Document jzywqzbvbQD3333moYwYJo6Z

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF LOUISIANA GORDON DAVID THOMPSON and BESSIE M. THOMPSON VERSUS CONOCO INCORPORATED, ET AL * * * * CIVIL ACTION NO. 93-809 SECTION: "B" MAG. NO. 2 CONOCO INC.'S OBJECTIONS AND RESPONSES TO PLAINTIFFS* REQUEST FOR ADMISSIONS NOW INTO COURT, through undersigned counsel, comes defendant, Conoco Inc. ("Conoco"), which provides this response to Plaintiffs' Request for Admissions. Conoco reserves the right to supplement this discovery at any time prior to trial. The requests and corresponding objections are as follows: GENERAL OBJECTIONS Conoco Inc. objects to each and every Request for Admissions propounded by plaintiffs to the extent any request seeks information: (1) from companies other than Conoco Chemicals; (2) regarding facilities other than the Aberdeen, Mississippi facility; (3) for a time period beyond the plaintiff's employment there and beyond Conoco Chemicals' ownership of the Aberdeen, Mississippi facility; (4) regarding a condition other than that allegedly contracted by the plaintiff; and concerning employees other than the plaintiff since each individual's medical history, work conditions, etc., vary and those employees are entitled to a right to privacy, all pursuant to Rules 36 and 26(b)(1) of the Federal Rules of Civil Procedure. DEFINITIONS DEFINITION NO, 4: "YOU" or "YOURS" or "YOUR COMPANY" or "DEFENDANT" unless limited by the wording of the question, should be understood as referring to the named Defendant upon whom these Requests for Admissions are served, including all parent corporations, subsidiaries, divisions, predecessors in interest, and successors in interest and including the directors, officers, employees, agents, servants, and representatives of these companies, inclusively. OBJECTION: This definition is objected to purusant to Rules 36 and 26(b)(1) of the Federal Rules of Civil Procedure. Defendant generally objects to Definition No. 4 on the grounds that numerous entities contained within said definition have not been named as parties to this action. Defendant agrees to answer these Request for Admissions on behalf of itself and any subsidiary or predecessor company previously owned and operated by this Defendant and which company employed Plaintiff. DEFINITION NO. 5: "VINYL CHLORIDE FACILITY" refers to any and all facilities operated by this defendant at any time between 1948 to present, whereby Vinyl Chloride was used, produced, manufactured and/or stored. OBJECTION: This definition is objected to purusant to Rules 36 and 26(b)(1) of the Federal Rules of Civil Procedure. Defendant generally objects to the definition of "VINYL CHLORIDE FACILITY" on the grounds that Plaintiff did not work in each and every vinyl chloride facility of Defendant but was employed only by Defendant at that vinyl chloride facility located in Aberdeen, Mississippi. Furthermore, Defendant objects to -2- responding to any Request for Admission for any time frame prior to 1969 or after 1983 on the grounds that it was only in the 1969-1983 time frame wherein Plaintiff was employed by Defendant. Defendant agrees to respond to these Request for Admissions for the time frame 1969-1983 and as they pertain to Defendant's facility in Aberdeen, Mississippi. DEFINITION NO. 6: "EXECUTIVE OFFICERS" includes Chief Executive Officers, Presidents, Vice Presidents, Department Heads, Medical Directors, Industrial Hygienist, Safety Personnel, Superintendents, Nurses and/or Supervisors of your company (as defined above by definition "C"). OBJECTION; This definition is objected to purusant to Rules 36 and 26(b)(1) of the Federal Rules of Civil Procedure. Defendant objects to the definition of "EXECUTIVE OFFICERS" to the extent said definition is in contravention of the judicially adopted definition of the States of Louisiana and/or Mississippi. REQUEST FOR ADMISSIONS REQUEST FOR ADMISSION NO. 1; Do you admit that this defendant has been correctly named as a defendant in the present cause, in so far as the legal designation of the name is concerned? RESPONSE; Denied. REQUEST FOR ADMISSION NO. 2: Do you admit that this defendant has been correctly served as a party defendant in the present cause? -3- RESPONSE: Admitted. REQUEST FOR ADMISSION NO. 3: Do you admit that this defendant has done in excess of $10,000.00 per year worth of business with the United States of America and/or any political subdivision thereof in: a. b. c. d. e. f. gh. i. j* k. 1. m. n. o. P- q. r. s. t. u. V. w. X, yz. aa. bb. ec. dd. ee. ff. eghh. 1960 1961 1962 1963 1964 1965 1966 1967 1968 1969 1970 1971 1972 1973 1974 1975 1976 1977 1978 1979 1980 1981 1982 1983 1984 1985 1986 1987 1988 1989 1990 1991 1992 1993 R&SJ63T08 -4 - RESPONSE: Defendant reiterates its general objections. Defendant further states that the Request for Admission is irrelevant for the time frame 1960 through 1968 and 1984 through 1993 on the ground that Plaintiff was not an employee of this Defendant during that time. Subject to its objections, Defendant admits Request for Admission No. 3 for the time frame 1969 through 1983, inclusive. REQUEST FOR ADMISSION NO. 4: Do you admit that your company used Vinyl Chloride at your Vinyl Chloride facility in; a. 1947 b. 1948 c. 1949 d. 1950 e. 1951 f. 1952 g* 1953 h. 1954 i. 1955 j- 1956 k. 1957 1. 1958 m. 1959 n. 1960 o. 1961 P- 1962 q* 1963 r. 1964 s. 1965 t. 1966 u. 1967 V. 1968 w. 1969 X. 1970 y- 1971 z. 1972 aa. 1973 bb. 1974 cc. 1975 dd. 1976 ee. 1977 ff. 1978 -5- R&S163109 gg* 1979 hh. 1980 ii. 1981 ii- 1982 kk. 1983 11. 1984 mm. 1985 nn. 1986 oo. 1987 PP- 1988 qq. 1989 rr. 1990 ss. 1991 tt. 1992 uu. 1993 RESPONSE Defendant reiterates its general objections. Defendant further states that Request for Admission No. 4 is irrelevant for that time frame of 1947 through 1968 and 1984 through 1993 on the ground that Plaintiff was not an employee of this Defendant during that time. Subject to its objections, Defendant admits Request for Admission No. 4 for the time frame 1969 through 1983, inclusive. REQUEST FOR ADMISSION NO. 5; Do you admit that your company stored Vinyl Chlorida at your Vinyl Chloride facility in: a. 1948 b. 1949 c. 1950 d. 1951 e. 1952 f. 1953 g- 1954 h. 1955 i. 1956 j- 1957 k. 1958 1. 1959 m. 1960 n. 1961 o. 1962 P- 1963 q- 1964 R&S163110 -6- r. 1965 s. 1966 t. 1967 u. 1968 V. 1969 w. 1970 X. 1971 y- 1972 z. 1973 aa. 1974 bb. 1975 cc. 1976 dd. 1977 ee. 1978 ff. 1979 gg- 1980 hh. 1981 ii. 1982 ii- 1983 kk. 1984 11. 