited to the premises at which Plaintiff allegedly was present, nor the area(s) within any of Defendant's premises where Plaintiff allegedly was present. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. 7 REQUEST FOR PRODUCTION NO. 2: Produce all ordering and sales documents pertaining to the purchase or acquisition of such asbestos-containing products for use at Defendant's Premises, including but not limited to invoices, price quotations, purchase orders, requisitions, bills of lading, and other purchasing and/or shipping documents of the similar nature. RESPONSE: Defendant objects to this request as overly broad and burdensome and calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. This request is overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly was present on Defendant's premises, nor limited to the premises at which Plaintiff allegedly was present, nor the area(s) within any of Defendant's premises where Plaintiff allegedly was present. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR ADMISSION NO. 3: Admit that during the time Plaintiff was employed by Defendant, it was foreseeable that asbestos-containing products on Defendant's Premises would or could be removed, stripped, replaced or repaired at some time after installation. RESPONSE: Defendant objects to this request as overly broad and burdensome and calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery ofadmissible evidence. Defendant further objects because this request is vague, ambiguous and argumentative because the request assumes Plaintiff on Defendant's premises. Defendant further objects to this request as overly broad in that it is not limited to any area within Defendant's premises where Plaintiff allegedly was present and, therefore, is not relevant. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT I5M37S 8 Corporation changed its name to CITGO Petroleum Corporation. On August31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections, Defendant denies this request as Plaintiff was not an employee of this Defendant. INTERROGATORY NO 3. Please state whether any asbestos-containing products in place or in use at Defendant's Premises have been abated at any time. a. Ifso, list each person or company that performed such abatement services (including address and telephone number) b. State the dates and locations of each abatement procedure; c. State which asbestos-containing products were abated. ANSWER: Defendant objects to this interrogatory as overly broad and burdensome and calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant objects to the extent this interrogatory is not limited to premises on which Plaintiff allegedly worked, nor to the areas within Defendant's premises Plaintiff allegedly worked. Further this interrogatory is overly broad in that it seeks information for time periods other than those upon which Plaintiffs claims are based. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR PRODUCTION NO. 3' Produce all documents that in any way pertain to abatement ofasbestos-containing materials on Defendant's Premises, including but not limited to a removal plan or organized written criteria or schedule for the removal ofasbestos at Defendant's Premises, and in operation and maintenance plan. .\ 9 RESPONSE: Defendant objects to this request as overly broad and burdensome and calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant objects to the extent this request is not limited to premises on which Plaintiff allegedly worked nor to the areas within Defendant's premises Plaintiff allegedly worked. Further Defendant objects to the phrase "operation and maintenance plan" as vague, ambiguous and, as such, renders a response impossible without speculation as to the meaning of this phrase. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed itsnametoCITGO Petroleum Corporation. OnAugust31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR ADMISSION NO. 4: Admit that Plaintiffworked on premises owned by Defendant or by a predecessor-in-interest of Defendant. RESPONSE: Defendant objects to this request as overly broad and burdensome and calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant objects to the extent this request is not limited to premises on which Plaintiff allegedly worked nor to the areas within Defendant's premises Plaintiff allegedly worked. Further Defendant objects to the word "worked" as vague, ambiguous and, as such, renders a response impossible without speculation as to the meaning of this phrase. To the extent this request is intended to encompass all areas of Defendant's premises, including those where Plaintiff did net work, this request is overly broad and irrelevant. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections, Defendant denies this request. .\< M/V' 10 REQUEST FOR PRODUCTION NO. 4. If you deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: Defendant objects to this request as overly broad and burdensome and calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant objects to the extent this request is not limited to premises on which Plaintiff allegedly worked nor to the areas within Defendant's premises Plaintiff allegedly worked. Further Defendant objects to the word "worked" as vague, ambiguous and, as such, renders a response impossible without speculation as to the meaning of this phrase. This request is overly broad in that Plaintiff has not provided any discovery responses and it is impossible to know Plaintiff's allegations. Furthermore, Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31, 1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR PRODUCTION NO. 5: If you admit the foregoing request, in whole or in part, produce all documents supporting your admission that Plaintiff was on Defendant's Premises. RESPONSE: Defendant objects to this request as overly broad and burdensome and calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant objects to the extent this request is not limited to premises on which Plaintiff allegedly worked nor to the areas within Defendant's premises Plaintiff allegedly worked. Further Defendant objects to the word "worked" as vague, ambiguous and, as such, renders a response impossible without speculation as to the meaning of this phrase. This request is overly broad in that Plaintiff has not provided any discovery responses and it is impossible to know Plaintiffs allegations. DNO-2J989 1S4578 11 Furthermore, Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31, 1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the l efinery located in Lake Charles, Louisiana on this date, but did not own REQUEST FOR PRODUCTION NO 6: Produce all records identifying contractors and/or the employees ofcontractors who were on your premises between the dates at issue, including but not limited to sign-in-logs, gate records, visitor's logs, identification badge logs and procedures, and other documents of a similar nature. RESPONSE: Defendant objects to this request as overly broad and burdensome and calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. This request is overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiffallegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR PRODUCTION NO. 7: Produce all records pertaining to the methods and manner of identification of individuals entering and/or leaving your facilities, between the dates at issue, including but not limited to fingerprinting or other methods of identifying contractor employees at your premises, and specifically including any fingerprinting or other records identifying the Plaintiff. RESPONSE: Defendant objects to this request as overly broad and burdensome and calls for DNOM9S9 IK4S78 12 information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. This request is overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. INTERROGATORY NO. 4. Identify the contractors who worked on your premises between the years at issue, and for each, state: a. The type of work performed by the contractor b. The dates such work was performed; c. Identify your employee responsible for monitoring, verifying, or instructing concerning these services to be performed by such contractors. ANSWER: Defendant objects to this interrogatory as overly broad and burdensome and calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. This interrogatory is overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's pi emises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR PRODUCTION NO. 8: Produce the contract documents pertaining to the contractors who performed services on Defendant's Premises between the years at issue, including but not limited to invitations to DNO;249$9'UM578 13 bid, requests for proposals, bids, proposals, scope of work, specifications, blueprints, plans, acceptances, contracts, amendments, addenda, change orders, and other contract documents of a similar nature. RESPONSE. Defendant objects to this request as overly broad and burdensome and calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. This request is overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. INTERROGATORY NO. 5: Identify each employee who was responsible for allowing contractor employees access to Defendant's Premises between the years at issue. ANSWER: Defendant objects to this interrogatory as overly broad and burdensome and calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery ofadmissible evidence. Defendant further objects to this interrogatory as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR ADMISSION NO. 5: DNO-240$0<|8457C 14 Admit that Plaintiff worked on Defendant's Premises where Defendant used or applied asbestos-containing products. RESPONSE: Defendant objects to this request as overly broad and burdensome and calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant objects to the extent this request is not limited to premises on which Plaintiff allegedly worked nor to the areas within Defendant's premises Plaintiff allegedly worked. Further Defendant objects to the word "worked" as vague, ambiguous and, as such, renders a response impossible without speculation as to the meaning of this phrase. To the extent this request is intended to encompass all areas of Defendant's premises, including those where Plaintiff did not work, this request is overly broad and irrelevant. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR PRODUCTION NO. 9: Ifyou deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: Defendant objects to this request as overly broad and burdensome and calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant objects to the extent this request is not limited to premises on which Plaintiff allegedly worked nor to the areas within Defendant's premises Plaintiff allegedly worked. Further Defendant objects to the word "worked" as vague, ambiguous and, as such, renders a response impossible without speculation as to the meaning of this phrase. To the extent this request is intended to encompass all areas of Defendant's premises, including those where Plaintiff did not work, this request is overly broad and irrelevant. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The 15 Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections, denied. INTERROGATORY NO. 6: Do you contend that Plaintiff was not exposed to asbestos while working at the Defendant's Premise(s)? If the answer is anything other than "no", identify each and every fact which supports this contention. ANSWER: Defendant objects to this interrogatory as overly broad and burdensome and calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. This interrogatory is overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Further Defendant objects to the word "working" as vague, ambiguous in the context of this case. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR ADMISSION NO. 6: Admit that Plaintiff, in the course and scope of his work as an employee of an independent contractor, worked around Defendant's employees who were using and/or applying asbestoscontaining products. RESPONSE: Defendant objects to this request as overly broad and burdensome and calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. This request is overly broad in that it is not DN0 2-W& 1*4*78 16 limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Defendant further objects because the terms "his work", "worked around", and "employee of an independent contractor" are vague and ambiguous in the context of this case. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections, Defendant denies this request. REQUEST FOR PRODUCTION NO. 10: Ifyou deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: Defendant objects to this request as vague, ambiguous and overly broad and subject to multiple of interpretations. This request is overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's' premises where Plaintiff allegedly worked. Defendant further objects because the phrase "employee ofan independent contractor" is vague and ambiguous in the context of this case. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR ADMISSION NO. 7: Admit that Plaintiff worked on and/or around Defendant's Premises in areas where asbestoscontaining products were installed, used, prepared for use, replaced or repaired, stored or loaded. DNO 249jJ9'IK4578 17 unloaded or transported. RESPONSE: Defendant objects to this request as vague, ambiguous and overly broad and subject to multiple of interpretations. This request is overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Defendant further objects because the phrase "Plaintiff worked" is vague and ambiguous in the context of this case. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did notown or operate the refinery until this date. Without waiving the foregoing objections, Defendant denies this request. REQUEST FOR ADMISSION NO. 8: Admit that during the time period Plaintiffworked at the premises, Defendant was aware that airborne asbestos dust created a potential health hazard to those who breathed such dust. RESPONSE: Defendant objects to this request as overly broad and burdensome and calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request in that it is vague and ambiguous in that the phrase "health hazard" as defined in Plaintiff's definitions is so overly broad that Defendant does not know which health hazard is being referred and renders a response impossible without speculation as to the meaning of this phrase. Since "health hazards" often are dependent on the quantity of exposure, this request is vague and ambiguous because the quantity of exposure had not been defined. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery ,V' Nl-JS*' '*4^ 18 located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections. Defendant denies this request. REQUEST FOR PRODUCTION NO. 11: Ifyou deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: Defendant objects to this request as overly broad and burdensome and calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request in that it is vague and ambiguous in that the phrase "health hazard" as defined in Plaintiffs definitions is so overly broad that Defendant does not know which health hazard is being referred and renders a response impossible without speculation as to the meaning of this phrase. Since "health hazards" often are dependent on the quantity of exposure, this request is vague and ambiguous because the quantity of exposure had not been defined. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR ADMISSION NO. 9: Admit that Defendant was aware of the presence of and/or use of asbestos-containing products on Defendant's Premises during the time period Plaintiffwas working on Defendant's Premises. RESPONSE: Defendant objects to this insofar as it assumes Plaintiff worked on Defendant's premises. Defendant objects that Plaintiff has not sufficiently identified the periods of time or the location(s) within Plaintiffs facility where Plaintiff is alleging to have ^V/24980 l\M'78 19 worked. Defendant further objects to this request because the phrase "was working" is vague and ambiguous. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections, Defendant denies this request. REQUEST FOR PRODUCTION NO. 12: Produce any and all photographs or video graphic depictions or films depicting the use by you or your employees ofany safety precautions (such as containment areas, warning signs, etc.) taken to protect bystanders from the hazards of airborne asbestos resulting from the use of asbestos-containing products by your employees at any locations. RESPONSE: Defendant objects to this request as overly broad and burdensome and calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. This request is overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. This request is overly broad in that Plaintiff has not provided any discovery responses and it is impossible to know Plaintiffs allegations. Further, Defendant objects to this request to the extent that many of the terms used therein are vague, ambiguous, and overly broad, which renders particular questions unintelligible, and renders a response impossible without speculation as to the meaning of the term. For instance, this objection refers to, but is not limited to PlaintifTs use of such terms as "hazards". Plaintiff fails to reference any specific use, exposure condition (i.e. concentration) or type of health injury in their requests TRCP 192.3(a). Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. DNO.24989/184578 20 INTERROGATORY NO 7: Please identify any and all warnings ever given by Defendant, if any, to Plaintiffs regarding the hazards of asbestos and the dangers inherent in the inhalation of asbestos fibers. ANSWER: Defendant objects to this interrogatory as overly broad and burdensome and calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. This interrogatory is overly broad in that it is not limited to any area within Defendant's premises where Plaintiff allegedly worked and, therefore, is not relevant. Defendant further objects to the terms "hazards" and "dangers ofasbestos and the dangers inherent inhalation" as vague and ambiguous and response impossible without speculation as to the meaning of this phrase. This interrogatory is overly broad in that Plaintiff has not provided any discovery responses and it is impossible to know Plaintiffs allegations. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its nameto CITGO Petroleum Corporation. On August31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did notown or operate the refinery until this date. Without waiving the foregoing objections, Defendant states that Plaintiff was not an employee of this Defendant and Plaintiff has not sufficiently- established when he was on Defendant's premises. REQUEST FOR PRODUCTION NO. 13: Produce all such warnings. RESPONSE: Defendant objects to this request as overly broad and burdensome and calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. This request is overly broad in that it is not limited to any s.rea within Defendant's premises where Plaintiff allegedly worked and, therefore, is not relevant. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT DNO'24989-184578 21 Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold ail of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections, Defendant states that Plaintiff was not an employee of this Defendant and Plaintiff has not sufficiently established when he was on Defendant's premises. REQUEST FOR ADMISSION NO. 10: Admit that Defendant did not distribute any literature or warnings ofany kind to its employees during the period of time Plaintiff worked on Defendant's Premises regarding the potential health hazards to those who breathe airborne asbestos dust. RESPONSE: ! Defendant objects to this request as overly broad and burdensome and calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. This request is overly broad in that it is not limited to any area within Defendant's premises where Plaintiff allegedly worked and, therefore, is not relevant. Defendant further objects because it assumes Plaintiff worked at Defendant's premises. Defendant further objects because the terms "hazards"and "worked on Defendant's premises" are vague and ambiguous. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving theforegoing objections, after reasonable inquire, Defendant is unable to admit or deny at this time. REQUEST FOR PRODUCTION NO. 14: If you deny the foregoing, produce all such warnings. RESPONSE Not applicable. 240*9 !S4>7X 22 INTERROGATORY NO. 8: Describe Defendant's safety policy as it relates to the use of asbestos-containing materials at job-sites where Defendant's employees were performing services. In your answer, please state: a. when, ifever. Defendant's employees were first warned about the hazards of asbestos exposure; and b. ANSWER: what instructions, if any, were given to Defendant's employees on the identification of materials which might or did contain asbestos. Defendant objects to this interrogatory as overly broad and burdensome and calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. This interrogatory is overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Defendant further objects to this interrogatory as vague and ambiguous in that the phrase "safety policy" is not defined and so overly broad that Defendant does not know which "safety policy" is being referred and renders a response impossible without speculation as to the meaning of this phrase. In addition, Defendant objects to this interrogatory as it implies that Plaintiffwas an employee ofthis Defendant and Plaintiff has not sufficiently established when he was even on Defendant's premises. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR PRODUCTION NO, 15: Produce all such safety policies. RESPONSE: Defendant objects to this request as overly broad and burdensome and calls for information and material which is neither relevant nor reasonably calculated to lead to the discover/ of admissible evidence. This request is overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Defendant further objects to this request as vague and ambiguous in that the term "safety policy" is not defined and so overly broad that Defendant does not know which "safety policy" is being referred and renders a response impossible without speculation as to the meaning of this phrase. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refineiy until this date. REQUEST FOR ADMISSION NO. 11: Admit that Defendant consciously decided not to warn its employees of the dangers of asbestos. RESPONSE: Defendant objects to this request as overly broad and burdensome and calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. This request is overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Further Defendant objects to this request as it is argumentative. In addition, Defendant objects to the term "dangers" as vague and ambiguous. