Document jyRdznnjELOQEzm3wb15ZYV9

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OHIO WESTERN DIVISION HERMAN A. DENDINGER, et al. Plaintiffs, vs. CHRYSLER PLASTIC PRODUCTS CORPORATION, et al., Case No. C 84-7854 [Hon. Nicholas J. Walinski] RESPONSE OF DEFENDANT UNIROYAL, INC. TO PLAINTIFFS' REQUESTS . FOR PRODUCTION OF DOCUMENTS DIRECTED TO- ALL DEFENDANT PVC MANUFACTURERS Defendants. -0O0- Now comes, defendant, Uniroyal', Inc. .and for its, response to plaintiffs' requests for production of documents, states-as follows; 1. All records.of sales, direct or indirect, of Polyvinyl Chloride (PVC) resin from you to Chrysler Plastic Products Corporation (Chrysler) between January 1, 1967 and December 31, 1980. ANSWER; Records containing such information are available for inspection and copying at Uniroyal's World Headquarters, Middlebury, Connecticut. 2._A11 documents indicating the extent to which PVC resin sales to Chrysler during the time period indicated above, represented sales of PVC resin manufactured in the; (a) suspension; (b) emulsion; (c) bulk; or, (d) solution process. ANSWER; See response to Request for Production No. 1. UCC 045350 3. All documents indicating the extent to which PVC resin sales to Chrysler during the time period specified in request number l,;were of (a) Homopolymer;;(b) copolymer; or, (c)' terpolymer. ANSWER: See response to Request for Production'No. 1, and Attachment 1. 4. All written documents indicating, with respect to PVC resin sold to Chrysler during the time period specified above, the size (in microns) of the resin sold. . ANSWER: j- See response to-Request for Production No. 1, and Attachments 1 and 2. 5. All written documents indicating the results of any tests done on any PVC resin by you or any other entity to determine the concentration (in parts per million) of residual vinyl chloride monomer in PVC resin of the type sold to Chrysler during the time period specified in request number 1. ANSWER: See^answer to Interrogatory No. 10. 6. All Material Safety Data Sheets published by you * prior to January 1, 1986, relating to any PVC resin manufactured by you. 2- - UCC 045851 ANSWER: Objection, any Material Safety Data Sheet, published subsequent .to 1980, the last date of exposure in this case, is irrelevant.. See Attachment 3. 7. All documents in your possession indicating the dates of manufacture-and the'dates of shipment of PVC resin sold' to Chrysler. ANSWER: See answer to Interrogatory No. 12. 8. All written results of any testing done on the PVC resin identified.in the prior'request to determine theconcentration of residual vinyl- chloride monomer. ANSWER: See answer to Interrogatory No. 10. 9. All documents sent by you to the Occupational Safety & Health Administration, relating, in any way, to PVC. ANSWER: See Attachment 4. 10. All documents reporting or summarizing efforts taken by you, at any time since January 1, 1967 to reduce the percentage of residual vinyl chloride monomer in PVC resin manufactured by you. ANSWER: See answer to Interrogatory No. 10. 3- - UCC 045852 11. Each and every document sent to Chrysler, informing Chrysler of any known or potential human health hazard relating to exposure or over exposure to vinyl chloride monomer. ANSWER: See answer to Interrogatory No. 14. 4- - UCC 045353 STATE OF CONNECTICUT ) ) ss COUNTY OF NEW HAVEN ) VERIFICATION BENTON R. LEACH, being duly sworn, deposes and says that he is Corporate Director, Health, Safety and Environmental Affairs of Uniroyal Chemical Company, Inc. and that he has read the, foregoing Responses to Request to Produce and is fqmiliar with the contents, thereof. He further states that he is informed and believes that the matters stated therein are true and on that ground he alleges that the matters stated therein are true. Benton R. Leach~ Sworn to before me this^^day of September, 1986. 4 Notary Public MADCUNE PAZZANI Notary Public My cocnmictioo expire* Mcreh 31,1990 LDL4/87a ucc 045854 AS TO OBJECTIONS: Of Counsel For Defendants The BFGoodrich Co., The Goodyear Tire & Rubber Co., Firestone Tire & Rubber Co., Conoco, Inc., Uniroyal, Inc. Union Carbide Corp., and Diamond Shamrock Corp. : FULLER & HENRY 1200 Edison Plaza 300 Madison Avenue P.O. Box 2088 Toledo, Ohio 43603 Robert A.'Bunda ^ 1200 Edison Plaza 300 Madison Avenue P.O. Box 2088 Toledo, Ohio 43603 Telephone: (419) 255-8220 Attorney for" Defendants The BFGoodrich Co., The Goodyear Tire & Rubber Co., Firestone Tire & Rubber Co., Conoco, Inc., Uniroyal, Inc., Union Carbide Corp., and Diamond Shamrock Corp. CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Responses^ to Plaintiff's Requests for Production of Documents Directed to all Defendant PVC Manufacturers was mailed by United States mail, postage prepaid, to Kirk J. Delli Bovi, Esq., attorney for plaintiff, at his office located at Murray & Murray Co., L.P.A., 300 Central Avenue, Sandusky, Ohio 44870, and to defense counsel yas set forth in the attached Schedule of Service this - ' : day of October, 1986. Ann'Attt/oprrnneey fqr// DDee: fendants tThe Goodyear Tire Rubber Company, The BFGoodrich Company, Firestone Tire & Rubber Company, Conoco, Inc., Uniroyal, Inc., Union Carbide Corporation, and Diamond Shamrock Corp. uec 045855 SCHEDULE OF SERVICE K. Donald Carmin, Esq. 800 United Savings Building Toledo, Ohio 43604 Attorney for Defendants Chrysler Plastic Products Corporation Norman P. Phillips Albert W. Cramer Robert D. Gustine William C. Holsapple Ron C. Abbott Willis P. Jones, Jr., Esq. 200 Toledo Legal Building 416 N. Erie Street Toledo, Ohio 43624 Attorney for Defendant DiversiTech General, Inc. S. Stuart Eilers, Esq. Douglas N. Barr, Esq. Timothy J. Coughlin, Esq. 1100 National City Bank Bldg. Cleveland, Ohio 44114 Attorney for Defendant Stauffer Chemical Company H. William Bamman, Esq. 414 K. Erie Street Toledo, Ohio 43624 Attorney for Defendant A. Schulman, Inc. Ellis F. Robinson, Esq. 610 United Savings Building Toledo, Ohio 43604 Attorney for Defendant Shintech, Inc. UCC 045856