1985 mm. 1986 nn. 1987 00. 1988 pp. 1989 qq. 1990 rr. 1991 ss. 1992 tt. 1993 RESPONSE Defendant reiterates its general objections. Defendant further states- that Request for Admission No. 5 is irrelevant for that time frame of 1948 through 1968 and 1984 through 1993 on the ground that Plaintiff was not an employee of this Defendant during that time. Subject to its objections, Defendant admits Request for Admission No. 5 for the time frame 1969 through 1983, inclusive. REQUEST FOR ADMISSION NO. 6; Do you admit that your company handled Vinyl Chloride at your Vinyl Chloride facility in: a. 1948 b. 1949 c. 1950 -7- d. 1951 e. 1952 f. 1953 g* 1954 h. 1955 i. 1956 j* 1957 k. 1958 1. 1959 m. 1960 n. 1961 o. 1962 P* 1963 <3- 1964 r. 1965 s. 1966 t. 1967 u. 1968 V. 1969 w. 1970 X. 1971 y- 1972 z. 1973 aa. 1974 bb. 1975 cc. 1976 dd. 1977 ee. 1978 ff. 1979 gg- 1980 hh. 1981 ii. 1982 ji- 1983 kk. 1984 11. 1985 mm. 1986 nn. 1987 00. 1988 PP- 1989 qq. 1990 rr. 1991 ss. 1992 tt. 1993 RESPONSE: Defendant reiterates its general objections. Defendant further states that Request for Admission No. 6 is irrelevant for that time frame of 1948 through 1968 and 1984 through 1993 on the ground that Plaintiff was not an employee of this -8- R&S163112 Defendant during that time. Subject to its objections, Defendant admits Request for Admission No. 6 for the time frame 1969 through 1983, inclusive. REQUEST FOR ADMISSION NO. 7; Do you admit that your company transported Vinyl Chloride at or from your Vinyl Chloride facility in: a. b. c. d. e. f. g* h. i. jk. 1. m. n. o. P* <3r. s. t. u. V. w. X. yz. aa. bb. cc. dd. ee. ff. gg* hh. ii. jj* kk. 11. mm. nn. 1948 1949 1950 1951 1952 1953 1954 1955 1956 1957 1958 1959 1960 1961 1962 1963 1964 1965 1966 1967 1968 1969 1970 1971 1972 1973 1974 1975 1976 1977 1978 1979 1980 1981 1982 1983 1984 1985 1986 1987 eviesiissu -9- 00. 1988 pp. 1989 qq. 1990 rr. 1991 ss. 1992 tt. 1993 RESPONSE: Defendant reiterates its general objections. Defendant further states that Request for Admission No. 7 is irrelevant for that time frame of 1948 through 1968 and 1984 through 1993 on the ground that Plaintiff was not an employee of this Defendant during that time. Subject to its objections, Defendant admits Request for Admission No. 7 for the time frame 1969 through 1983, inclusive. REQUEST FOR ADMISSION NO. 8; Do you admit that your company manufactured Vinyl Chloride at your Vinyl Chloride facility in: a. 1948 b. 1949 c. 1950 d. 1951 e. 1952 f. 1953 1954 h. 1955 i. 1956 i- 1957 k. 1958 1. 1959 m. 1960 n. 1961 0. 1962 P- 1963 q- 1964 r. 1965 s. 1966 t. 1967 u. 1968 V. 1969 w. 1970 X. 1971 y- 1972 z. 1973 - 10 - R&S163114 aa. 1974 bb. 1975 cc. 1976 dd. 1977 ee. 1978 ff. 1979 gg- 1980 hh. 1981 ii. 1982 jj- 1983 kk. 1984 11. 1985 mm. 1986 nn. 1987 oo. 1988 pp. 1989 qq. 1990 rr. 1991 ss. 1992 tt. 1993 RESPONSEi* Defendant reiterates its general objections. Defendant further states that Request for Admission No. 8 is irrelevant for that time frame of 1948 through 1968 and 1984 through 1993 on the ground that Plaintiff was not an employee of this Defendant during that time. Subject to its objections, Defendant admits Request for Admission No. 8 for the time frame 1969 through 1983, inclusive. REQUEST FOR ADMISSION NO. 9; Do you admit that your company used Vinyl Chloride containing products at your Vinyl Chloride facility in: a. 1948 b. 1949 c. 1950 d. 1951 e. 1952 f. 1953 g- 1954 h. 1955 i. 1956 ]' 1957 k. 1958 1. 1959 - 11 - R&S163115 m. 1960 n. 1961 o. 1962 P* 1963 q- 1964 r. 1965 s. 1966 t. 1967 u. 1968 V. 1969 w. 1970 X. 1971 y* 1972 z. 1973 aa. 1974 bb. 1975 cc. 1976 dd. 1977 ee. 1978 ff. 1979 gg* 1980 hh. 1981 ii. 1982 jj- 1983 kk. 1984 11. 1985 mm. 1986 nn. 1987 oo. 1988 pp. 1989 qq. 1990 rr. 1991 ss. 1992 tt. 1993 RESPONSE Defendant reiterates its general objections. Defendant further states that Request for Admission No. 9 is irrelevant for that time frame of 1948 through 1968 and 1984 through 1993 on the ground that Plaintiff was not an employee of this Defendant during that time. Subject to its objections, Defendant admits Request for Admission No. 9 for the time frame 1969 through 1983, inclusive. - 12 - R&S163116 REQUEST FOR ADMISSION NO. 10: Do you admit that your company stored Vinyl Chloride containing products at your Vinyl Chloride facility in: a. b. c. d. e. f. S* h. i. j* k. 1. m. n. 0. P* <3* r. s. t. u. V. w. X. y* z. aa. bb. cc. dd. ee. ff. EE* hh. ii. jj* kk. 11. mm. nn. oo. pp. qq. rr. 1948 1949 1950 1951 1952 1953 1954 1955 1956 1957 1958 1959 1960 1961 1962 1963 1964 1965 1966 1967 1968 1969 1970 1971 1972 1973 1974 1975 1976 1977 1978 1979 1980 1981 1982 1983 1984 1985 1986 1987 1988 1989 1990 1991 R&Sl 63117 - 13 - ss. 1992 tt. 1993 RESPONSE; Defendant reiterates its general objections. Defendant further states that Request for Admission No. 10 is irrelevant for that time frame of 1948 through 1968 and 1984 through 1993 on the ground that Plaintiff was not an employee of this Defendant during that time. Subject to its objections, Defendant admits Request for Admission No, 10 for the time frame 1969 through 1983, inclusive. REQUEST FOR ADMISSION NO. 11: Do you admit that your company handled Vinyl Chloride containing products at your Vinyl Chloride facility in; a. 1948 b. 1949 c. 1950 d. 1951 e. 1952 f. 1953 g- 1954 h. 1955 i. 1956 j* 1957 k. 1958 1. 1959 m. 1960 n. 1961 o. 1962 P- 1963 q- 1964 r. 1965 s. 1966 t. 1967 u. 1968 V. 1969 w. 1970 X. 1971 y- 1972 z. 1973 aa. 1974 bb. 1975 cc. 1976 dd. 1977 - 14 - R&S163118 ee. 1978 ff. 1979 re- 1980 hh. 1981 ii. 1982 jj- 1983 kk. 1984 11. 1985 mm. 1986 nn. 1987 oo. 1988 pp. 1989 qq. 1990 rr. 1991 ss. 1992 tt. 1993 RESPONSE Defendant reiterates its general objections. Defendant further states that Request for Admission No. 11 is irrelevant for that time frame of 1948 through 1968 and 1984 through 1993 on the ground that Plaintiff was not an employee of this Defendant during that time. Subject to its objections, Defendant admits Request for Admission No. 11 for the time frame 1969 through 1983, inclusive. REQUEST FOR ADMISSION NO. 12; Do you admit that your company transported Vinyl Chloride containing products at or from your Vinyl Chloride facility in: a. 1948 b. 1949 c. 1950 d. 1951 e. 1952 f. 1953 g. 1954 h. 1955 i. 1956 j. 1957 k. 1958 l. 1959 m. 1960 n. 1961 o. 1962 p. 1963 - 15 - R&S163119 <3* 1964 r. 1965 s. 1966 t. 1967 u. 1968 V. 1969 w. 1970 X. 1971 y- 1972 z. 1973 aa. 1974 bb. 1975 cc. 1976 dd. 1977 ee. 1978 ff. 1979 Eg- 1980 hh. 1981 ii. 1982 jj- 1983 kk. 1984 11. 