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving these objectives, Defendant denies this request. INTERROGATORY NO 9- Do you contend that Defendant specifically warned Plaintiffabout the hazards ofasbestos and asbestos-containing products? If the answer is anything other than "no", identify each and every fact which supports this contention. DN'O/24989,184578 24 ANSWER: Defendant objects to this interrogatory as overly broad and burdensome and calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. This interrogatory is overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On Aug'ust31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. INTERROGATORY NO. 10: Describe ail safety precautions taken by you or your employees (such as containment areas, warning signs, ventilation systems, evacuating the premises, etc.) for the protection of bystanders (including but not limited to Plaintiffs) from the hazards resulting from the use of asbestos-containing products by your employees at any locations. ANSWER: Defendant objects to this interrogatory as overly broad and burdensome and calls for information and material which is neither relevant nor reasonably calculated to lead to the discover/ of admissible evidence. This interrogatory is overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. To the extent this interrogatory seeks information unrelated to the subject matter of this lawsuit, the information sought is irrelevant. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did notown or operate the refinery until this date. ns INTERROGATORY NO. 11: Have you ever provided safety equipment to persons working on Defendant's Premises? If so, please list the safety equipment provided and indicate: a. when the equipment was first provided b. to whom the equipment was provided c. under what circumstances the equipment was provided d. Further, identify the person with the most knowledge of your "safety equipment" policies. ANSWER: Defendant objects to this interrogatory as overly broad and burdensome and calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. This interrogatory is overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. To the extent this interrogatory seeks information unrelated to the subject matter of this lawsuit, the information sought is irrelevant. This interrogatory is overly broad in that Plaintiff has not provided any discovery responses and it is impossible to know Plaintiff's allegations. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Defendant further objects to this request as vague and ambiguous in that the term "safety equipment policies" is not defined and so overly broad that Defendant does not know which "safety equipment policies" is being referred and renders a response impossible without speculation as to the meaning of the phrase. 26 REQUEST FOR ADMISSION NO. 12: Admit that Defendant did not continuously provide face masks to contract employees working with or around asbestos from 1945 for the purpose of protecting these employees from inhaling asbestos RESPONSE: Defendant objects to this request as overly broad and burdensome and calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. This request is overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections, Defendant denies this request. INTERROGATORY NO. 12: State in detail what tests have been conducted with regard to the quantity, quality, or threshold limit values of asbestos dust or particles to which workers were exposed while using, working with or around, or installing asbestos-containing products in any of your facilities. Please state where and when these tests were conducted, by whom these tests were conducted, and the results of any such test. ANSWER. Defendant objects to this interrogatory as overly broad and burdensome and calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. This interrogatory is overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Defendant further objects to this interrogatory as overly broad, vague and ambiguous IVJ57S 27 in that the terms "tests" and "using" are not defined and so overly broad and Defendant does not know which "tests" is being referred and renders a response impossible without speculation as to the meaning of this phrase. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its nametoCITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. INTERROGATORY NO. 13: Do you contend that Defendant, Defendant's representatives, insurance carriers and/or agents performed any measurements and/or studies prior to 1964 to determine the quantity of asbestos fibers in the air at Mobil Oil Corporation's facility? If the answer is anything other than"no", identify each and every fact which supports this contention. ANSWER: Defendant objects to each interrogatory to the extent that it is not limited to the premises on which Plaintiff allegedly worked and that the information sought is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. For instance, this objection refers to, but is not limited to Plaintiffs use of such general terms as "studies." To the extent this interrogatory seeks information unrelated to the subject matter of this lawsuit, the information sought is irrelevant. TRCP 192.3(a). Defendant objects to this interrogatory because it seeks information for time periods other than those upon which Plaintiffs claims against Defendant are based. Further, Defendant objects to this interrogatory to the extent it seeks information the subject of which is protected from disclosure by the attorney work product privilege, the attorney/client privilege, the investigative privilege, the party communication privilege, or any other applicable privilege or immunity from discovery provided by TRCP 192.5. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. Tn April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. 28 INTERROGATORY NO. 14: Please state each time any regulatory agency or other governing body has inspected the Defendant's premises to determine if health and safety regulations governing exposure to asbestos were being followed. Include in your response the date and results of each inspection, and state whether a written report was generated. ANSWER: Defendant objects to this interrogatory as overly broad and burdensome and calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. This interrogatory is overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Defendant further objects to the phases "regulatory agency" and "governing body" as vague and ambiguous in that they are not defined and so overly broad that Defendant does not know which "regulations" is being referred and renders a response impossible without speculation as to the meaning of these phrases. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR ADMISSION NO. 13: Admit that you did not erect containment barriers to prevent emission of asbestos dust at the work sites where your employees were using asbestos-containing materials, including the work-sites where Plaintiff worked. RESPONSE: Defendant objects to this request as overly broad in that it is not limited to any applicable time period nor in scope to the premises upon which Plaintiffclaims to have worked nor to the specific areas within the premises upon which Plaintiffclaims to have worked. Defendant further objects to this request as it is vague and ambiguous and calls for information which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as it does not identify the work sites where Plaintiff alleges he worked. :).\G' ISJ57S 29 Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections, based on reasonable inquiry, Defendant denies this request as written. REQUEST FOR PRODUCTION NO. 16: Ifyou deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: Defendant objects to this request as overly broad in that it is not limited to any applicable time period nor in scope to the premises upon which Plaintiffclaims to have worked nor to the specific areas within the premises upon which Plaintiffclaims to have worked. Defendant further objects to this request as it is vague and ambiguous and calls for information which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as it does not identify the work sites where Plaintiff alleges he worked. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its nameto CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did notown or operate the refinery until this date. REQUEST FOR ADMISSION NO. 14: Admit that you did not utilize engineering controls such as isolation or enclosure at the work sites where your employees were using asbestos-containing materials, including the work sites where Plaintiff worked DNO/2-*989'l84S78 30 RESPONSE- Defendant objects to this request as overly broad in that it is not limited to any applicable time period nor in scope to the premises upon which Plaintiffclaims to have worked nor to the specific areas within the premises upon which Plaintiffclaims to have worked. Defendant further objects to this request as it is vague and ambiguous and calls for information which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as it does not identify the work sites where Plaintiff alleges he worked. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections, based on reasonable inquiry, Defendant denies this request as written. REQUEST FOR PRODUCTION NO. 17; Ifyou deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: Defendant objects to this request as overly broad in that it is not limited to any applicable time period nor in scope to the premises upon which Plaintiffclaims to have worked nor to the specific areas within the premises upon which Plaintiffclaims to have worked. Defendant further objects to this request as it is vague and ambiguous and calls for information which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as it does not identify the work sites where Plaintiff alleges he worked. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery Mysv u-ra 31 located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR ADMISSION NO. 15: Adipit that you did not utilize ventilation or exhaust systems to divert dust at the work sites where your employees were using asbestos-containing materials, including the work sites where Plaintiff worked. RESPONSE: Defendant objects to this request as overly broad in that it is not limited to any applicable time period nor in scope to the premises upon which Plaintiff claims to have worked nor to the specific areas within the premises upon which Plaintiffclaims to have worked. Defendant further objects to this request as it is vague and ambiguous and calls for information which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as it does not identify the work sites where Plaintiff alleges he worked. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing, Defendant denies this request. REQUEST FOR PRODUCTION NO. 18: Ifyou deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: Defendant objects to this request as overly broad in that it is not limited to any applicable time period nor in scope to the premises upon which Plaintiff claims to have 2W9 ;*S57$ 32 worked nor to the specific areas within the premises upon which Plaintiffclaims to have worked. Defendant further objects to this request as it is vague and ambiguous and calls for information which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as it does not identify the work sites where Plaintiff alleges he worked. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR ADMISSION NO. 16: Admit that you did not utilize dust collection engineering controls to trap airborne asbestos dust at the work sites where your employees were using asbestos-containing materials, including the work sites where Plaintiffworked. RESPONSE Defendant objects to this request as overly broad in that it is not limited to any applicable time period nor in scope to the premises upon which Plaintiff claims to have worked nor to the specific areas within the premises upon which Plaintiffclaims to have worked. Defendant further objects to this request as it is vague and ambiguous and calls for information which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as it does not identify the work sites where Plaintiff alleges he worked. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August3i, 1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections, Defendant denies this request. REQUEST FOR PRODUCTION NO. 19: DM>24'/Jy 1*457$ 33 Ifyou deny the foregoing request, in whole or in part, produce all documents supporting vour denial. RESPONSE: Defendant objects to this request as overly broad in that it is not limited to any applicable time period nor in scope to the premises upon which Plaintiffclaims to have worked nor to the specific areas within the premises upon which Plaintiffclaims to have worked. Defendant further objects to this request as it is vague and ambiguous and calls for information which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as it does not identify the work sites where Plaintiff alleges he worked. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did notown or operate the refinery until this date. REQUEST FOR ADMISSION NO. 17: Admit that you did not require your employees to handle, mix, apply, remove, cut or score asbestos-containing products in a wet state to prevent emission of airborne asbestos fibers at the work sites where your employees were using asbestos-containing materials, including the work sites where Plaintiff worked. RESPONSE: Defendant objects to this request as overly broad in that it is not limited to any applicable time period nor in scope to the premises upon which Plaintiff claims to have worked nor to the specific areas within the premises upon which Plaintiffclaims to have worked. Defendant further objects to this request as it is vague and ambiguous and calls for information which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as it does not identify the work sites where Plaintiff alleges he worked. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August31,1983, 34 Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing, based on reasonable inquiry, Defendant is unable to admit or deny this request as written as to every conceivable work site. REQUEST FOR PRODUCTION NO. 20: Ifyou deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE Not applicable. REQUEST FOR ADMISSION NO. 18: Admit that you did not evacuate the premises prior to the utilization of asbestos-containing materials at the work sites where your employees were using asbestos-containing materials, including the work sites where Plaintiff was present. RESPONSE: Defendant objects to this request as overly broad in that it is not limited to any applicable time period nor in scope to the premises upon which Plaintiffclaims to have worked nor to the specific areas within the premises upon which Plaintiffclaims to have worked. Defendant further objects to this request as it is vague and ambiguous and calls for information which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as it does not identify the worksites where Plaintiffalleges he worked. Defendant further objects to this request as vague and ambiguous as respects to the term "utilization". This request is overly broad in that Plaintiff has not provided any discovery responses and it is impossible to know Plaintiff's allegations. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did notown or operate the refinery 35 until this date. Without waiving the foregoing, based on reasonable inquiry, Defendant is unable to admit or deny this request as written as to every conceivable work site. REQUEST FOR PRODUCTION NO, 21: Ifyou deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: Defendant objects to this request as overly broad in that it is not limited to any applicable time period nor in scope to the premises upon which Plaintiff claims to have worked nor to the specific areas within the premises upon which Plaintiffclaims to have worked. Defendant further objects to this request as it is vague and ambiguous and calls for information which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as it does not identify the work sites where Plaintiffalleges he worked. Defendant further objects to this request as vague and ambiguous as respects to the term "utilization". This request is overly broad in that Plaintiff has not provided any discovery responses and it is impossible to know Plaintiff's allegations. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. INTERROGATORY NO. 15: Have you ever warned workers on Defendant's Premises of the hazards of asbestos and asbestos-contaii ,ing products? If so, describe in detail the methods of such warnings, who you warned and when. Please include in your response a description of any written warnings relating to the hazards ofasbestos in place at Defendant's Premises and state when the written warnings were installed, how many were installed, and whether they have been removed. ANSWER: Defendant objects to this interrogatory to the extent that it is not limited to the DV* 2-WS9 1S457S' 36 premises on which Plaintiff allegedly worked, is overly broad, vague, ambiguous, and unduly burdensome. Defendant objects to this interrogatory because it seeks information for time periods other than those upon which Plaintiffs claims against Defendant are based. Further, Defendant objects to this interrogatory the extent that many of the terms used therein are vague, ambiguous, and overly broad, which renders particular questions unintelligible, and renders a response impossible without speculation as to the meaning of the term. For instance, this objection refers to, but is not limited to Plaintiffs use of such terms as "in place" and/or "hazards" relating to asbestos. Plaintiff fails to reference any specific use, exposure condition (i.e. concentration) or type of health injury in their requests TRCP 192.3(a). Cities Service RMTCorporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. INTERROGATORY NO. 16' Have you ever had a policy requiring workers on Defendant's premises to use respirators? If so, please: a, state when this policy was implemented; b describe this policy in detail; c. state to whom it applied (i.e. Defendant employees and contractor employees); d. and describe what types and brand names of respirators were required by you. ANSWER: Defendant objects to this interrogatory to the extent that it is not limited to the premises where Plaintiff allegedly worked, is overly broad and burdensome and calls for information or material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant objects to this interrogatory because it seeks information for time periods other than those upon which Plaintiffs claims against Defendant are based. Defendant further objects to this interrogatory to the extent that the information sought is neither relevant nor reasonably calculated to lead to the discovery ofadmissible evidence. For instance, this objection refers to, but is not limited to Plaintiffs use of such general terms as "policy." To the extent this \ 37 interrogatory seeks information unrelated to the subject matter of this lawsuit, the information sought is irrelevant. TRCP 192.3(a). Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on thisdate, but did notown or operate the refinery until this date. REQUEST FOR ADMISSION NO. 19: Admit that you did not post warning, caution or hazard signs prior to the utilization of asbestos-containing materials by your employees at the work sites where your employees were using asbestos-containing materials, including the work sites where Plaintiffwas present. RESPONSE: Defendant objects to this request as overly broad in that it is not limited to any applicable time period nor in scope to the premises upon which Plaintiffclaims to have worked nor to the specific areas within the premises upon which Plaintiffclaims to have worked. Defendant further objects to this request as it is vague and ambiguous and calls for information which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as it does not identify the work sites where Plaintiff alleges he worked. Defendant further objects to this request as vague and ambiguous as respects to the term "utilization". Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August31,1983, Cities Service Company sold ail of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections, Defendant denies this request. REQUEST FOR PRODUCTION NO. 22: Ifyou deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: Defendant objects to this request as overly broad in that it is not limited to any applicable time period nor in scope to the premises upon which Plaintiff claims to have worked nor to the specific areas within the premises upon which Plaintiffclaims to have worked. Defendant further objects to this request as it is vague and ambiguous and calls for information which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as it does not identify the work sites where Plaintiff alleges he worked. Defendant further objects to this request as vague and ambiguous as respects to the term "utilization". Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR ADMISSION NO. 20: Admit that you did not issue any warnings to others at the work sites where your employees were using asbestos-containing materials, including the work sites where Plaintiffwas present. RESPONSE: Defendant objects to this request as overly broad in that it is not limited to any applicable time period nor in scope to the premises upon which Plaintiffclaims to have worked nor to the specific areas within the premises upon which Plaintiffclaims to have worked. Defendant further objects to this request as it is vague and ambiguous and calls for information which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as it does not identify the worksites where Plaintiffalleges he worked. Defendant further objects to this request as vague and ambiguous as respects to the terms "using" and "warning". Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT DKO'24989-184578 39 Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections, Defendant denies this request. REQUEST FOR PRODUCTION NO. 23: Ifyou deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE; Defendant objects to this request as overly broad in that it is not limited to any applicable time period nor in scope to the premises upon which Plaintiff claims to have worked nor to the specific areas within the premises upon which Plaintiffclaims to have worked. Defendant further objects to this request as it is vague and ambiguous and calls for information which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as it does not identify the work sites where Plaintiff alleges he worked. Defendant further objects to this request as vague and ambiguous as respects to the terms "using" and "warning". Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR PRODUCTION NO. 24: Produce all documents reflecting payments made to contractors during the years at issue, including Plaintiffs employer, including but not limited to invoices, bills, check requests, requisitions, canceled checks, or other documents of a similar nature reflecting payment for services rendered by Plaintiffs employer. RESPONSE: Defendant objects to this request as it is overly broad in that it is not limited to the 24*Ay 1W>78 40 facilities at which Plaintiff claims to have been present nor to Plaintiffs employer. As such, this request is overly broad and overly burdensome and calls for information which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, butdidnot own or operate the refinery until this date. REQUEST FOR ADMISSION NO. 21: Admit that the use of asbestos-containing materials on Defendant's Premises created a substantial risk of injury. RESPONSE: Defendant objects to this request as overly broad in that it is not limited to any applicable time period nor in scope to the premises upon which Plaintiffclaims to have been present nor to the specific areas within the premises upon which Plaintiff claims to have been present. Defendant further objects to this request as it is vague and ambiguous and calls for information which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as it does not identify the work sites where Plaintiff alleges he worked. Defendant further objects to this request as vague and ambiguous as respects to the terms "use" and "substantial risk of injury. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections. Defendant denies this request. REQUEST FOR ADMISSION NO. 22 41 Admit that during the years at issue. Defendant had the power to control Defendant's Premises. RESPONSE: Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant objects to this request as vague, ambiguous, overly broad to the extent it is not limited in time or scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Defendant objects to this request for admission to the extent that the phrase "power to control" is vague, ambiguous, and overly broad, which renders this particular request unintelligible, and renders a response impossible without speculation as to the meaning of the term. The request calls for a legal conclusion. Further, Defendant objects to this request as it is overly broad, vague and ambiguous in that the request does not specify the specific task or activity about which Plaintiffis inquiring. Independent contractors were retained by Defendant to perform various activities on the premises because independent contractors were experts in the various fields in which they were retained. The contractors were independent and the control over the details of their work was left to their expertise. Further, each independent contractor agrees to take all reasonable precautions to protect the workmen, and Defendant anticipated that most, if not all, advice and control of the contractors' day to day activities regarding safety would come from the contractor employer. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections, Defendant denies this request as written. REQUEST FOR PRODUCTION NO, 25: Ifyou deny the foregoing request, in whole or in part, produce all documents supporting your denial. DSO 2J9S9 IS-157S 42 RESPONSE: Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant objects to this request as vague, ambiguous, overly broad to the extent it is not limited in time or scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Defendant objects to this request for production to the extent that the phrase "power to control" is vague, ambiguous, and overly broad, which renders this particular request unintelligible, and renders a response impossible without speculation as to the meaning of the term. The request calls for a legal conclusion. Further, Defendant objects to this request as it is overly broad, vague and ambiguous in that the request does not specify the specific task or activity about which Plaintiff is inquiring. Independent contractors were retained by Defendant to perform various activities on the premises because independent contractors were experts in the various fields in which they were retained. The contractors were independent and the control over the details of their work was left to their expertise. Further, each independent contractor agrees to take all reasonable precautions to protect the workmen, and Defendant anticipated that most, if not all, advice and control of the contractors' day to day activities regarding safety would come from the contractor employer. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR ADMISSION NO. 23: Admit that, during the years at issue, Defendant had the power to manage the use or condition of Defendant's Premises. RESPONSE: Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant objects to this request as vague, ambiguous, overly broad to the extent it is not limited in time or scope to time periods when Plaintiff 43 allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Defendant objects to this request for admission to the extent that the phrase "power to manage the use or condition ofDefendant's premises" is vague, ambiguous, and overly broad, which renders this particular request unintelligible, and renders a response impossible without speculation as to the meaning of the term. The request calls for a legal conclusion. Further, Defendant objects to this request as it is overly broad, vague and ambiguous in that the request does not specify the specific task or activity about which Plaintiff is inquiring. Independent contractors were retained by Defendant to perform various activities on the premises because independent contractors were experts in the various fields in which they were retained. The contractors were independent and the control over the details of their work was left to their expertise. Further, each independent contractor agrees to take ail reasonable precautions to protect the workmen, and Defendant anticipated that most, if not all, advice and control of the contractors' day to day activities regarding safety would come from the contractor employer. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections, Defendant denies this request as written. REQUEST FOR PRODUCTION NO. 26: Ifyou deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant objects to this request as vague, ambiguous, overly broad to the extent it is not limited in time or scope to time periods when Plaintiff 44 allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Defendant objects to this request for production to the extent that the phrase "power to manage the use or condition of Defendant's premises" is vague, ambiguous, and overly broad, which renders this particular request unintelligible, and renders a response impossible without speculation as to the meaning of the term. The request calls for a legal conclusion. Further, Defendant objects to this request as it is overly broad, vague and ambiguous in that the request does not specify the specific task or activity about which Plaintiff is inquiring. Independent contractors were retained by Defendant to perform various activities on the premises because independent contractors were experts in the various fields in which they were retained. The contractors were independent and the control over the details of their work was left to their expertise. Further, each independent contractor agrees to take all reasonable precautions to protect the workmen, and Defendant anticipated that most, if not all, advice and control ofthe contractors' day to day activities regarding safety would come from the contractor employer. This request is overly broad in that Plaintiff has not provided any discovery responses and it is impossible to know Plaintiff's allegations. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did notown or operate the refinery until this date. REQUEST FOR ADMISSION NO. 24: Admit that, between the years at issue. Defendant had the power to direct the use or condition of Defendant's Premises. RESPONSE: Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on ,A< / M9.S9 lh4>7K 45 Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Defendant objects to this request for admission to the extent that the phrase "power to direct the use or condition of Defendant's premises" is v ague, ambiguous, and overly broad, which renders this particular request unintelligible, and renders a response impossible without speculation as to the meaning of the term. The request calls for a legal conclusion. Further, Defendant objects to this request as it is overly broad, vague and ambiguous in that the request does not specify the specific task or activity about which Plaintiff is inquiring. Independent contractors were retained by Defendant to perform various activities on the premises because independent contractors were experts in the various fields in which they were retained. The contractors were independent and control over the details of their work was left to their expertise. Further, each independent contractor agrees to take all reasonable precautions to protect the workmen, and Defendant anticipated that most, if not all, advice and control of the contractors' day to day activities regarding safety would come from the contractor employer. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its nametoCITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections, Defendant denies this request as written. REQUEST FOR PRODUCTION NO, 27: Ifyou deny the foregoing request, in whole or in part, produce all documents supporting your denial RESPONSE: Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated. to lead to the discovery of admissible evidence. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on f N-<'S 46 Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Defendant objects to this request for production to the extent that the phrase "power to direct the use or condition of Defendant's premises" is vague, ambiguous, and overly broad, which renders this particular request unintelligible, and renders a response impossible without speculation as to the meaning of the term. The request calls for a legal conclusion. Further, Defendant objects to this request as it is overly broad, vague and ambiguous in that the request does not specify the specific task or activity about which Plaintiff is inquiring. Independent contractors were retained by Defendant to perform various activities on the premises because independent contractors were experts in the various fields in which they were retained. The contractors were independent and control over the details of their work was left to their expertise. Further, each independent contractor agrees to take all reasonable precautions to protect the workmen, and Defendant anticipated that most, if not all, advice and control of the contractors' day to day activities regarding safety would come from the contractor employer. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR ADMISSION NO. 25: Admit that, during the years at issue, Defendant had the power to superintend the use or conditions of Defendant's Premises. RESPONSE: Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on 47 Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Defendant objects to this request for production to the extent that the phrase "power to superintend the use or conditions of Defendant's premises" is vague, ambiguous, and overly broad, which renders this particular request unintelligible, and renders a response impossible without speculation as to the meaning of the term. The request calls for a legal conclusion. Further, Defendant objects to this request as it is overly broad, vague and ambiguous in that the request does not specify the specific task or activity about which Plaintiff is inquiring. Independent contractors were retained by Defendant to perform various activities on the premises because independent contractors were experts in the various fields in which they were retained. The contractors were independent and the control over the details of their work was left to their expertise. Further, each independent contractor agrees to take all reasonable precautions to protect the workmen, and Defendant anticipated that most, if not all, advice and control ofthe contractors' day to day activities regarding safety would come from the contractor employer. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR ADMISSION NO. 26: Admit that, during the tears at issue, Defendant had the power to restrict the use or condition of Defendant's Premises. RESPONSE. Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on 0SO24989 I$457$ 49 Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Defendant objects to this request for admission to the extent that the phrase "power to restrict the use or condition of Defendant's premises" is vague, ambiguous, and overly broad, which renders this particular request unintelligible, and renders a response impossible without speculation as to the meaning of the term. The request calls for a legal conclusion. Further, Defendant objects to this request as it is overly broad, vague and ambiguous in that the request does not specify the specific task or activity about which Plaintiff is inquiring. Independent contractors were retained by Defendant to perform various activities on the premises because independent contractors were experts in the various fields in which they were retained. The contractors were independent and control over the details of their work was left to their expertise. Further, each independent contractor agrees to take ail reasonable precautions to protect the workmen, and Defendant anticipated that most, if not all, advice and control of the contractors' day to day activities regarding safety would come from the contractor employer. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to C1TGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections, Defendant denies this request as written. REQUEST FOR PRODUCTION NO. 29: Ifyou deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on 50 Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Defendant objects to this request for production to the extent that the phrase "power to restrict the use or condition of Defendant's premises" is vague, ambiguous, and overly broad, which renders this particular request unintelligible, and renders a response impossible without speculation as to the meaning of the term. The request calls for a legal conclusion. Further, Defendant objects to this request as it is overly broad, vague and ambiguous in that the request does not specify the specific task or activity about which Plaintiff is inquiring. Independent contractors were retained by Defendant to perform various activities on the premises because independent contractors were experts in the various fields in which they were retained. The contractors were independent and the control over the details of their work was left to their expertise. Further, each independent contractor agrees to take all reasonable precautions to protect the workmen, and Defendant anticipated that most, if not all, advice and control ofthe contractors' day to day activities regarding safety would come from the contractor employer. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR ADMISSION NO. 27: Admit that, between the years at issues, Defendant had the power to regulate the use or condition of Defendant's Premises, RESPONSE: Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as overly broad in that 51 if is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Defendant objects to this request for admission to the extent that the phrase "power to regulate the use or condition ofDefendant's premises" is vague, ambiguous, and overly broad, which renders this particular request unintelligible, and renders a response impossible without speculation as to the meaning of the term. The request calls for a legal conclusion. Further, Defendant objects to this request as it is overly broad, vague and ambiguous in that the request does not specify the specific task or activity about which Plaintiff is inquiring. Independent contractors were retained by Defendant to perform various activities on the premises because independent contractors were experts in the various fields in which they were retained. The contractors were independent and the control over the details of their work was left to their expertise. Further, each independent contractor agrees to take all reasonable precautions to protect the workmen, and Defendant anticipated that most, if not all, advice and control of the contractors' day to day activities regarding safety would come from the contractor employer. in March, 1983 an6i4kfcfict*i>jixrBAlT Corporation was incorporated or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections. Defendant denies this request as written. REQUEST FOR PRODUCTION NO. 30: Ifyou deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: Defendant objects to this request as vague, ambiguous and overly broad and subject to multiple of interpretations. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly DN'0-24989.(84578 52 worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Defendant objects to this request for production to the extent that the phrase "power to regulate the use or condition of Defendant's premises is vague, ambiguous, and overly broad, which renders this particular request unintelligible, and renders a response impossible without speculation as to the meaningof the term. The request call for a legal conclusion. Further, Defendant objects to this request as it is overly broad, vague and ambiguous in that the request does not specify the specific task or activity about which Plaintiff is inquiring. Independent contractors were retained by Defendant to perform various activities on the premises because independent contractors were experts in the various fields in which they were retained. The contractors were independent and the control over the details of their work was left to their expertise. Further, each independent contractor agrees to take all reasonable precautions to protect the workmen, and Defendant anticipated that most, if not all, advice and control ofthe contractors' day to day activities regarding safety would come from the contractor employer. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR ADMISSION NO. 28: Admit that, between the years at issue, Defendant had the power to govern the use or condition of Defendant's Premises. RESPONSE: Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Defendant objects to this request for admission to the extent that the phrase "power to govern the use or condition of Defendant's premises" is vague, ambiguous, and overly ,>N, 53 broad, which renders this particular request unintelligible, and renders a response impossible without speculation as to the meaning of the term. The request calls for a legal conclusion. Further, Defendant objects to this request as it is overly broad, vague and ambiguous in that the request does not specify the specific task or activity about which Plaintiff is inquiring. Independent contractors were retained by Defendant to perform various activities on the premises because independent contractors were experts in the various fields in which they were retained. The contractors were independent and the control over the details of their work was left to their expertise. Further, each independent contractor agrees to take all reasonable precautions to protect the workmen, and Defendant anticipated that most, if not all, advice and control of the contractors' day to day activities regarding safety would come from the contractor employer. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections, Defendant denies this request as written. REQUEST FOR PRODUCTION NO. 31: Ifyou deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Defendant objects to this request for production to the extent that the phrase "power 54 to govern the use or condition of Defendant's premises" is vague, ambiguous, and overly broad, which renders this particular request unintelligible, and renders a response impossible without speculation as to the meaning of the term. The request calls for a legal conclusion. Further, Defendant objects to this request as it is overly broad, vague and ambiguous in that the request does not specify the specific task or activity about which Plaintiff is inquiring. Independent contractors were retained by Defendant to perform various activities on the premises because independent contractors were experts in the various fields in which they were retained. The contractors were independent and the control over the details of their work was left to their expertise. Further, each independent contractor agrees to take all reasonable precautions to protect the workmen, and Defendant anticipated that most, if not all, advice and control of the contractors' day to day activities regarding safety would come from the contractor employer. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR ADMISSION NO. 29: Admit that, between the years at issue, Defendant had the power to oversee the use or condition of Defendant's Premises. RESPONSE Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Defendant objects to this request for admission to the extent that the phrase "power to oversee the use or condition of Defendant's premises" is vague, ambiguous, and overly 55 broad, which renders this particular request unintelligible, and renders a response impossible without speculation as to the meaning of the term. This request calls for a legal conclusion. Further, Defendant objects to this request as it is overly broad, vague and ambiguous in that the request does not specify the specific task or activity about which Plaintiff is inquiring. Independent contractors were retained by Defendant to perform various activities on the premises because independent contractors were experts in the various fields in which they were retained. The contractors were independent and control over the details of their work was left to their expertise. Further, each independent contractor agrees to take all reasonable precautions to protect the workmen, and Defendant anticipated that most, if not all, advice and the control of the contractors' day to day activities regarding safety would come from the contractor employer. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections, Defendant denies this request as written. REQUEST FOR PRODUCTION NO. 32: Ifyou deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Defendant objects to this request for production to the extent that the phrase "power to oversee the use or condition of Defendant's premises" is vague, ambiguous, and overly broad, which renders this particular request unintelligible, and renders a response impossible without speculation as to the meaning of the term. The request calls for a legal conclusion. Further, Defendant objects to this request as it is overly broad, vague and ambiguous in that the request does not specify the specific task or activity about which Plaintiff is inquiring. Independent contractors were retained by Defendant to perform various activities on the premises because independent contractors were experts in the various fields in which they were retained. The contractors were independent and the control over the details of their work was left to their expertise. Further, each independent contractor agrees to take all reasonable precautions to protect the workmen, and Defendant anticipated that most, if not all, advice and control ofthe contractors' day to day activities regarding safety would come from the contractor employer. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its nametoCITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR ADMISSION NO. 30: Admit that, between the years at issue, Defendant had the power to administer the use or condition of Defendant's Premises. RESPONSE: Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Defendant objects to this request for admission to the extent that the phrase "power to administer the use or condition of Defendant's premises" is vague, ambiguous, and overly broad, which renders this particular request unintelligible, and renders a response impossible without speculation as to the meaning of the term. The request calls for a legal conclusion. Further, Defendant objects to this request as it is overly broad, vague and ambiguous in that the request does not specify the specific task or activity about which Plaintiff is inquiring. Independent contractors were retained by Defendant to perform various activities on the premises because independent contractors were experts in the various fields in which they were retained. The contractors were independent and the control over the details of their work was left to their expertise. Further, each independent contractor agrees to take all reasonable precautions to protect the workmen, and Defendant anticipated that most, if not all, advice and control ofthe contractors' day to day activities regarding safety would come from the contractor employer. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections, Defendant denies this request as written. REQUEST FOR PRODUCTION NO. 33: Ifyou deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Defendant objects to this request for production to the extent that the phrase "power to administer the use or condition of Defendant's premises" is vague, ambiguous, and M-Y/ s-l'T'S 5S overly broad, which renders this particular request unintelligible, and renders a response impossible without speculation as to the meaning of the term. The request calls for a legal conclusion. Further, Defendant objects to this request as it is overly broad, vague and ambiguous in that the request does not specify the specific task or activity about which Plaintiff is inquiring. Independent contractors were retained by Defendant to perform various activities on the premises because independent contractors were experts in the various fields in which they were retained. The contractors were independent and the control over the details of their work was left to their expertise. Further, each independent contractor agrees to take all reasonable precautions to protect the workmen, and Defendant anticipated that most, if not all, advice and control ofthe contractors' day to day activities regarding safety would come from the contractor employer. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR ADMISSION NO. 31: Admit that between the years at issue, Defendant controlled Defendant's Premises. RESPONSE: Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Defendant objects to this request for admission to the extent that the phrase "controlled Defendant's premises" is vague, ambiguous, and overly broad, which renders this particular request unintelligible, and renders a response impossible without speculation as to the meaning of the term. The request calls for a legal conclusion. Further, Defendant objects to this request as it is overly broad, vague and ambiguous in that the request does not specify the specific task or activity about which Plaintiff is inquiring. Independent contractors were retained by Defendant to perform various activities on the premises because independent contractors were experts in the various fields in which they were retained. The contractors were independent and the control over the details of their work was left to their expertise. Further, each independent contractor agrees to take all reasonable precautions to protect the workmen, and Defendant anticipated that most, if not all, advice and control of the contractors' day to day activities regarding safety would come from the contractor employer. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date.- Without waiving the foregoing objections, Defendant denies this request as written. REQUEST FOR PRODUCTION NO. 34: Ifyou deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Defendant objects to this request for production to the extent that the phrase "controlled Defendant's premises" is vague, ambiguous, and overly broad, which renders this particular request unintelligible, and renders a response impossible without speculation as to the meaning of the term. The request calls for a legal conclusion. Further, Defendant objects to this request as it is overly broad, vague and ambiguous in that the request does not specify the specific task or activity about which Plaintiffis inquiring. Independent contractors were retained by Defendant to perform various activities on the premises because independent contractors were experts in the various fields in which they were retained. The contractors were independent and the control over the details of their work was left to their expertise. Further, each independent contractor agrees to take all reasonable precautions to protect the workmen, and Defendant anticipated that most, if not all, advice and control of the contractors' day to day activities regarding safety would come from the contractor employer. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR ADMISSION NO. 32: Admit that, during the years at issue. Defendant managed the use or condition ofDefendant's Premises. RESPONSE: Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Defendant objects to this request for admission to the extent that the phrase "managed , . VO i 1 t the use or condition of Defendant's premises" is vague, ambiguous, and overly broad, which renders this particular request unintelligible, and renders a response impossible without speculation as to the meaning of the term. The request calls for a legal conclusion. Further, Defendant objects to this request as it is overly broad, vague and ambiguous in that the request does not specify the specific task or activity about which Plaintiff is inquiring. Independent contractors were retained by Defendant to perform various activities on the premises because independent contractors were experts in the various Fields in which they were retained. The contractors were independent and the control over the details of their work was left to their expertise. Further, each independent contractor agrees to take all reasonable precautions to protect the workmen, and Defendant anticipated that most, if not all, advice and control of the contractors' day to day activities regarding safety would come from the contractor employer. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. Tn April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did notown or operate the refinery until this date. Without waiving the foregoing objections, Defendant denies this request as written. REQUEST FOR PRODUCTION NO. 35: Ifyou deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Defendant objects to this request for production to the extent that the phrase 62 "managed the use or condition of Defendant's premises" is vague, ambiguous, and overly broad, which renders this particular request unintelligible, and renders a response impossible without speculation as to the meaning of the term. The request calls for a legal conclusion. Further, Defendant objects to this request as it is overly broad, vague and ambiguous in that the request does not specify the specific task or activity about which Plaintiff is inquiring. Independent contractors were retained by Defendant to perform various activities on the premises because independent contractors were experts in the various fields in which they were retained. The contractors were independent and the control over the details of their work was left to their expertise. Further, each independent contractor agrees to take all reasonable precautions to protect the workmen, and Defendant anticipated that most, if not all, advice and control of the contractors' day to day activities regarding safety would come from the contractor employer. Cities Service KMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR ADMISSION NO. 33: Admit that, during the years at issue, Defendant directed the use or condition of Defendant's Premises. RESPONSE: Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Defendant objects to this request for admission to the extent that the phrase "directed the use or condition of Defendant's premises" is vague, ambiguous, and overly broad. 1M57S 63 which renders this particular request unintelligible, and renders a response impossible without speculation as to the meaning of the term. The request calls for a legal conclusion. Further, Defendant objects to this request as it is overly broad, vague and ambiguous in that the request does not specify the specific task or activity about which Plaintiffis inquiring. Independent contractors were retained by Defendant to perform various activities on the premises because independent contractors were experts in the various fields in which they were retained. The contractors were independent and the control over the details of their work was left to their expertise. Further, each independent contractor agrees to take all reasonable precautions to protect the workmen, and Defendant anticipated that most, if not all, advice and control of the contractors' day to day activities regarding safety would come from the contractor employer. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections, Defendant denies this request as written. REQUEST FOR PRODUCTION NO. 36: Ifyou deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Defendant objects to this request for production to the extent that the phrase "directed the use or condition of Defendant's premises" is vague, ambiguous, and overly broad, DN'O-2-W*? 7$ 64 which renders this particular request unintelligible, and renders a response impossible without speculation as to the meaning of the term. The request calls for a legal conclusion. Further, Defendant objects to this request as it is overly broad, vague and ambiguous in that the request does not specify the specific task or activity about which Plaintiff is inquiring. Independent contractors were retained by Defendant to perform various activities on the premises because independent contractors were experts in the various fields in which they were retained. The contractors were independent and the control over the details of their work was left to their expertise. Further, each independent contractor agrees to take all reasonable precautions to protect the workmen, and Defendant anticipated that most, if not all, advice and control of the contractors' day to day activities regarding safety would come from the contractor employer. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR ADMISSION NO. 34: Admit that, between the years at issue. Defendant superintended the use or conditions of Defendant's Premises. RESPONSE: Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Defendant objects to this request for admission to the extent that the phrase "superintended the use or condition of Defendant's premises" is vague, ambiguous, DNC 65 and overly broad, which renders this particular request unintelligible, and renders a response impossible without speculation as to the meaning of the term. The request calls for a legal conclusion. Further, Defendant objects to this request as it is overly broad, vague and ambiguous in that the request does not specify the specific task or activity about which Plaintiff is inquiring. Independent contractors were retained by Defendant to perform various activities on the premises because independent contractors were experts in the various fields in which they were retained. The contractors were independent and the control over the details of their work was left to their expertise. Further, each independent contractor agrees to take all reasonable precautions to protect the workmen, and Defendant anticipated that most, if not all, advice and control ofthe contractors' day to day activities regarding safety would come from the contractor employer. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its nametoCITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections, Defendant denies this request as written. REQUEST FOR PRODUCTION NO. 37: Ifyou deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. r 66 Defendant objects to this request for production to the extent that the phrase "superintended the use or condition of Defendant's premises" is vague, ambiguous, and overly broad, which renders this particular request unintelligible, and renders a response impossible without speculation as to the meaning of the term. The request calls for a legal conclusion. Further, Defendant objects to this request as it is overly broad, vague and ambiguous in that the request does not specify the specific task or activity about which Plaintiff is inquiring. Independent contractors were retained by Defendant to perform various activities on the premises because independent contractors were experts in the various fields in which they were retained. The contractors were independent and the control over the details of their work was left to their expertise. Further, each independent contractor agrees to take all reasonable precautions to protect the workmen, and Defendant anticipated that most, if not all, advice and control ofthe contractors' day to day activities regarding safety would come from the contractor employer. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR ADMISSION NO. 35: Admit that, during the years at issue. Defendant restricted the use or condition ofDefendant's Premises. RESPONSE: Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Defendant objects to this request for admission to the extent that the phrase "restricted the use or condition of Defendant's premises" is vague, ambiguous, and overly broad, .v. s_: 'v 67 which renders this particular request unintelligible, and renders a response impossible without speculation as to the meaning of the term. The request calls for a legal conclusion. Further, Defendant objects to this request as it is overly broad, vague and ambiguous in that the request does not specify the specific task or activity about which Plaintiff is inquiring. Independent contractors were retained by Defendant to perform various activities on the premises because independent contractors were experts in the various fields in which they were retained. The contractors were independent and the control over the details of their work was left to their expertise. Further, each independent contractor agrees to take all reasonable precautions to protect the workmen, and Defendant anticipated that most, if not all, advice and control of the contractors' day to day activities regarding safety would come from the contractor employer. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections, Defendant denies this request as written. REQUEST FOR PRODUCTION NO. 38: Ifyou deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. 68 Defendant objects to this request for production to the extent that the phrase "restricted the use or condition of Defendant's premises" is vague, ambiguous, and overly broad, which renders this particular request unintelligible, and renders a response impossible without speculation as to the meaning of the term. The request calls for a legal conclusion. Further, Defendant objects to this request as it is overly broad, vague and ambiguous in that the request does not specify the specific task or activity about which Plaintiff is inquiring. Independent contractors were retained by Defendant to perform various activities on the premises because independent contractors were experts in the various Fields in which they were retained. The contractors were independent and the control over the details of their work was left to their expertise. Further, each independent contractor agrees to take all reasonable precautions to protect the workmen, and Defendant anticipated that most, if not all, advice and control ofthe contractors' day to day activities regarding safety would come from the contractor employer. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR ADMISSION NO. 36: Admit that, during the years at issue, Defendant regulated the use or condition ofDefendant's Premises. RESPONSE: Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. *S4v7.S' 69 Defendant objects to this request for admission to the extent that the phrase "regulated the use or condition of Defendant's premises" is vague, ambiguous, and overly broad, which renders this particular request unintelligible, and renders a response impossible without speculation as to the meaning of the term. The request calls for a legal conclusion. Further, Defendant objects to this request as it is overly broad, vague and ambiguous in that the request does not specify the specific task or activity about which Plaintiffis inquiring. Independent contractors were retained by Defendant to perform Various activities on the premises because independent contractors were experts in the various fields in which they were retained. The contractors were independent and the control over the details of their work was left to their expertise. Further, each independent contractor agrees to take all reasonable precautions to protect the workmen, and Defendant anticipated that most, if not all, advice and control of the contractors' day to day activities regarding safety would come from the contractor employer. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections, Defendant denies this request as written. REQUEST FOR PRODUCTION NO. 39: Ifyou deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. 70 Defendant objects to this request for production to the extent that the phrase "regulated the use or condition of Defendant's premises" is vague, ambiguous, and overly broad, which renders this particular request unintelligible, and renders a response impossible without speculation as to the meaning of the term. The request calls for a legal conclusion. Further, Defendant objects to this request as it is overly broad, vague and ambiguous in that the request does not specify the specific task or activity about which Plaintiff is inquiring. Independent contractors were retained by Defendant to perform various activities on the premises because independent contractors were experts in the various fields in which they were retained. The contractors were independent and the control over the details of their work was left to their expertise. Further, each independent contractor agrees to take all reasonable precautions to protect the workmen, and Defendant anticipated that most, if not all, advice and control ofthe contractors' day to day activities regarding safety would come from the contractor employer. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR ADMISSION NO. 37: Admit that, during the years at issue, Defendant governed the use or condition ofDefendant's Premises. RESPONSE: Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. DN0.245S9'184578 71 Defendant objects to this request for admission to the extent that the phrase "governed the use or condition of Defendant's premises" is vague, ambiguous, and overly broad, which renders this particular request unintelligible, and renders a response impossible without speculation as to the meaning of the term. The request calls for a legal conclusion. Further, Defendant objects to this request as it is overly broad, vague and ambiguous in that the request does not specify the specific task or activity about which Plaintiff is inquiring. Independent contractors were retained by Defendant to perform various activities on the premises because independent contractors were experts in the various fields in which they were retained. The contractors were independent and the control over the details of their work was left to their expertise. Further, each independent contractor agrees to take all reasonable precautions to protect the workmen, and Defendant anticipated that most, if not ail, advice and control of the contractors' day to day activities regarding safety would come from the contractor employer. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections, Defendant denies this request as written. REQUEST FOR PRODUCTION NO. 40: Ifyou deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. 72;.V Defendant objects to this request for production to the extent that the phrase "governed the use or condition of Defendant's premises" is vague, ambiguous, and overly broad, which renders this particular request unintelligible, and renders a response impossible without speculation as to the meaning of the term. The request calls for a legal conclusion. Further, Defendant objects to this request as it is overly broad, vague and ambiguous in that the request does not specify the specific task or activity about which Plaintiff is inquiring. Independent contractors were retained by Defendant to perform various activities on the premises because independent contractors were experts in the various fields in which they were retained. The contractors were independent and the control over the details of their work was left to their expertise. Further, each independent contractor agrees to take all reasonable precautions to protect the workmen, and Defendant anticipated that most, if not all, advice and control ofthe contractors' day to da' activities regarding safety would come from the contractor employer. Cities Service RMT Corporation was incorporated in March, L983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR ADMISSION NO. 38: Admit that, between the years at issue. Defendant oversaw the use or condition of Defendant's Premises. RESPONSE: Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. 73 Defendant objects to this request for admission to the extent that the phrase "oversaw the use or condition of Defendant's premises" is vague, ambiguous, and overly broad, which renders this particular request unintelligible, and renders a response impossible without speculation as to the meaning of the term. The request calls for a legal conclusion. Further, Defendant objects to this request as it is overly broad, vague and ambiguous in that the request does not specify the specific task or activity about which Plaintiff is inquiring. Independent contractors were retained by Defendant to perform various activities on the premises because independent contractors were experts in the various fields in which they were retained. The contractors were independent and the control over the details of their work was left to their expertise. Further, each independent contractor agrees to take all reasonable precautions to protect the workmen, and Defendant anticipated that most, if not all, advice and control of the contractors' day to day activities regarding safety would come from the contractor employer. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its nametoCITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on thisdate, but did notown or operate the refinery until this date. Without waiving the foregoing objections, Defendant denies this request as written. REQUEST FOR PRODUCTION NO. 41: Ifyou deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. 3053 UDNO/24989/184578 74 Defendant objects to this request for production to the extent that the phrase "oversaw the use or condition of Defendant's premises" is vague, ambiguous, and overly broad, which renders this particular request unintelligible, and renders a response impossible without speculation as to the meaning of the term. The request calls for a legal conclusion. Further, Defendant objects to this request as it is overly broad, vague and ambiguous in that the request does not specify the specific task or activity about which Plaintiff is inquiring. Independent contractors were retained by Defendant to perform various activities on the premises because independent contractors were experts in the various fields in which they were retained. The contractors were independent and the control over the details of their work was left to their expertise. Further, each independent contractor agrees to take all reasonable precautions to protect the workmen, and Defendant anticipated that most, if not all, advice and control of the contractors' day to day activities regarding safety would come from the contractor employer. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR ADMISSION NO. 39: Admit that, between the years at issue, Defendant administered the use or condition of Defendant's Premises. RESPONSE: Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. 75 Defendant objects to this request for admission to the extent that the phrase "administered the use or condition ofDefendant's premises" is vague, ambiguous, and overly broad, which renders this particular request unintelligible, and renders a response impossible without speculation as to the meaning of the term. The request calls for a legal conclusion. Further, Defendant objects to this request as it is overly broad, vague and ambiguous in that the request does not specify the specific task or activity about which Plaintiff is inquiring. Independent contractors were retained by Defendant to perform various activities on the premises because independent contractors were experts in the various fields in which they were retained. The contractors were independent and the control over the details of their work was left to their expertise. Further, each independent contractor agrees to take all reasonable precautions to protect the workmen, and Defendant anticipated that most, if not all, advice and control ofthe contractors' day to day activities regarding safety would come from the contractor employer. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections, Defendant denies this request as written. REQUEST FOR PRODUCTION NO. 42: Ifyou deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. 76 Defendant objects to this request for production to the extent that the phrase "administered the use or condition ofDefendant's premises" is vague, ambiguous, and overly broad, which renders this particular request unintelligible, and renders a response impossible without speculation as to the meaning of the term. The request calls for a legal conclusion. Further, Defendant objects to this request as it is overly broad, vague and ambiguous in that the request does not specify the specific task or activity about which Plaintiff is inquiring. Independent contractors were retained by Defendant to perform various activities on the premises because independent contractors were experts in the various fields in which they were retained. The contractors were independent and the control over the details of their work was left to their expertise. Further, each independent contractor agrees to take all reasonable precautions to protect the workmen, and Defendant anticipated that most, if not all, advice and control ofthe contractors' day to day activities regarding safety would come from the contractor employer. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR ADMISSION NO. 40: Admit that Defendant retained some control over the manner in which Plaintiffs work was performed, RESPONSE Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. 77 Defendant objects to this request insofar as it assumes Plaintiffworked and worked on Defendant's premises which is subject to question. Defendant further objects to this request for admission to the extent that Plaintiff does not specify what work was performed, thereby making the phrase "plaintiffs work" vague, ambiguous and overly broad, which renders this particular request unintelligible, and renders a response impossible without speculation as to the meaning of the phrase. Defendant objects to this request for admission to the extent that the phrase "retained some control" is vague, ambiguous and overly broad, which renders this particular request unintelligible and renders a response impossible without speculation as to the meaning of the term. The request calls for a legal conclusion. Further, Defendant objects to this request as it is overly broad, vague and ambiguous in that the request does not specify the specific task or activity about which Plaintiff is inquiring. Independent contractors were retained by Defendant to perform various activities on the premises because independent contractors were experts in the various fields in which they were retained. The contractors were independent and the control over the details of their work was left to their expertise. Further, each independent contractor agrees to take all reasonable precautions to protect the workmen, and Defendant anticipated that most, if not all, advice and the control of the contractors' day to day activities regarding safety would come from the contractor employer, present, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections, Defendant denies this request. REQUEST FOR PRODUCTION NO. 43: Ifyou deny the foregoing request, in whole or in part, produce all documents supporting your denial RESPONSE: Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as overly broad in that 78 it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Defendant objects to this request insofar as it assumes Plaintiff worked and worked on Defendant's premises which is subject to question. Defendant further objects to this request for production to the extent that Plaintiff does not specify what work was performed, thereby making the phrase "plaintiff's work" vague, ambiguous and overly broad, which renders this particular request unintelligible, and renders a response impossible without speculation as to the meaning of the phrase. Defendant objects to this request for admission to the extent that the phrase "retained some control" is vague, ambiguous and overly broad, which renders this particular request unintelligible and renders a response impossible without speculation as to the meaning of the term. The request calls for a legal conclusion. Further, Defendant objects to this request as it is overly broad, vague and ambiguous in that the request does not specify the specific task or activity about which Plaintiff is inquiring. Independent contractors were retained by Defendant to perform various activities on the premises because independent contractors were experts in the various fields in which they were retained. The contractors were independent and the control over the details of their work was left to their expertise. Further, each independent contractor agrees to take all reasonable precautions to protect the workmen, and Defendant anticipated that most, if not all, advice and the control of the contractors' day to day activities regarding safety would come from the contractor employer. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. INTERROGATORY NO. 17: Do you contend that at no time between the years at issue, Defendant did not have the right to advise or, if necessary, control the activities of employees of contractors, working on the premises of Mobil Oil Corporation facility, who were engaged in activities which could be potentially hazardous to either themselves or to the employees of Defendant? If the answer is anything other than "no", identify each and every fact which supports this contention. ANSWER: Defendant objects to this interrogatory in that this interrogatory calls for information 79 and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Defendant objects to this request for admission to the extent that the phrases "right to advise" and "control the activities" are vague, ambiguous and overly broad, which renders this particular request unintelligible and renders a response impossible without speculation as to the meaning of the term. Defendant objects to this interrogatory the extent that many of the terms used therein are vague, ambiguous, and overly 80broad, which renders particular questions unintelligible, and renders a response impossible without speculation as to the meaning of the term. For instance, this objection refers to, but is not limited to Plaintiff's use of such terms as "hazardous". Plaintiff fails to reference any specific use, exposure condition (i.e. concentration) or type of health injury in their requests TRCP 192.3(a). Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections, Defendant respond as follows: Independent contractors were retained by Defendant to perform various activities on their premises because independent contractors were experts in the various fields in which they were retained. The contractors were independent and the control over the details ofthe work was left to their expertise. Further, each independent contractor agrees to take all reasonable precautions to protect the workmen. Defendant anticipated that most, if not all, advice and control of contractors' day to day activities regarding safety would come from the contractors' employer. REQUEST FOR ADMISSION NO. 41 Admit that Defendant retained some control over the manner in which Plaintiffs employer performed the work requested by the Defendant. RESPONSE: %ONOM9S9 !SJ<7 80 Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Defendant objects to this request insofar as it assumes Plaintiffworked on Defendant's premises which is subject to question. Defendant further objects to this request for admission to the extent that Plaintiff does not specify what work was performed, thereby making the phrase "Plaintiff's employer" vague, ambiguous, and overly broad, which renders this particular request unintelligible, and renders a response impossible without speculation as to the meaning of the ph 'ase. Defendant further objects to this request for admission to the extent that the phrase "retained some control" is vague, ambiguous, and overly broad, which renders this particular request unintelligible, and renders a response impossible without speculation as to the meaning of the term. Further, Defendant objects to this request as it is overly broad, vague and ambiguous in that the request does not specify the specific task, work site, or activity about which Plaintiff is inquiring. Independent contractors were retained by Defendant to perform various activities on the premises because independent contractors were experts in the various fields in which they were retained. The contractors were independent and the control over the details of their work were left to their expertise. Further, each independent contractor agrees to take all reasonable precautions to protect the workmen. Defendant anticipated that most, if not all, advice and control of the contractors' day to day activities regarding safety would come from the contractor employer. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections, Defendant denies this request. REQUEST FOR PRODUCTION NO. 44: Ifyou deny the foregoing request, in whole or in part, produce all documents supporting your denial DNo2-*y$9 i<J457S 81 RESPONSE Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Defendant objects to this request insofar as it assumes Plaintiff worked on Defendant's premises which is subject to question. Defendant further objects to this request for production to the extent that Plaintiff does not specify what work was performed, thereby making the phrase "Plaintiff's employer" vague, ambiguous, and overly broad, which renders this particular request unintelligible, and renders a response impossible without speculation as to the meaning of the phrase. Defendant further objects to this request to the extent that the phrase "retained some control" is vague, ambiguous, and overly broad, which renders this particular request unintelligible, and renders a response impossible without speculation as to the meaning of the term. Further, Defendant objects to this request as it is overly broad, vague and ambiguous in that the request does not specify the specific task, work site, or activity about which Plaintiff is inquiring. Independent contractors were retained by Defendant to perform various activities on the premises because independent contractors were experts in the various fields in which they were retained. The contractors were independent and the control over the details of their work were left to their expertise. Further, each independent contractor agrees to take all reasonable precautions to protect the workmen. Defendant anticipated that most, if not all, advice and control of the contractors' day to day activities regarding safety would come from the contractor employer. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its nametoCITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR ADMISSION NO. 42: Admit that Plaintiff was not entirely free to do the work on Defendant's Premises in his own way RESPONSE. DNO 24M9.I&578 82 Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Defendant objects to this request insofar as it assumes Plaintiffworked on Defendant's premises which is subject to question. Defendant further objects to this request for admission to theextent that Plaintiffdoes not specify what work he allegedly performed on Defendant's premises, thereby making the phrase "entirely free do the work on Defendant's premises in his own way" vague, ambiguous, and overly broad, which renders this particular request unintelligible, and renders a response impossible without speculation as to the meaning of the phrase. Further, Defendant objects to this request as it is overly broad, vague and ambiguous in that the request does not specify the specific task, work site, or activity about which Plaintiff is inquiring. Independent contractors were retained by Defendant to perform various activities on the premises because independent contractors were experts in the various fields in which they were retained. The contractors were independent and the control over the details of their work were left to their expertise. Further, each independent contractor agrees to take all reasonable precautions to protect the workmen. Defendant anticipated that most, if not all, advice and control of the contractors' day to day activities regarding safety would come from the contractor employer. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections, Defendant denies this request as written. REQUEST FOR PRODUCTION NO. 45: Ifyou deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: l $457$ 83 Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Defendant objects to this request insofar as it assumes Plaintiffworked on Defendant's premises which is subject to question. Defendant further objects to this request for production to the extent that Plaintiff does not specify what work he allegedly performed on Defendant's premises, thereby making the phrase "entirely free do the work on Defendant's premises in his own way" vague, ambiguous, and overly broad, which renders this particular request unintelligible, and renders a response impossible without speculation as to the meaning ofthe phrase. Further, Defendant objects to this request as it is overly broad, vague and ambiguous in that the request does not specify the specific task, work site, or activity about which Plaintiff is inquiring. Independent contractors were retained by Defendant to perform various activities on the premises because independent contractors were experts in the various fields in which they were retained. The contractors were independent and the control over the details of their work were left to their expertise. Further, each independent contractor agrees to take all reasonable precautions to protect the workmen. Defendant anticipated that most, if not all, advice and control of the contractors' day to day activities regarding safety would come from the contractor employer. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR ADMISSION NO. 43: Admit that Plaintiffs employer was not entirely free to do the work requested by Defendant on Defendant's Premises in its own way. RESPONSE: Defendant objects to this request as vague, ambiguous and overly broad and subject to multiple of interpretations. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly 84 worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Defendant objects to this request insofar as it assumes Plaintiffworked on Defendant's premises which is subject to question. Defendant further objects to this request for admission to the extent that Plaintiff does not specify his employer or what work Defendant requested his employer perform, thereby making the phrases "do the work requested" and "entirely free do the work on Defendant's premises in his own way" vague, ambiguous, and overly broad, which renders this particular request unintelligible, and renders a response impossible without speculation as to the meaning of the phrases. Further, Defendant objects to this request as it is overly broad, vague and ambiguous in that the request does not specify the specific task, work site, or activity about which Plaintiff is inquiring. Independent contractors were retained by Defendant to perform various activities on the premises because independent contractors were experts in the various fields in which they were retained. The contractors were independent and control over the details of their work were left to their expertise. Further, each independent contractor agrees to take ail reasonable precautions to protect the workmen. Defendant anticipated that most, if not all, advice and the control of the contractors' day to day activities regarding safety would come from the contractor employer. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections. Defendant denies this request. REQUEST FOR PRODUCTION NO. 46: Ifyou deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discoveiy of 249X9 iVJ'TS 85 admissible evidence. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Defendant objects to this request insofar as it assumes Plaintiffworked on Defendant's premises which is subject to question. Defendant further objects to this request for production to the extent that Plaintiff does not specify his employer or what work Defendant requested his employer perform, thereby making the phrases "do the work requested" and "entirely free do the work on Defendant's premises in his own way" vague, ambiguous, and overly broad, which renders this particular request unintelligible, and renders a response impossible w!.thout speculation as to the meaning of the phrases. Further, Defendant objects to this request as it is overly broad, vague and ambiguous in that the request does not specify the specific task, work site, or activity about which Plaintiff is inquiring. Independent contractors were retained by Defendant to perform various activities on the premises because independent contractors were experts in the various fields in which they were retained. The contractors were independent and control over the details of their work were left to their expertise. Further, each independent contractor agrees to take ail reasonable precautions to protect the workmen. Defendant anticipated that most, ifnot all, advice and the control of the contractors' day to day activities regarding safety would come from the contractor employer. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR ADMISSION NO. 44: Admit that asbestos-containing gaskets were installed at Defendant's Premises. RESPONSE: Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on LAG :nJ57S 86 Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its nameto CITGO Petroleum Corporation. On August31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections, after reasonable inquiry, Defendant are unable to admit or deny. REQUEST FOR PRODUCTION NO. 47: Ifyou deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR ADMISSION NO, 45: Admit that asbestos-containing pipe covering was installed at Defendant's Premises. .8*57S 87 RESPONSE: Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discoveiy of admissible evidence. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. This request is overly broad in that Plaintiff has not provided any discovery responses and it is impossible to know Plaintiff's allegations. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections, it is admitted that asbestos containing pipe covering was installed at certain locations and at certain times. REQUEST FOR PRODUCTION NO. 48: Ifyou deny the foregoing request, in whole or in part, produce ail documents supporting your denial. RESPONSE: Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. This request is overly broad in that Plaintiff has not provided any discovery responses and it is impossible to know Plaintiff's allegations. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The 88 Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did no t own or operate the refinery until this date. REQUEST FOR ADMISSION NO. 46: Admit that asbestos-containing boilers were installed at Defendant's Premises. RESPONSE: Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections, after reasonable inquiry, Defendant are unable to admit or deny. REQUEST FOR PRODUCTION NO. 49: Ifyou deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as overly broad in that jXJ'Ok 89 it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did notown or operate the refinery until this date. REQUEST FOR ADMISSION NO. 47: Admit that asbestos-containing fireproofing was installed at Defendant's Premises. RESPONSE: Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. This request is overly broad in that Plaintiff has not provided any discovery responses and it is impossible to know Plaintiff's allegations. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections, after reasonable inquiry, Defendant are unable to admit or deny. REQUEST FOR PRODUCTION NO. 50, DNG24vS9 1*457$ 90 Ifyou deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. This request is overly broad in that Plaintiff has not provided any discovery responses and it is impossible to know Plaintiff's allegations. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its nametoCITGO Petroleum Corporation. On August31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR ADMISSION NO. 48: Admit that asbestos-containing joint compound was installed at Defendant's Premises. RESPONSE: Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did notown or operate the refinery until this date. JNo MVW Ik4^7.\ 91 Without waiving the foregoing objections, Defendant denies. REQUEST FOR PRODUCTION NO. 51: Ifyou deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR ADMISSION NO, 49: Admit that asbestos-containing insulation was installed at Defendant's Premises. RESPONSE: Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections, Defendant denies. REQUEST FOR PRODUCTION NO. 52: Ifyou deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR ADMISSION NO. 50: Admit that such installation was done under your direction, supervision, and/or control. RESPONSE Defendant objects to this request in that this request calls for information and material 184578 93 which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Defendant objects to this request as vague, ambiguous, and subject to multiple interpretations. Defendant further objects to this request as it is overly broad in that it is not limited in time nor scope either to time periods when Plaintiffallegedly worked on Defendant's premises, to the premises at which Plaintiff allegedly worked, nor the area(s) within any Defendant's premises where Plaintiff allegedly worked. Defendant further objects to this request for admission to the extent that the terms "such installation" and "your direction, supervision and/or control" are vague, ambiguous, and overly broad, which renders this particular request unintelligible, and renders a response impossible without speculation as to the meaning of the term. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections, Defendant denies. REQUEST FOR PRODUCTION NO. 53: Ifyou deny the foregoing request, in whole or in part, produce all documents supporting your denial, including but not limited to all documents identifying the entities or individuals who directed, supervised, and/or controlled such installation activities. RESPONSE: Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Defendant objects to this request as vague, ambiguous, and subject to multiple interpretations. Defendant further objects to this request as it is overly broad in that 'S 94 it is not limited in time nor scope either to time periods when Plaintiff allegedly worked on Defendant's premises, to the premises at which Plaintiff allegedly worked, nor the area(s) within any Defendant's premises where Plaintiff allegedly worked. Defendant further objects to this request for admission to the extent that the terms "such installation" and "your direction, supervision and/or control" are vague, ambiguous, and overly broad, which renders this particular request unintelligible, and renders a response impossible without speculation as to the meaning of the term. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. INTERROGATORY NO. 18: Please state the first year you learned that persons could suffer physical injury through the inhalation of asbestos fibers and how Defendant became aware of the existence of asbestos hazards. ANSWER: Defendant objects to this interrogatory in that this interrogatory calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this interrogatory as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Defendant objects to this interrogatory as overly broad and burdensome and calls for information or material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Further, Defendant objects to this interrogatory the extent that many ofthe terms used therein are vague, ambiguous, and overly broad, which renders particular questions unintelligible, and renders a response impossible without speculation as to the meaning of the term. For instance, this objection refers to, but is not limited to Plaintiff's use ofsuch terms as "inhalation", "hazards", and/or ' -iv's'v . V 95 "injury" and/or "physical injury" relating to asbestos. Plaintiff fails to reference any specific use, exposure condition (i.e. concentration) or type of health injury in their requests TRCP 192.3(a). Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR PRODUCTION NO. 54: Produce all documents that indicate that asbestos fibers, when inhaled, can be hazardous to the health of human beings. RESPONSE: Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Defendant objects to this request to the extent it is overly broad and burdensome and calls for information or material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. In addition, this request includes terms used therein which are vague, ambiguous, and overly broad, which renders particular questions unintelligible, and renders a response impossible without speculation as to the meaning of the terms. Plaintiff fails to reference any specific use, exposure condition (i.e. concentration) or type of health injury in their requests. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on thisdate, but did notown or operate the refinery until this date. DSO'Z49H'} 1S-J57S 96 REQUEST FOR ADMISSION NO. 51: Admit that you supervised the health and safety procedures implemented by contractors working on Defendant's Premises. RESPONSE. Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Defendant objects to this request insofar as it assumes Plaintiff worked on Defendant's premises which is subject to question. Defendant further objects to this request for admission to the extent that Plaintiff does not specify which contractor was his employer or what work was performed by that contractor, thereby making the phrases "health and safety practices" and "implemented by contractors" vague, ambiguous, and overly broad, which renders this particular request unintelligible, and renders a response impossible without speculation as to the meaning of the phrases. Defendant further objects to this request for admission to the extent that the term "supervised" is vague, ambiguous, and overly broad, which renders this particular request unintelligible, and renders a response impossible without speculation as to the meaning of the term. Further, Defendant objects to this request as it is overly broad, vague and ambiguous in that the request does not specify the specific task, work site, or activity about which Plaintiff is inquiring. Independent contractors were retained by Defendant to perform various activities on the premises because independent contractors were experts in the various fields in which they were retained. The contractors were independent and control over the details of their work were left to their expertise. Further, each independent contractor agrees to take all reasonable precautions to protect the workmen. Defendant anticipated that most, ifnot all, advice and the control of the contractors' day to day activities regarding safety would come from the contractor employer. Cities Service RMTCorporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did notown or operate the refinery until this date. 3653UDNO 24989184578 9" Without waiving the foregoing objections, Defendant denies this request. REQUEST FOR ADMISSION NO. 52: Admit that you supervised the health and safety practices implemented by Plaintiffs employer. RESPONSE: Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Defendant objects to this request insofar as it assumes Plaintiffworked on Defendant's premises which is subject to question. Defendant further objects to this request for admission to the extent that Plaintiff does not specify his employer or what work was performed by his employer, thereby making the phrase phrases "health and safety practices" and "implemented by Plaintiff's employer" vague, ambiguous, and overly broad, which renders this particular request unintelligible, and renders a response impossible without speculation as to the meaning of the phrase. Defendant further objects to this request for admission to the extent that the phrase "you supervised" is vague, ambiguous, and overly broad, which renders this particular request unintelligible, and renders a response impossible without speculation as to the meaning of the term. Further, Defendant objects to this request as it is overly broad, vague and ambiguous in that the request does not specify the specific task, work site, or activity about which Plaintiff is inquiring. Independent contractors were retained by Defendant to perform various activities on the premises because independent contractors were experts in the various fields in which they were retained. The contractors were independent and control over the details of their work were left to their expertise'; Further, each independent contractor agrees to take all reasonable precautions to protect the workmen. Defendant anticipated that most, if not all, advice and the control of the contractors' day to day activities regarding safety would come from the contractor employer. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its nametoCITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery 98 located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections, Defendant denies. REQUEST FOR ADMISSION NO. 53: Admit that you did not protect the Plaintiff from exposure to asbestos on Defendant's Premises. RESPONSE. Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Defendant objects to this request insofar as it assumes Plaintiffworked on Defendant's premises which is subject to question. Defendant further objects to request for admission to the extent that the term "protect" is vague, ambiguous, and overly broad, which renders this particular request unintelligible, and renders a response impossible without speculation as to the meaning of the term. Further, Defendant objects to this request as it is overly broad, vague and ambiguous in that the request does not specify the specific task, work site, or activity about which Plaintiff is inquiring. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. J.SO 99 Without waiving the these objections, Defendant denies this request. REQUEST FOR PRODUCTION NO. 55: Produce all documents supporting the legal theories and factual bases of your defenses set forth in your response to Plaintiffs Request for Disclosure under Texas Rules of Civil Procedure 194.2, subparagraph (c). RESPONSE: Defendant objects to the request as premature and a violation of the attorney work product privilege. This request is overly broad in that Plaintiff has not provided any discovery responses and it is impossible to know Plaintiffs allegations. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections, Defendant will produce documents and trial exhibits as required by the TRCP. INTERROGATORY NO. 19: Do you contend that Plaintiffs exposure to asbestos at Defendant's Premises was not a substantial contributing factor in causing his asbestos-related injury? Ifthe answer is anything other than "no", identify each and every fact which supports this contention. ANSWER: Defendant objects to this interrogatory insofar as it assumes Plaintiff worked on Defendant's premises and that he was exposed to asbestos, which is subject to question. Defendant further objects to this interrogatory as it is overly broad, vague and ambiguous in that the request does not specify the specific task, worksite, time period, or activity about which Plaintiff is inquiring. Defendant objects to the phrase 'V* .SSr'* 100 "substantial contributing factor" as vague and ambiguous and renders a response impossible without speculation as to the meaning of the term. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did notown or operate the refinery until this date. Without waiving the foregoing objections, yes. REQUEST FOR ADMISSION NO. 54: Admit that Plaintiffs exposure to asbestos at Defendant's Premises was a substantial contributing factor in causing his asbestos-related injury. RESPONSE: Defendant objects to this request in that the phrases "Plaintiffs exposure" and "substantial contributing factor" and "asbestos-related injury" are vague, indefinite and ambiguous. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections, Defendant denies this request. REQUEST FOR PRODUCTION NO. 56: Ifyou deny the foregoing request, in whole or in part, produce all documents supporting your 101 denial. RESPONSE: Defendant objects to this request in that the phrases "Plaintiff's exposure" and "substantial contributing factor" and "asbestos-related injury" are vague, indefinite and ambiguous. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Cities Service RMTCorporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all ofthe stock ofCITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR ADMISSION NO, 55: Admit that Defendant did not exercise reasonable care to reduce or eliminate the risk of asbestos-related injury. RESPONSE: Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Defendant objects to this request insofar as it assumes Plaintiffworked on Defendant's premises which is subject to question. Defendant further objects to this request as it is overly broad, vague and ambiguous in that the request does not specify the specific task, work site, time period, or activity about which Plaintiff is inquiring. It is not limited to any applicable time period nor in scope to the premises upon which Plaintiff claims to have been present, nor to the specific areas where Plaintiff claims to have been present. Defendant further objects to this request for admission to the extent that the phrase "reasonable care to reduce or eliminate the risk of asbestos-related injury" is vague, ambiguous, and overly broad, which renders this particular request 2-is^s . v '3 102 unintelligible, and renders a response impossible without speculation as to the meaning of the term. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections, Defendant denies this request. REQUEST FOR ADMISSION NO. 56: Admit that Defendant did not reduce or eliminate the unreasonable risk ofharm posed by the use of asbestos-containing products at Defendant's Premises. RESPONSE: Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Defendant objects to this request insofar as it assumes Plaintiffworked on Defendant's premises which is subject to question. Defendant further objects to this request as it is overly broad, vague and ambiguous in that the request does not specify the specific task, work site, time period, or activity about which Plaintiff is inquiring. It is not limited to any applicable time period nor in scope to the premises upon which Plaintiff claims to have been present, nor to the specific areas where Plaintiff claims to have been present. Defendant further objects to this request for admission to the extent that the phrase "reduce or eliminate the unreasonable risk of harm posed by the use of asbestos-containing products" is vague, ambiguous, and overly broad, which renders this particular request unintelligible, and renders a response impossible without speculation as to the meaning of the term. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT 103 Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock ofCITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections, Defendant denies this request. REQUEST FOR PRODUCTION NO. 57: Ifyou deny the foregoing request, in whole or in part, produce all documents supporting your denial, RESPONSE: Defendant objects to this request in that this request calls for information and material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects to this request as overly broad in that it is not limited in time nor scope to time periods when Plaintiff allegedly worked on Defendant's premises, nor limited to the premises at which Plaintiff allegedly worked, nor the area(s) within any of Defendant's premises where Plaintiff allegedly worked. Defendant objects to this request insofar as it assumes Plaintiff worked on Defendant's premises which is subject to question. Defendant further objects to this request as it is overly broad, vague and ambiguous in that the request does not specify the specific task, work site, time period, or activity about which Plaintiff is inquiring. It is not limited to any applicable time period nor in scope to the premises upon which Plaintiff claims to have been present, nor to the specific areas where Plaintiff claims to have been present. Defendant further objects to this request for admission to the extent that the terms "unreasonable risk of harm" and "use" are vague, ambiguous, and overly broad, which renders this particular request unintelligible, and renders a response impossible without speculation as to the meaning of the term. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. 104 REQUEST FOR ADMISSION NO. 57: Admit that Defendant's failure to reduce or eliminate the risk of harm to Plaintiff was a substantial factor in bringing about Plaintiffs asbestos-related injury. RESPONSE: Defendant objects to this request insofar as it assumes Plaintiffworked on Defendant's premises and that he was exposed to asbestos [or that Plaintiff has an asbestos related injury), which is subject to question. Defendant further objects to this request as it is overly broad, vague and ambiguous in that the request does not specify the specific task, work site, time period, or activity about which Plaintiff is inquiring. Defendant further objects to this request for admission to the extent that the phrase "reduce or eliminate the risk of harm to Plaintiff was a substantial factor in bringing about Plaintiffs asbestos-related injury" is vague, ambiguous, and overly broad, which renders this particular request unintelligible, and renders a response impossible without speculation as to the meaning of the term. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did notown or operate the refinery until this date. Without waiving the foregoing objections, Defendant denies this request. REQUEST FOR PRODUCTION NO. 58: Ifyou deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: Defendant objects to this request insofar as it assumes Plaintiff worked on Defendant's premises and that he was exposed to asbestos or that Plaintiff has an asbestos related injury, which is subject to question. Defendant further objects to this request as it is overly broad, vague and ambiguous in that the request does not specify the specific task, work site, time period, or activity about which Plaintiff is inquiring. 105 Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR PRODUCTION NO. 59: Ifyou contend that while at the premises on which you or your employees were working with asbestos-containing materials, Plaintiff was not exposed to sufficient quantities of asbestos dust to produce the disease(s) complained of, produce all documents supporting your contention. RESPONSE- Defendant objects to this request insofar as it assumes Plaintiffworked on Defendant's premises, which is subject to question. Defendant further objects to this request as it is overly broad, vague and ambiguous in that the request does not specify the specific task, work site, time period, or activity about which Plaintiff is inquiring. Plaintiff has not identified any specific work site or time periods in which he worked on Defendant's premises and; therefore. Defendant is unable to respond at this time. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR PRODUCTION NO. 60: If you contend that Plaintiff is suffering from an asbestos disease as a result of exposures other than asbestos dust at the premises on which you or your employees were working with asbestos-containing materials, produce all documents supporting your contention. RESPONSE Defendant objects to this request insofar as it assumes Plaintiffworked on Defendant's 106 premises, which is subject to question. Defendant further objects to this request as it is overly broad, vague and ambiguous in that the request does not specify the specific task, worksite, time period, or activity about which Plaintiff is inquiring. At this time, Defendant do not contend that Mr. Banks has an asbestos-related injury and discovery is continuing as to what asbestos exposures he may have had on other premises. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR PRODUCTION NO. 61: If you contend that Plaintiffdoes not suffer from the asbestos-related disease(s) complained of, produce all documents supporting your contention. RESPONSE: Defendant does not yet have enough information to finalize contentions. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR PRODUCTION NO. 62: If you contend that Plaintiff was not exposed to asbestos dust at the premises on which you or your employees were working with asbestos-containing materials, produce all documents supporting your contention. 107 RESPONSE: Defendant objects to this request as it is overly broad, vague and ambiguous in that the request does not specify the specific task, work site, time period, or activity about which Plaintiff is inquiring. Plaintiff has not identified any specific work site or time periods in which he worked on Defendant's premises and; therefore, Defendant are unable to respond at this time. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR PRODUCTION NO. 63: Produce all documents used, referred to or relied upon in answering any Interrogatories. RESPONSE: Defendant objects to this request as it is overly broad, vague and ambiguous. It is not limited by time or location and constitutes a "fishing expedition". It calls for information or material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR PRODUCTION NO. 64: Produce any and all documents and other tangible things which refer to the document 108 retention (and/or destruction) policy of Defendant, including the following: a. Any document retention and/or destruction policies for Defendant that pertain to documents and records, including but not limited to supplements, addenda, memoranda, operating bulletins, revisions, or any other superseding instructions that referred to the stopping, suspending or resuming of such retention or destruction policies. b. Any record retention and/or destruction, dumping, or purging policies for Defendant that pertain to documents and records created, maintained or stored by electronic and/or magnetic means, including but not limited to records that have been microfilmed, microfiched, imaged, scanned, or stored on tapes, disks, diskettes, CDrom, databases, etc. or on or within any computer hardware, backup system, download system, file dumping or other system ofinformation management, whether on-site or off-site, including but not limited to supplements, addenda, memoranda, operating bulletins, revisions, or any other superseding instructions that referred to the stopping, suspending or resuming of such retention or destruction policies. RESPONSE: Defendant objects to this request as it is overly broad, burdensome, vague and ambiguous. U is not limited by time or location and constitutes a "fishing expedition". It calls for information or material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR PRODUCTION NO. 65: Produce any and all documentation, including but not limited to lists, inventories, indices, databases or print-outs thereof, archives, storage inventories, logs, or other search aids that refer or relate to the existence, extent, type, organization, filing system, method ofaccess or retrieval, and/or location ofDefendant's documents (maintained or stored on-site or off-site) described in the preceding paragraphs. DN'OM9$$ 5 54575 109 RESPONSE: Defendant objects to this request as it is overly broad, burdensome, vague and ambiguous. It is not limited by time or location and constitutes a "fishing expedition". It calls for information or material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. INTERROGATORY NO. 20: Does Defendant have in its possession any books, pamphlets, memoranda, or written materials ofany kind or character that would indicate that asbestos fibers, when inhaled, can be hazardous to the health of human beings? If so, identify the individuals who received, maintained, reviewed, or disseminated the information contained in such written materials. ANSWER: Defendant objects to this interrogatory as it is overly broad, burdensome, vague and ambiguous. It is not limited by time or location and constitutes a "fishing expedition". It calls for information or material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR PRODUCTION NO. 66: Produce the written materials referred to in the interrogatory above. RESPONSE: Defendant objects to this request as it is overly broad, burdensome, vague and ambiguous. It is not limited by time or location and constitutes a "fishing expedition". It calls for information or material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refineiy located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REOUEST-FOR ADMISSION NO. 58: Admit that Plaintifffiled suit against Defendant within two (2) years ofthe date ofdiscovering his asbestos-related condition or the existence of any asbestos-related causes of action. RESPONSE: Denied. REQUEST FOR ADMISSION NO, 59: Admit that Defendant is liable for Plaintiffs asbestos related illness. RESPONSE: Without waiving the foregoing objection, denied. REQUEST FOR ADMISSION NO. 60: Admit that asbestos is still in use and/or in place on Defendant's Premises. RESPONSE: Defendant objects to this request as it is overly broad, burdensome, vague and jno 2498V ;K4^:s 111 ambiguous in that the request does not specify a time period of the specific work site location about which Plaintiff is inquiring, TRCP 192.3(a). Further, Defendant objects to this request to the extent it is overly broad and burdensome and calls for information or material which is neither relevant nor reasonably calculated to lead to the discoveiy of admissible evidence. Defendant further objects because the phrase "in use and/or in place" is vague and ambiguous. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation, On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections, Defendant, denies. REQUEST FOR ADMISSION NO. 61: Admit that Defendant no longer uses asbestos on its Premises. RESPONSE: Defendant objects to this request as it is overly broad, burdensome, vague and ambiguous in that the request does not specify a the time period or specific work site location aboutwhich Plaintiffis inquiring, TRCP 192.3(a). Further, Defendant objects to this request to the extent it is overly broad and burdensome and calls for information or material which is neither relevant nor reasonably calculated to lead to the discovery ofadmissible evidence. Defendant further objects because the term "asbestos" is vague and ambiguous. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections, Defendant denies. '*y> 112 REQUEST FOR ADMISSION NO. 62: Admit that asbestos-containing materials were in-place on Defendant's Premises after January 1, 1972. RESPONSE: Defendant objects to this request as it is overly broad, burdensome, vague and ambiguous in that the request does not specify a the time period or specific work site location about which Plaintiffis inquiring, TRCP 192.3(a). Further, Defendant objects to this request to the extent it is overly broad and burdensome and calls for information or material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects because the term "asbestoscontaining materials" is vague and ambiguous. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections, denied REQUEST FOR ADMISSION NO, 63 : Admit that asbestos-containing materials were in-place on Defendant's Premises after January 1, 1973. RESPONSE: Defendant objects to this request as it is overly broad, burdensome, vague and ambiguous in that the request does not specify a the time period or specific work site location about which Plaintiffis inquiring, TRCP 192.3(a). Further, Defendant objects to this request to the extent it is overly broad and burdensome and calls for information or material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects because the term "asbestoscontaining materials" is vague and ambiguous. LAC :\jOy 113 Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In Aprii, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections, denied REQUEST FOR ADMISSION NO. 64: Admit that asbestos-containing materials were in-place on Defendant's Premises after January I, 1974. RESPONSE: Defendant objects to this request as it is overly broad, burdensome, vague and ambiguous in that the request does not specify a the time period or specific work site location about which Plaintiffis inquiring, TRCP 192.3(a). Further, Defendant objects to this request to the extent it is overly broad and burdensome and calls for information or material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects because the term "asbestoscontaining materials" is vague and ambiguous. Cities Service RMT Corporation was incorporated in March, 1983-and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections, denied. REQUEST FOR ADMISSION NO. 65: 114 Admit that asbestos-containing materials were in-place on Defendant's Premises after January 1, 1975. RESPONSE: Defendant objects to this request as it is overly broad, burdensome, vague and ambiguous in that the request does not specify a the time period or specific work site location about which Plaintiffis inquiring, TRCP 192.3(a). Further, Defendant objects to this request to the extent it is overly broad and burdensome and calls for information or material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects because the term "asbestos- containing materials" is vague and ambiguous. **;".* Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its nametoCITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections, denied. REQUEST FOR ADMISSION NO. 66: Admit that asbestos-containing materials were in-place on Defendant's Premises after January 1, 1976. RESPONSE: Defendant objects to this request as it is overly broad, burdensome, vague and ambiguous in that the request does not specify a the time period or specific work site location about which Plaintiffis inquiring, TRCP 192.3(a). Further, Defendant objects to this request to the extent it is overly broad and burdensome and calls for information or material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects because the term "asbestoscontaining materials" is vague and ambiguous. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The :$<. ;5's 115 Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections, denied. REQUEST FOR ADMISSION NO. 67: Admit that asbestos-containing materials were in-place on Defendant's Premises after January 1, 1977. RESPONSE: Defendant objects to this request as it is overly broad, burdensome, vague and ambiguous in that the request does not specify a the time period or specific work site location about which Plaintiff is inquiring, TRCP 192.3(a). Further, Defendant objects to this request to the extent it is overly broad and burdensome and calls for information or material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects because the term "asbestoscontaining materials" is vague and ambiguous. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections, denied REQUEST FOR ADMISSION NO. 68: Admit that asbestos-containing materials were in-place on Defendant's Premises after January 1, 1978. RESPONSE: Defendant objects to this request as it is overly broad, burdensome, vague and ambiguous in that the request does not specify a the time period or specific work site 116 location about which Plaintiffis inquiring, TRCP 192.3(a). Further, Defendant objects to this request to the extent it is overly broad and burdensome and calls for information or material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects because the term "asbestoscontaining materials" is vague and ambiguous. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections, denied. REQUEST FOR ADMISSION NO. 69: Admit that asbestos-containing materials were in-place on Defendant's Premises after January 1, 1979. RESPONSE: Defendant objects to this request as it is overly broad, burdensome, vague and ambiguous in that the request does not specify a the time period or specific work site location about which Plaintiffis inquiring, TRCP 192.3(a). Further, Defendant objects to this request to the extent it is overly broad and burdensome and calls for information or material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects because the term "asbestoscontaining materials" is vague and ambiguous. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections, denied. 117 REQUEST FOR ADMISSION NO. 70: Admit that asbestos-containing materials were in-place on Defendant's Premises after January 1, 1980. RESPONSE: Defendant objects to this request as it is overly broad, burdensome, vague and ambiguous in that the request does not specify a the time period or specific work site location about which Plaintiffis inquiring, TRCP 192.3(a). Further, Defendant objects to this request to the extent it is overly broad and burdensome and calls for information or material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects because the term "asbestoscontaining materials" is vague and ambiguous. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections, denied. REQUEST FOR ADMISSION NO. 71: Admit that asbestos-containing materials were in-place on Defendant's Premises after January 1, 1981. RESPONSE: Defendant objects to this request as it is overly broad, burdensome, vague and ambiguous in that the request does not specify a the time period or specific work site location about which Plaintiffis inquiring, TRCP 192.3(a). Further, Defendant objects to this request to the extent it is overly broad and burdensome and calls for information or material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects because the term "asbestoscontaining materials" is vague and ambiguous. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate 24989 .8-457$ 118 or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections, denied. REQUEST FOR ADMISSION NO. 72: Admit that asbestos-containing materials were in-place on Defendant's Premises after January 1, 1982. RESPONSE: Defendant objects to this request as it is overly broad, burdensome, vague and ambiguous in that the request does not specify a the time period or specific work site location about which Plaintiffis inquiring, TRCP 192.3(a). Further, Defendant objects to this request to the extent it is overly broad and burdensome and calls for information or material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects because the term "asbestoscontaining materials" is vague and ambiguous. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections, denied. REQUEST FOR ADM'SSIQN NO. 73: Admit that asbestos-containing materials were in-place on Defendant's Premises after January I, 1983. RESPONSE- DNO049S9.IS4578 119 Defendant objects to this request as it is overly broad, burdensome, vague and ambiguous in that the request does not specify a the time period or specific work site location about which Plaintiffis inquiring, TRCP 192.3(a). Further, Defendant objects to this request to the extent it is overly broad and burdensomeand calls for information or material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects because the term "asbestoscontaining materials" is vague and ambiguous. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections, denied. REQUEST FOR ADMISSION NO. 74: Admit that asbestos-containing materials were in-place on Defendant's Premises after January 1. 1984. RESPONSE: Defendant objects to this request as it is overly broad, burdensome, vague and ambiguous in that the request does not specify a the time period or specific work site location about which Piaintiffis inquiring, TRCP 192.3(a). Further, Defendant objects to this request to the extent it is overly broad and burdensome and calls for information or material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects because the term "asbestoscontaining materials" is vague and ambiguous. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did notown or operate the refinery until this date. 120 Without waiving the foregoing objections, denied. REQUEST FOR ADMISSION NO. 75: Admit that asbestos-containing materials were in-place on Defendant's Premises after January 1, 1985. RESPONSE: Defendant objects to this request as it is overly broad, burdensome, vague and ambiguous in that the request does not specify a the time period or specific work site location about which Plaintiffis inquiring, TRCP 192.3(a). Further, Defendant objects to this request to the extent it is overly broad and burdensome and calls for information or material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects because the term "asbestoscontaining materials" is vague and ambiguous. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections, Defendant denies. REQUEST FOR ADMISSION NO. 76: Admit that asbestos-containing materials were in-place on Defendant's Premises after January 1.1986 RESPONSE: Defendant objects to this request as it is overly broad, burdensome, vague and ambiguous in that the request does not specify a the time period or specific work site location about which Plaintiffis inquiring, TRCP 192.3(a). Further, Defendant objects DN'0*4989'UW578 121 to this request to the extent it is overly broad and burdensome and calls for information or material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects because the term "asbestoscontaining materials" is vague and ambiguous. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections, Defendant denies. REQUEST FOR ADMISSION NO. 77: Admit that asbestos-containing materials were in-place on Defendant's Premises after Januaty 1, 1987. RESPONSE: Defendant objects to this request as it is overly broad, burdensome, vague and ambiguous in that the request does not specify a the time period or specific work site location about which Plaintiff is inquiring, TRCP 192.3(a). Further, Defendant objects to this request to the extent it is overly broad and burdensome and calls for information or material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects because the term "asbestoscontaining materials" is vague and ambiguous. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections, Defendant denies. DNO/24989* 1 $4578 122 REQUEST FOR ADMISSION NO. 78: Admit that asbestos-containing materials were in-piace on Defendant's Premises after January 1, 1988. RESPONSE: Defendant objects to this request as it is overly broad, burdensome, vague and ambiguous in that the request does not specify a the time period or specific work site location about which Plaintiffis inquiring, TRCP 192.3(a). Further, Defendant objects to this request to the extent it is overly broad and burdensome and calls for information or material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant further objects because the term "asbestoscontaining materials" is vague and ambiguous. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. Without waiving the foregoing objections, Defendant denies. REQUEST FOR PRODUCTION NO. 67: Produce all documents that reflect, indicate or in anyway relate to communications between you and any manufacturer of asbestos-containing products concerning or related to the asbestos contained in such products. RESPONSE: Defendant objects to this requests for production to the extent that it is overly broad, vague, irrelevant, unduly burdensome, and not limited to the facilities where Plaintiff allegedly worked. TRCP 192.3(a). Defendant objects to this request for production because it seeks information for time periods other than those upon which Plaintiff's DNO/24989`184578 123 claims against Defendant are based. Further, Defendant objects to this requests for production to the extent it seeks information, the subject of which is protected from disclosure by the attorney/client privilege, or any other applicable privilege or immunity from discovery provided by TRCP 192.5. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed itsnametoCITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR PRODUCTION NO. 68: Produce all documents disseminated or published by any trade association that contain information relating to the hazards of asbestos and all documents which refer to such documents, RESPONSE: Defendant objects to this request for production to the extent it is overly broad, vague, unduly burdensome, and calls for information or material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant objects to this request for production because it seeks information for time periods other than those upon which Plaintiff's claims against Defendant are based, and it is not limited to the facilities where Plaintiff allegedly worked. Further, Defendant objects to this request to the extent that many of the terms used therein are vague, ambiguous, and overly broad, which renders particular questions unintelligible, and renders a response impossible without speculation as to the meaning of the term. For instance, this objection refers to, but is not limited to Plaintiff's use of such terms as "hazards". Plaintiff fails to reference any specific use, exposure condition (i.e. concentration) or type of health injury in their requests TRCP 192.3(a). Defendant objects to the production of documents which are protected by the attorney/client or other privilege. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisianaon thisdate, but did notown or operate the refinery DNO.M989.I1MS7S 124 until this date. REQUEST FOR PRODUCTION NO. 69: Produce all documents, that relate to any inspections by any regulatory agency for the purpose ofascertaining whether health or safety regulations were being followed or adhered to at any of your plants. This request specifically seeks any and all such documentation referring to dust hazards, including but not limited to asbestos in your plants. RESPONSE. Defendant objects to this request for production to the extent it is overly broad, vague, unduly burdensome, and calls for information or material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Further, Defendant objects to this request to the extent that it is not limited to the premises where Plaintiffallegedly worked. TRCP 192.3(a). Defendant objects to this request for production because it seeks information for time periods other than those upon which Plaintiff's claims against Defendant are based, and it is not limited to the facilities where Plaintiff worked. Defendant also objects to this request in that it is not limited to health and safety regulations dealing with asbestos. In addition, Defendant objects to this request to the extent that it seeks information which is a matter of public record or otherwise available to Plaintiffwithout imposing a burden on Defendant. Defendant objects to the extent this request seeks information the subject of which is protected from disclosure by the attorney work product privilege, the attorney/client privilege, the investigative privilege, the party communication privilege, or any other applicable privilege or immunity from discovery provided by TRCP 192.5. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR PRODUCTION NO. 70: DN'0/249$9/IW578 125 Produce all safety meeting minutes or other documents, that refer to the dangers ofasbestos safety measures to be used in the vicinity of asbestos at Defendant's Premises. RESPONSE: Defendant objects to this request for production to the extent it is overly broad, vague, unduly burdensome and calls for information or material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant objects to this request for production because it seeks information for time periods other than those upon which Plaintiffs claims against Defendant are based. Further, Defendant objects to the extent that it is not limited to the premises where Plaintiff allegedly worked. Defendant objects to the extent this request seeks information the subject of which is protected from disclosure by the attorney work product privilege, the attorney/client privilege, the investigative privilege, the party communication privilege, or any other applicable privilege or immunity from discovery provided by TRCP 192.5. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR PRODUCTION NO. 71: Produce all contracts, or other documents that relate to abatement ofasbestos at Defendant's Premises. RESPONSE: Defendant objects to this request for production as overly broad, vague, irrelevant, unduly burdensome, and calls for information or material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant objects to this request for production because it seeks information for time periods other than those upon which Plaintiffs claims against Defendant are based. Further, Defendant objects to the extent that it is not limited to the premises where Plaintiff allegedly worked. TRCP 192.3(a). In addition, Defendant objects to this requestto the extent it seeks information the subject of which is protected from disclosure by the attorney work product privilege, the attorney/client privilege, the investigative 126 privilege, the party communication privilege, or any other applicable privilege or immunity from discovery provided by TRCP 192.5. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR PRODUCTION NO. 72: Produce all contracts, or other documents that relate to the installation ofasbestos products at Defendant's Premises. RESPONSE: Defendant objects to this request for production as overly broad, vague, irrelevant, unduly burdensome, and calls for information or material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant objects to this request for production because it seeks information for time periods other than those upon which Plaintiffs claims against Defendant are based. Further, Defendant objects to the extent that it is not limited to the premises where Plaintiff allegedly worked. TRCP 192.3(a). In addition, Defendant objects to this request to the extent it seeks information the subject of which is protected from disclosure by the attorney work product privilege, the attorney/client privilege, the investigative privilege, the party communication privilege, or any other applicable privilege or immunity from discovery provided by TRCP 192.5. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. 127 REQUEST FOR PRODUCTION NO. 73: Produce all documents that in any way reflect a removal plan or organized written criteria or schedule for the removal of asbestos at Defendant's Premises. RESPONSE: Defendant objects to this request for production as overly broad, vague, irrelevant, unduly burdensome, and calls for information or material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant objects to this request for production because it seeks information for time periods other than those upon which PlaintifTs claims against Defendant are based. Further, Defendant objects to the extent that it is not limited to the premises where Plaintiff allegedly worked. TRCP 192.3(a). In addition, Defendant objects to this request to the extent it seeks information the subject of which is protected from disclosure by the attorney work product privilege, the attorney/client privilege, the investigative privilege, the party communication privilege, or any other applicable privilege or immunity from discovery provided by TRCP 192.5. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did notown or operate the refinery until this date. REQUEST FOR PRODUCTION NO. 74: Produce all documents related to the medical condition ofPlaintiffat anytime during his work at Defendant's Premises. This request specifically includes any and all x-rays, x-ray reports, medical notes and/or medical records of any kind, annual physical forms, and employment records relating to Plaintiffs health. RESPONSE: Defendant objects to this request for production to the extent it seeks information the subject of which is protected from disclosure by the attorney work product privilege, the attorney/client privilege, the investigative privilege, the party communication privilege, or any other applicable privilege or immunity from discovery provided by TRCP 192.5. 0N0.249S9.I84S78 128 Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR PRODUCTION NO. 75: Produce Plaintiffs entire personnel file from Defendant's Premises. RESPONSE: Defendant has no personnel file on Plaintiff. REQUEST FOR PRODUCTION NO. 76: Produce all documents that reflect the layout ofDefendant's Premises, including the location and dimensions of all buildings and the location and placement of asbestos-containing products. RESPONSE: Defendant objects to this request for production as overly broad and burdensome and calls for information or material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. TRCP 192.3(a). Further, Defendant objects to this request to the extent that it seeks confidential and/or proprietary information and/or trade secrets. In addition, this request seeks information the subject of which is protected from disclosure by the attorney work product privilege, the attorney/client privilege, the investigative privilege, the party communication privilege, or any other applicable privilege or immunity from discovery provided by TRCP 192.5. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, butdidnot own or operate the refinery ;ao 2->9S9 mm 129 until this date. REQUEST FOR PRODUCTION NO. 77: Produce all documents containing any warnings concerning the possibility ofinjury resulting from the use of asbestos-containing products or exposure to asbestos, RESPONSE: Defendant objects to this request for production as overly broad and burdensome and calls for information or material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Further, Defendant objects to this request to the extent that many of the terms used therein are vague, ambiguous, and overly broad, which renders particular questions unintelligible, and renders a response impossible without speculation as to the meaning of the term. For instance, this objection refers to, but is not limited to Plaintiffs use of such terms as "exposure" and/or "injury" or "possibility of injury" relating to asbestos. Plaintiff fails to reference any specific use, exposure condition (i.e. concentration) or type of health injury in their requests TRCP 192.3(a). Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR PRODUCTION NO. 78: Produce all photographs ofasbestos products in place or asbestos-containing products being fabricated or uti'ized at Defendant's Premises. DNO.24989.184578 130 RESPONSE: Defendant objects to this requests for production to the extent that it seeks confidential and/or proprietary information and/or trade secrets. Further, Defendant objects to this request to the extent that it is not limited to the facilities Plaintiff allegedly worked. TRCP 192.3(a). Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on thisdate, but did not own or operate the refinery until this date. REQUEST FOR PRODUCTION NO. 79: Produce all photographs of warning signs or warning statements which are or have been in place at Defendant's Premises in the vicinity of asbestos-containing products. RESPONSE: Defendant objects to this requests for production to the extent that it seeks confidential and/or proprietary information and/or trade secrets. Further, Defendant objects to this request to the extent that it is not limited to the facilities Plaintiff allegedly worked. TRCP 192.3(a). Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR PRODUCTION NO. 80: DNO.:4989M84S78 131 Produce all documents relating to any individuals claimed injury as a result of exposure to asbestos at Defendant's Premises, including, but not limited to, workers compensation claims. RESPONSE: Defendant objects to this request for production as overly broad and burdensome and calls for information or material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Further, Defendant objects to the extent that it is not limited to the facilities at which Plaintiff allegedly worked. TRCP 192.3(a). In addition, Defendant objects to this request to the extent it seeks information the subject of which is protected from disclosure by the attorney work product privilege, the attorney/client privilege, the investigative privilege, the party communication privilege, or any other applicable privilege or immunity from discovery provided by TRCP 192.5. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR PRODUCTION NO. 81: Produce all documents, including but not limited to, corporate minutes, which mention the hazards or potential hazards of asbestos. RESPONSE: Defendant objects to this request for production as overly broad and burdensome and calls for information or material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Further, Defendant objects to the extent that it is not limited to the facilities Plaintiff allegedly worked. In addition, Defendant objects to this request to the extent that many of the terms used therein are vague, ambiguous, and overly broad, which renders particular questions unintelligible, and renders a response impossible without speculation as to the meaning of the term. For instance, this objection refers to, but is not limited to Plaintiffs use of such terms as "hazards", and/or "potential hazards" relating to asbestos. Plaintiff fails to reference any specific use, exposure condition (i.e. concentration) or type of health injury in their requests. TRCP 192.3(a). In addition. Defendant objects to this request to the extent j)no wrc 132 it seeks information the subject of which is protected from disclosure by the attorney work product privilege, the attorney/client privilege, the investigative privilege, the party communication privilege, or any other applicable privilege or immunity from discovery provided by TRCP 192.5. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR PRODUCTION NO. 82: Produce all documents, including invoices, shipping receipts, bills of lading and purchase orders, related to the purchase of asbestos-containing products for use at Defendant's Premises. RESPONSE: Defendant objects to this request for production as overly broad and burdensome and calls for information or material which is neither relevant nor reasonably calculated to lead to the discovery ofadmissible evidence. Further, Defendant objects to this request to the extent that it is not limited to the facilities Plaintiff allegedly worked. TRCP 192.3(a), Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. DN'O* 2-4989* 18*4$78 133 REQUEST FOR PRODUCTION NO. 83: Produce all documents relating to inspections by labor inspectors, insurance company inspectors or anyone from your company or hired by your company, that included the taking or measuring of "dust counts". RESPONSE: Defendant objects to this request for production as overly broad and burdensome and calls for information or material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Further, Defendant objects to the extent that it is not limited to the facilities Plaintiff allegedly worked. TRCP 192.3(a). In addition, Defendant objects to this request to the extent it seeks information the subject of which is protected from disclosure by the attorney work product privilege, the attorney/client privilege, the investigative privilege, the party communication privilege, or any other applicable privilege or immunity from discovery provided by TRCP 192.5. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did notown or operate the refinery until this date. REQUEST FOR PRODUCTION NO. 84: In the event that Defendant performed or had performed any dust.level counts or measurements ofany ofits plants or industrial facilities with respect to asbestos dust, produce any documents, memoranda, or other writings that in any way reflect the results of such studies or counts and actions taken as a result of such counts or studies. RESPONSE: Defendant objects to this request for production as overly broad and burdensome and calls for information or material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Further, Defendant objects to the extent that it is not limited to the facilities Plaintiff allegedly worked. TRCP 192.3(a). In addition, Defendant objects to this request to the extent it seeks information the subject of which is protected from disclosure by the attorney work product privilege, the DNO/249$9'IW578 134 attorney/client privilege, the investigative privilege, the party communication privilege, or any other applicable privilege or immunity from discovery provided by TRCP 192.5. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR PRODUCTION NO. 85: Produce all reports, writings (whether published or unpublished) and/or other documentation written, created and/or edited by any ofyour experts that in any way pertain to asbestos and the hazards and/or diseases that may result therefrom. RESPONSE: Defendant objects to this request for production as overly broad and burdensome and calls for information or material which is neither relevant nor reasonably calculated to lead to the discovery ofadmissible evidence. Further, Defendant objects to this request to the extent that many of the terms used therein are vague, ambiguous, and overly broad, which -renders particular questions unintelligible, and renders a response impossible without speculation as to the meaning of the term. For instance, this objection refers to, but is not limited to Plaintiffs use of such terms as "hazards" and/or "diseases" relating to asbestos. Plaintiff fails to reference any specific use, exposure condition (i.e. concentration) or type of health injury in their requests TRCP 192.3(a). Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. DSO 24989 ls*4>78 135 REQUEST FOR PRODUCTION NO. 86: Produce all documents which will be used at the time of trial, including all potential exhibits and those documents which may be used to cross-examine other witnesses or in rebuttal, and which you contend are relevant to any of Defendant's enumerated defenses in Defendant's most recently filed Answer. RESPONSE: Defendant objects to this request for production to the extent that it is overly broad and burdensome and seeks information, the subject of which is protected from disclosure by the attorney work product privilege. Defendant will identify witnesses and trial exhibits at such time as the court may require. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR PRODUCTION NO. 87: Produce documents between Defendant and any of its worker's compensation carriers regarding the hazards of asbestos and asbestos-containing products. RESPONSE: Defendant objects to this request for production as overly broad, vague, unduly burdensome, mid calls for information or material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Defendant objects to this request for production because it seeks information for time periods other than those upon which Plaintiff's claims against Defendant are based, and it is not limited to the facilities where Plaintiff allegedly worked. Further, Defendant objects to this request to the extent that many of the terms used therein are vague, ambiguous, and overly broad, which renders particular questions unintelligible, and renders a response impossible without speculation as to the meaning of the term. For DN<M49S9.1S4578 136 instance, this objection refers to, but is not limited to Plaintiffs use of such terms as "hazards" relating to asbestos. Plaintiff fails to reference any specific use, exposure condition (i.e. concentration) or type of health injury in their requests TRCP 192.3(a). Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its nametoCITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR PRODUCTION NO. 88: Produce a copy ofall regulations, orders, rules and/or policies which have been used relating to the safety of the Defendant's Premises. RESPONSE: Defendant objects to this request for production as overly broad, vague, unduly burdensome, and calls for information or material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Further, Defendant objects to this request to the extent that it is not limited to the facilities Plaintiff allegedly worked. TRCP 192.3(a). Defendant objects to this request for production because it seeks information for time periods other than those upon which Plaintiff's claims against Defendant are based. Defendant also objects to this request in that it is not limited to health and safety regulations dealing with asbestos. Defendant objects to the production of documents which are protected by the attorney/client self audit/self critical analysis, or other privilege. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR PRODUCTION NO, 89: \DNO/249S9' $4$78 137 Produce all documents which contain complaints by employees of the Defendant's Premises regarding safety conditions and work place conditions at the Defendant's Premises. RESPONSE. Defendant objects to this request for production as overly broad, vague, unduly burdensome, and calls for information or material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Further, Defendant objects to this request to the extent that it is not limited to the facilities Plaintiff allegedly worked. TRCP 192.3(a). Defendant objects to this request for production because it seeks information for time periods other than those upon which Plaintiff's claims against Defendant are based. Defendant also objects to this request in that it is not limited to health and safety regulations dealing with asbestos. Defendant objects to the production of documents which are protected by the attorney/client self audit/self critical analysis, or other privilege. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did notown or operate the refinery until this date. REQUEST FOR PRODUCTION NO. 90: Produce all documents which contain complaints by Union representatives of Defendant's Premises regarding safety conditions and work place conditions at the Defendant's Premises. RESPONSE: Defendant objects to this request for production as overly broad, vague, unduly burdensome, and calls for information or material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. Further, Defendant objects to this request to the extent that it is not limited to the facilities Plaintiff allegedly worked. TRCP 192.3(a). Defendant objects to this request for production because it seeks information for time periods other than those upon which Plaintiffs claims against Defendant are based. Defendant also objects to this request in that it is not limited to health and safety regulations dealing with asbestos. . Defendant objects to the production of documents which are protected by the attorney/client self audit/self critical analysis, or other privilege. .A< Mv>;y 1>n78 138 Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold ail of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR PRODUCTION NO. 91: Produce all documents, organizational charts or rosters which identify the members of the management at the Defendant's Premises and their areas of responsibility during the time period of Plaintiffs work at Defendant's Premises. RESPONSE: Defendant objects to this request for production as overly broad, vague, unduly burdensome, and calls for information or material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. TRCP 192.3(a). Plaintiff has not formally indicated the time period he claims to have been present at Defendant' facilities. Defendant assume the period of time was from 1961 to 1964 and will search for organizational charts and rosters during those years. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation, CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR PRODUCTION NO. 92: Produce all documents which evidence Defendant's, net worth, including but not limited to all "10-K" forms filed for the last five (5) years. RESPONSE: Defendant objects to this request as overly broad, vague, and unduly burdensome with which to comply. Defendant objects to this request for production to the extent that it DN'U-24989/184578 139 is not limited to the facilities Plaintiff allegedly worked. TRCP 192.3(a). Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR PRODUCTION NO. 93: Produce all documents which evidence Defendant's purchase, acquisition, sale, or transfer of ownership of Defendant's Premises. RESPONSE: Defendant objects to this request for production as overly broad, vague, unduly burdensome, and burdensome and calls for information or material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence TRCP 192.3(a). Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. OnAugust31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR PRODUCTION NO. 94: Produce all indemnity agreements, assignments ofliability, subrogation agreements and other similar documents relating to Defendant's Premises and liabilities arising from said ownership. RESPONSE: Defendant objects to this request for production as overly broad, vague, unduly burdensome, and calls for information or material which is neither relevant nor DNO/24989' 184578 140 reasonably calculated to lead to the discovery of admissible evidence TRCP 192.3(a). Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR PRODUCTION NO. 95: Produce all contracts pertaining to work done by contractors at Defendant's facility. RESPONSE: Defendant objects to this request for production as overly broad, vague, unduly burdensome, and calls for information or material which is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence TRCP 192.3(a). Defendant objects to this request for production because it seeks information for time periods other than those upon which Plaintiffs claims against Defendant are based. Defendant also objects to this request in that it is not limited to contractors dealing with asbestos. Defendant objects to the production of documents which are protected by the attorney/client self audit/self critical analysis, or other privilege. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR PRODUCTION NO. 96: Please produce any printed material produced or published by Defendant containing any warnings concerning the possibility of injury resulting from the use of asbestos-containing products or exposure to asbestos? RESPONSE: Defendant objects to this request as overly broad, vague, irrelevant and unduly DNO<24989.184578 141 burdensome. Defendant objects to this request for production because it seeks information for time periods other than those upon which Plaintiffs claims against Defendant are based, and it is not limited to the facilities where Plaintiff worked. Defendant objects to the production of documents which are protected by the attorney/client or other privilege. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR PRODUCTION NO. 97: Produce all documents and other tangible things relating to the Plaintiff. RESPONSE: Defendant objects to this request for production to the extent that the phrase "tangible things relating to" is vague, ambiguous, and overly broad, which renders this particular request unintelligible, and renders a response impossible without speculation as to the meaning of the term. Defendant further objects to this request for production as it is nothing but a "fishing expedition" in violation of Texas law concerning discovery Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. REQUEST FOR PRODUCTION NO. 98: If you content that you did not own or control the facility(ies) during any time period that Plaintiffworked (or believes he worked) at the facility(ies), please produce all documentation that supports your contention, including but not limited to documentation pertaining to the purchase, sale, acquisition, merger, or divestment ofcorporations, subsidiaries, divisions, or other corporate entities or assets that include the purchase, sale, acquisition, merger, or divestment of the facility(ies); such documentation to include, by way of example and not DNCM4989.IS4578 142 limitation, purchase or sale agreements, minutes, resolutions, annual reports, 10K reports or other state or federal agency filings, or deposition, trial testimony or affidavits of your corporate representatives who are the most knowledgeable individuals with respect to such matters. RESPONSE. Defendant objects to the request as overly broad, irrelevant and the terms "own or control" as vague and ambiguous. Defendant further objects because this request is not limited to a relevant time period. Defendant further objects because the request is outside the scope of TRCP 192.3 and not calculated to lead to the discovery of admissible evidence. Cities Service RMT Corporation was incorporated in March, 1983 and did not operate or exist as a company prior to that time. In April, 1983 Cities Service RMT Corporation changed its name to CITGO Petroleum Corporation. On August 31,1983, Cities Service Company sold all of the stock of CITGO Petroleum Corporation to The Southland Corporation. CITGO Petroleum Corporation purchased the refinery located in Lake Charles, Louisiana on this date, but did not own or operate the refinery until this date. DN0249S9/I84578 143