1985 mm. 1986 nn. 1987 00. 1988 pp. 1989 qq. 1990 rr. 1991 ss. 1992 tt. 1993 RESPONSE Defendant reiterates its general objections. Defendant further states that Request for Admission No. 12 is irrelevant for that time frame of 1948 through 1968 and 1984 through 1993 on the ground that Plaintiff was not an employee of this Defendant during that time. Subject to its objections, Defendant admits Request for Admission No. 12 for the time frame 1969 through 1983, inclusive. REQUEST FOR ADMISSION NO. 13: Do you admit that your company manufactured Vinyl Chloride containing products at your Vinyl Chloride facility in: a. 1948 b. 1949 - 16 - R&S163120 c. 1950 d. 1951 e. 1952 f. 1953 g- 1954 h. 1955 i. 1956 j- 1957 k. 1958 1. 1959 m. 1960 n. 1961 o. 1962 P- 1963 q- 1964 r. 1965 s. 1966 t. 1967 u. 1968 V. 1969 w. 1970 X. 1971 y- 1972 z. 1973 aa. 1974 bb. 1975 cc. 1976 dd. 1977 ee. 1978 ff. 1979 gg- 1980 hh. 1981 ii. 1982 31- 1983 kk. 1984 11. 1985 mm. 1986 nn. 1987 oo. 1988 pp. 1989 qq. 1990 rr. 1991 ss. 1992 tt. 1993 RESPONSE: Defendant reiterates its general objections. Defendant further states that Request for Admission No. 13 is irrelevant for that time frame of 1948 through 1968 - 17 - R&S163121 and 1984 through 1993 on the ground that Plaintiff was not an employee of this Defendant during that time- Subject to its objections, Defendant admits Request for Admission No. 13 for the time frame 1969 through 1983, inclusive. REQUEST FOR ADMISSION NO. 14: Do you admit that your company recognizes that there was an association between an exposure to Vinyl Chloride and: a. Acute myelogenous leukemia b. Leukemia c. Lymphoma d. Disorders of the hemopoietic system e. Disorders of the lymphatic system f. Brain cancer g. Astrocytoma h. Glioblastoma i. Angio sarcoma RESPONSE: Defendant reiterates its general objections. Defendant further objects to Request for Admission No. 14 on the grounds that said request is vague and ambiguous, because no time frame is given in the Request for Admission. Defendant further objects to Request for Admission No. 14(a)-(f) and 14(h)-(i) as being irrelevant to the extent that it seeks this defendant to admit facts regarding conditions from which Plaintiff allegedly does not suffer. Subject to its objections, Defendant denies Request for Admission No. 14(g). REQUEST FOR ADMISSION NO. 15: Do you admit that any person or entity has ever affirmatively indicated to you that the following conditions may result from exposure to Vinyl Chloride: a. Acute myelogenous leukemia b. Leukemia c. Lymphoma d. Disorders of the hemopoietic system e. Disorders of the lymphaticsystem f. Brain cancer - 18 - g. Astrocytoma h. Glioblastoma i. Angio sarcoma RESPONSE: Defendant reiterates its general objections. Defendant further objects to Request for Admission No. 15 on the grounds that said request is vague and ambiguous, because no time frame is given in the Request for Admission. Defendant further objects to Request for Admission No. 15(a)-(f) and 14(h)-(i) as being irrelevant to the extent that it seeks this defendant to admit facts regarding conditions from which Plaintiff allegedly does not suffer. Subject to its objections, Defendant denies Request for Admission No. 15(g). REQUEST FOR ADMISSION NO. 16; Do you admit that any physician, nurse or other health care provider employed by your company, operating within the scope of that employment from the years 1948 through the present has ever affirmatively indicated that acute myelogenous leukemia may be caused as a result of exposure to Vinyl Chloride? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 17; Do you admit that any physician, nurse or other health care provider employed by your company, operating within the scope of that employment from the years 1948 - 19 - through the present has ever affirmatively indicated that leukemia may be caused as a result of exposure to Vinyl Chloride? RESPONSE; Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 18; Do you admit that any physician, nurse or other health care provider employed by your company, operating within the scope of that employment from the years 1948 through the present has ever affirmatively indicated that lymphoma may be caused as a result of exposure to Vinyl Chloride? RESPONSE; Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 19; Do you admit that any physician, nurse or other health care provider employed by your company, operating within the scope of that employment from the years 1948 - 20 - R&S163124 \ through the present has ever affirmatively indicated that disorders of the hemopoietic system may be caused as a result of exposure to Vinyl Chloride? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 20: Do you admit that any physician, nurse or other health care provider empoyed byouour company, operating within the scope of that employment from the years 1948 through the present has ever affirmatively indicated that disorders of the lymphatic system may be caused as a result of exposure to Vinyl Chloride? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 21: Do you admit that any physician, nurse or other health care provider employed by your company, operating within the scope of that employment from the years 1948 - 21 - R&S163125 through the present has ever affirmatively indicated that brain cancer may be caused as a result of exposure to Vinyl Chloride? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 22: Do you admit that any physician, nurse or other health care provider employed by your company, operating within the scope of that employment from the years 1948 through the present has ever affirmatively indicated that angio sarcoma may be caused as a result of exposure to Vinyl Chloride? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 23: Do you admit that any physician, nurse or other health care provider employed by your company, operating within the scope of that employment from the years 1948 - 22 - R&Sl 63126 through the present has ever affirmatively indicated that astrocytoma may be caused as a result of exposure to Vinyl Chloride? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Subject to its objections, Request for Admission No. 24 is denied. REQUEST FOR ADMISSION NO. 24: Do you admit that any physician, nurse or other health care provider employed by your company, operating within the scope of that employment from the years 1948 through the present has ever affirmatively indicated that glioblastoma may be caused as a result of exposure to Vinyl Chloride? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 2S: Do you admit that any physician, nurse or other health care provider employed by your company, operating within the scope of that employment from the years 1948 through present has ever affirmatively indicated that acute myelogenous leukemia may be caused as a result of exposure to Vinyl Chloride containing products? - 23 - R&S163127 RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 26: Do you admit that any physician, nurse or other health care provider employed by your company, operating within the scope of that employment from the years 1948 through present has ever affirmatively indicated that leukemia may be caused as a result of exposure to Vinyl Chloride containing products? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 27: Do you admit that any physician, nurse or other health care provider employed by your company, operating within the scope of that employment from the years 1948 through present has ever affirmatively indicated that disorders of the hemopoietic system may be caused as a result of exposure to Vinyl Chloride containing products? - 24 - R&Sl 63128 RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 28: Do you admit that any physician, nurse or other health care provider employed by your company, operating within the scope of that employment from the years 1948 through present has ever affirmatively indicated that disorders of the lymphatic system may be caused as a result of exposure to Vinyl Chloride containing products? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 29: Do you admit that any physician, nurse or other health care provider employed by your company, operating within the scope of that employment from the years 1948 through present has ever affirmatively indicated that brain cancer may be caused as a result of exposure to Vinyl Chloride containing products? - 25 - R&S163129 RESPONSE; Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 30; Do you admit that any physician, nurse or other health care provider employed by your company, operating within the scope of that employment from the years 1948 through present has ever affirmatively indicated that angio sarcoma may be caused as a result of exposure to Vinyl Chloride containing products? RESPONSE; Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 31; Do you admit that any physician, nurse or other health care provider employed by your company, operating within the scope of that employment from the years 1948 through present has ever affirmatively indicated that astrocytoma may be caused as a result of exposure to Vinyl Chloride containing products? - 26 - R&S163130 RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Subject to its objections, Request for Admission No. 31 is denied. REQUEST FOR ADMISSION NO. 32: Do you admit that any physician, nurse or other health care provider employed by your company, operating within the scope of that employment from the years 1948 through present has ever affirmatively indicated that glioblastoma may be caused as a result of expousre to Vinyl Chloride containing products. RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 41: Do you admit that any expert employed by your company, operating within the scope of that employment from the years 1948 through present has ever affirmatively indicated that acute myelogenous leukemia may be caused as a result of exposure to Vinyl Chloride? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the - 27 - present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 42: Do you admit that any expert employed by your company, operating within the scope of that employment from the years 1948 through present has ever affirmatively indicated that leukemia may be caused as a result of exposure to Vinyl Chloride? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 43: Do you admit that any expert employed by your company, operating within the scope of that employment from the years 1948 through present has ever affirmatively indicated that lymphoma may be caused as a result of exposure to Vinyl Chloride? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being - 28 - R&S163132 irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION HO. 44i Do you admit that any expert employed by your company, operating within the scope of that employment from the years 1948 through present has ever affirmatively indicated that disorders of the hemopoietic system may be caused as a result of exposure to Vinyl Chloride? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 45: Do you admit that any expert employed by your company, operating within the scope of that employment from the years 1948 through present has ever affirmatively indicated that disorders of the lymphatic system may be caused as a result of exposure to Vinyl Chloride? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being - 29 - R&S163133 irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION WO. 46: Do you admit that any expert employed by your company, operating within the scope of that employment from the years 1948 through present has ever affirmatively indicated that brain cancer may be caused as a result of exposure to Vinyl Chloride? RESPONSE; Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 47; Do you admit that any expert employed by your company, operating within the scope of that employment from the years 1948 through present has ever affirmatively indicated that angio sarcoma may be caused as a result of exposure to Vinyl Chloride? RESPONSE; Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. - 30 - R&S163134 REQUEST FOR ADMISSION NO. 48: Do you admit that any expert employed by your company, operating within the scope of that employment from the years 1948 through present has ever affirmatively indicated that astrocytoma may be caused as a result of exposure to Vinyl Chloride? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Subject to its objections, Request for Admission No. 48 is denied. REQUEST FOR ADMISSION NO. 49: Do you admit that any expert employed by your company, operating within the scope of that employment from the years 1948 through present has ever affirmatively indicated that glioblastoma may be caused as a result of exposure to Vinyl Chloride? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 50: Do you admit that any expert employed by your company, operating within the scope of that employment from the years 1948 through present has ever affirmatively indicated that acute myelogenous leukemia may be caused as a result of exposure to Vinyl Chloride containing products? - 31 - R&S163135 RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 51: Do you admit that any expert employed by your company, operating within the scope of that employment from the years 1948 through present has ever affirmatively indicated that leukemia may be caused as a result of exposure to Vinyl Chloride containing products? RESPONSE; Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 52: Do you admit that any expert employed by your company, operating within the scope of that employment from the years 1948 through present has ever affirmatively indicated that lymphoma may be caused as a result of exposure to Vinyl Chloride containing products? - 32 - R&S163136 RESPONSE; Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. S3; Do you admit that any expert employed by your company, operating within the scope of that employment from the years 1948 through present has ever affirmatively indicated that disorders of the hemopoietic system may be caused as a result of exposure to Vinyl Chloride containing products? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 54: Do you admit that any expert empoyed by your company, operating within the scope of that employment from the years 1948 through present has ever affirmatively indicated that disorders of the lymphatic system may be caused as a result of exposure to Vinyl Chloride containing products? - 33 - R&S163137 RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 55: Do you admit that any expert employed by your company, operating within the scope of that employment from the years 1948 through present has ever affirmatively indicated that brain cancer may be caused as a result of exposure to Vinyl Chloride containing products? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 56: Do you admit that any expert employed by your company, operating within the scope of that employment from the years 1948 through present has ever affirmatively indicated that angio sarcoma may be caused as a result of exposure to Vinyl Chloride containing products? - 34 - R&S163138 RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 57: Do you admit that any expert employed by your company, operating within the scope of that employment from the years 1948 through present has ever affirmatively indicated that astrocytoma may be caused as a result of exposure to Vinyl Chloride containing products? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Subject to its objections, Request for Admission No. 57 is denied. REQUEST FOR ADMISSION NO. 57: (sic) Do you admit that any expert employed by your company, operating within the scope of that employment from the years 1948 through present has ever affirmatively indicated that glioblastoma may be caused as a result of exposure to Vinyl Chloride containing products? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the - 35 - R&S163139 present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 80: Do you admit that any expert in occupational health employed by your company operating within the scope of that employment from the year 1948 to present has ever affirmatively indicated that acute myelogenous leukemia may be caused as a result of exposure to Vinyl Chloride? RESPONSE; Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 81: Do you admit that any expert in occupational health employed by your company operating within the scope of that employment from the year 1948 to present has ever affimatively indicated that lymphoma may be caused as a result of exposure to Vinyl Chloride? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that - 36 - R&S163140 time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 82; Do you admit that any expert in occupational health employed by your company operating within the scope of that employment from the year 1948 to present has ever affirmatively indicated that lymphoma may be caused as a result of exposure to Vinyl Chloride? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 83: Do you admit that any expert in occupational health employed by your company operating within the scope of that employment from the year 1948 to present has ever affirmatively indicated that disorders of the hemopoietic system may be caused as a result of exposure to Vinyl Chloride? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being - 37 - R&S163141 irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 84; Do you admit that any expert in occupational health employed by your company operating within the scope of that employment from the year 1948 to present has ever affirmatively indicated that disorders of the lymphatic system may be caused as a result of exposure to Vinyl Chloride? RESPONSE; Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 85; Do you admit that any expert in occupational health employed by your company operating within the scope of that employment from the year 1948 to present has ever affirmatively indicated that brain cancer may be caused as a result of exposure to Vinyl Chloride? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being - 38 - R&S163142 irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 86: Do you admit that any expert in occupational health employed by your company operating within the scope of that employment from the year 1948 to present has ever affirmatively indicated that angio sarcoma may be caused as a result of exposure to Vinyl Chloride? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 87: Do you admit that any expert in occupational health employed by your company operating within the scope of that employment from the year 1948 to present has ever affirmatively indicated that astrocytoma may be caused as a result of exposure to Vinyl Chloride? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Subject to its objections, Request for Admission No. 87 is denied. - 39 - R&S163143 REQUEST FOR ADMISSION NO. 88: Do you admit that any expert in occupational health employed by your company operating within the scope of that employment from the year 1948 to present has ever affirmatively indicated that glioblastoma may be caused as a result of exposure to Vinyl Chloride? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 89: Do you admit that any expert in industrial hygiene employed by your company operating within the scope of that employment from the year 1948 to present has ever affirmatively indicated that acute myelogenous leukemia may be caused as a result of exposure to Vinyl Chloride? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. R&S163144 - 40 - tt REQUEST FOR ADMISSION NO. 90; Do you admit that any expert in industrial hygiene employed by your company operating within the scope of that employment from the year 1948 to present has ever affirmatively indicated that leukemia may be caused as a result of exposure to Vinyl Chloride? RESPONSE; Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 91; Do you admit that any expert in industrial hygiene employed by your company operating within the scope of that employment from the year 1948 to present has ever affirmatively indicated that leukemia may be caused as a result of exposure to Vinyl Chloride? RESPONSE; Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. - 41 - R&S163145 REQUEST FOR ADMISSION NO. 92; Do you admit that any expert in industrial hygiene employed by your company operating within the scope of that employment from the year 1948 to present has ever affirmatively indicated that disorders of the hemopoietic system may be caused as a result of exposure to Vinyl Chloride? RESPONSE; Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 93: Do you admit that any expert in industrial hygiene employed by your company operating within the scope of that employment from the year 1948 to present has ever affirmatively indicated that disorders of the lymphatic system may be caused as a result of exposure to Vinyl Chloride? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. - 42 - R&S163146 REQUEST FOR ADMISSION NO. 94; Do you admit that any expert in industrial hygiene employed by your company operating within the scope of that employment from the year 1948 to present has ever affirmatively indicated that brain cancer may be caused as a result of exposure to Vinyl Chloride? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 95: Do you admit that any expert in industrial hygiene employed by your company operating within the scope of that employment from the year 1948 to present has ever affirmatively indicated that angio sarcoma may be caused as a result of exposure to Vinyl Chloride? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. - 43 - R&S163147 REQUEST FOR ADMISSION HO. 96; Do you admit that any expert in industrial employed by your company operating within the scope of that employment from the year 1948 to present has ever affirmatively indicated that astrocytoma may be caused as a result of exposure to Vinyl Chloride? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Subject to its objections, Request for Admission No. 96 is denied. REQUEST FOR ADMISSION NO. 97: Do you admit that any expert in industrial hygiene employed by your company operating within the scope of that employment from the year 1948 to present has ever affirmatively indicated that glioblastoma may be caused as a result of exposure to Vinyl Chloride? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 98: Do you admit that any expert in safety employed by your company operating within the scope of that employment from the year 1948 to present has ever - 44 - affirmatively indicated that acute myelogenous leukemia may be caused as a result of exposure to Vinyl Chloride? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION WO. 99: Do you admit that any expert in safety employed by your company operating within the scope of that employment from the year 1948 to present has ever affirmatively indicated that leukemia may be caused as a result of exposure to Vinyl Chloride? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 100: Do you admit that any expert in safety employed by your company operating within the scope of that employment from the year 1948 to present has ever - 45 - * affirmatively indicated that lymphoma may be caused as a result of exposure to Vinyl Chloride? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 101: Do you admit that any expert in safety employed by your company operating within the scope of that employment from the year 1948 to present has ever affirmatively indicated that disorders of the hemopoietic system may be caused as a result of exposure to Vinyl Chloride? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 102: Do you admit that any expert in safety employed by your company operating within the scope of that employment from the year 1948 to present has ever - 46 - 'S^9iSVH affirmatively indicated that disorders of the lymphatic system may be caused as a result of exposure to Vinyl Chloride? RESPONSE; Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 103; Do you admit that any expert in safety employed by your company operating within the scope of that employment from the year 1948 to present has ever affirmatively indicated that brain cancer may be caused as a result of exposure to Vinyl Chloride? RESPONSE; Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 104; Do you admit that any expert in safety employed by your company operating within the scope of that employment from the year 1948 to present has ever - 47 - 1SJ.E9ISSH affirmatively indicated that angio sarcoma may be caused as a result of exposure to Vinyl Chloride? RESPONSE; Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 105; Do you admit that any expert in safety employed by your company operating within the scope of that employment from the year 1948 to present has ever affirmatively indicated that astrocytoma may be caused as a result of exposure to Vinyl Chloride? RESPONSE; Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Subject to its objections, Request for Admission No. 105 is denied. REQUEST FOR ADMISSION NO. 106; Do you admit that any expert in safety employed by your company operating within the scope of that employment from the year 1948 to present has ever affirmatively indicated that glioblastoma may be caused as a result of exposure to Vinyl Chloride? - 48 - R&S163152 RESPONSE; Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 107; Do you admit that any expert in occupational health employed by your company operating within the scope of that employment from the year 1948 to present has ever affirmatively indicated that acute myelogenous leukemia may be caused as a result of exposure to Vinyl Chloride containing products? RESPONSE; Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 108; Do you admit that any expert in occupational health employed by your company operating within the scope of that employment from the year 1948 to present has ever affirmatively indicated that leukemia may be caused as a result of exposure to Vinyl Chloride containing products? - 49 - R&S163153 RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 109: Do you adit that any expert in occupational health employed by your company operating within the scope of that employment from the year 1948 to present has ever affirmatively indicated that lymphoma may be caused as a result of exposure to Vinyl Chloride containing products? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 110: Do you admit that any expert in occupational health employed by your company operating within the scope of that employment from the year 1948 to present has ever affirmatively indicated that disorders of the hemopoietic system may be caused as a result of exposure to Vinyl Chloride containing products? - 50 - R&S163154 RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. Ill: Do you admit that any expert in occupational health employed by your company operating within the scope of that employment from the year 1948 to present has ever affirmatively indicated that disorders of the lymphatic system may be caused as a result of exposure to Vinyl Chloride containing products? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 112: Do you admit that any expert in occupational health employed by your company operating within the scope of that employment from the year 1948 to present has ever affirmatively indicated that brain cancer may be caused as a result of exposure to Vinyl Chloride containing products? - 51 - RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 113; Do you admit that any expert in occupational health employed by your company operating within the scope of that employment from the year 1948 to present has ever affirmatively indicated that angio sarcoma may be caused as a result of exposure to Vinyl Chloride containing products? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 114; Do you admit that any expert in occupational health employed by your company operating within the scope of that employment from the year 1948 to present has ever affirmatively indicated that astrocytoma may be caused as a result of exposure to Vinyl Chloride containing products? - 52 - R&S163156 RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Subject to its objections, Request for Admission No. 114 is denied. REQUEST FOR ADMISSION NO. 115: Do you admit that any expert in occupational health employed by your company operating within the scope of that employment from the year 1948 to present has ever affirmatively indicated that glioblastoma may be caused as a result of exposure to Vinyl Chloride containing products? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 116: Do you admit that any expert in industrial hygiene employed by your company operating within the scope of that employment from the year 1948 to present has ever affirmatively indicated that acute myelogenous leukemia may be caused as a result of exposure to Vinyl Chloride containing products? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the - 53 - ~*s present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 117; Do you admit that any expert in industrial hygiene employed by your company operating within the scope of that employment from the year 1948 to present has ever affirmatively indicated that leukemia may be caused as a result of exposure to Vinyl Chloride containing products? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 118: Do you admit that any expert in industrial hygiene employed by your company operating within the scope of that employment from the year 1948 to present has ever affirmatively indicated that lymphoma may be caused as a result of exposure to Vinyl Chloride containing products? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that - 54 - R&S163158 time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 119; Do you admit that any expert in industrial hygiene employed by your company operating within the scope of that employment from the year 1948 to present has ever affirmatively indicated that disorders of the hemopoietic system may be caused as a result of exposure to Vinyl Chloride containing products? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 120: Do you admit that any expert in industrial hygiene employed by your company operating within the scope of that employment from the year 1948 to present has ever affirmatively indicated that disorders of the lymphatic system may be caused as a result of exposure to Vinyl Chloride containing products? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being - 55 - R&S163159 irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST POR ADMISSION NO. 121: Do you admit that any expert in industrial hygiene employed by your company operating within the scope of that employment from the year 1948 to present has ever affirmatively indicated that brain cancer may be caused as a result of exposure to Vinyl Chloride containing products? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST POR ADMISSION NO. 122: Do you admit that any expert in industrial hygiene employed by your company operating within the scope of that employment from the year 1948 to present has ever affirmatively indicated that angio sarcoma may be caused as a result of exposure to Vinyl Chloride containing products? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being - 56 - irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 123: Do you admit that any expert in industrial hygiene employed by your company operating within the scope of that employment from the year 1948 to present has ever affirmatively indicated that astrocytoma may be caused as a result of exposure to Vinyl Chloride containing products? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Subject to its objections, Request for Admission No. 123 is denied. REQUEST FOR ADMISSION NO. 124: Do you admit that any expert in industrial hygiene employed by your company operating within the scope of that employment from the year 1948 to present has ever affirmatively indicated that glioblastoma may be caused as a result of exposure to Vinyl Chloride containing products? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. - 57 - R&S163161 REQUEST FOR ADMISSION NO. 125; Do you admit that any expert in safety employed by your company operating within the scope of that employment from the year 1948 to present has ever affirmatively indicated that acute myelogenous leukemia may be caused as a result of exposure to Vinyl Chloride containing products? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 126: Do you admit that any expert in safety employed by your company operating within the scope of that employment from the year 1948 to present has ever affirmatively indicated that acute myelogenous leukemia may be caused as a result of exposure to Vinyl Chloride containing products? RESPONSE; Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. - 58 - R&SI 63162 REQUEST FOR ADMISSION NO. 127: Do you admit that any expert in safety employed by your company operating within the scope of that employment from the year 1948 to present has ever affirmatively indicated that leukemia may be caused as a result of exposure to Vinyl Chloride containing products? RESPONSE; Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 128; Do you admit that any expert in safety employed by your company operating within the scope of that employment from the year 1948 to present has ever affirmatively indicated that lymphoma may be caused as a result of exposure to Vinyl Chloride containing products? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. - 59 - R&S163163 <* REQUEST FOR ADMISSION NO. 129; Do you admit that any expert in safety employed by your company operating within the scope of that employment from the year 1948 to present has ever affirmatively indicated that disorders of the hemopoietic system may be caused as a result of exposure to Vinyl Chloride containing products? RESPONSE; Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 130; Do you admit that any expert in safety employed by your company operating within the scope of that employment from the year 1948 to present has ever affirmatively indicated that disorders of the lymphatic system may be caused as a result of exposure to Vinyl Chloride containing products? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. - 60 - R&S163164 REQUEST FOR ADMISSION NO. 131: Do you admit that any expert in safety employed by your company operating within the scope of that employment from the year 1948 to present has ever affirmatively indicated that brain cancer may be caused as a result of exposure to Vinyl Chloride containing products? RESPONSE: Defendant reiterates its general objections- Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 132: Do you admit that any expert in safety employed by your company operating within the scope of that employment from the year 1948 to present has ever affirmatively indicated that angio sarcoma may be caused as a result of exposure to Vinyl Chloride containing products? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. - 61 - R&S163165 REQUEST FOR ADMISSION NO. 133: Do you admit that any expert in safety employed by your company operating within the scope of that employment from the year 1948 to present has ever affirmatively indicated that astrocytoma may be caused as a result of exposure to Vinyl Chloride containing products? RESPONSE; Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Subject to its objections, Request for Admission No. 133 is denied. REQUEST FOR ADMISSION NO. 134; Do you admit that any expert in safety employed by your company operating within the scope of that employment from the year 1948 to present has ever affirmatively indicated that glioblastoma may be caused as a result of exposure to Vinyl Chloride containing products? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission for the time frame 1948 through 1969 and 1984 through the present on the grounds that Plaintiff was not an employee of this Defendant at that time. Defendant objects to this Request for Admission in its entirety as being irrelevant to the extent that the Request seeks an admission from this Defendant with regard to a condition from which this Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 135: Do you admit that your company possesses documents which indicate or set forth the opinion that exposure to Vinyl Chloride may cause acute myelogenous leukemia? - 62 * R&S163166 RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission as being irrelevant because it seeks this Defendant to admit facts regarding a condition from which Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 136: Do you admit that your company possesses documents which indicate or set forth the opinion that exposure to Vinyl Chloride may cause leukemia? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission as being irrelevant because it seeks this Defendant to admit facts regarding a condition from which Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 137: Do you admit that your company possesses documents which indicate or set forth the opinion that exposure to Vinyl Chloride may cause lymphoma? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission as being irrelevant because it seeks this Defendant to admit facts regarding a condition from which Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 138: Do you admit that your company possesses documents which indicate or set forth the opinion that exposure to Vinyl Chloride may cause disorders of the hemopoietic system? - 63 - R&S163167 RESPONSE; Defendant reiterates its general objections. Defendant further objects to this Request for Admission as being irrelevant because it seeks this Defendant to admit facts regarding a condition from which Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 139: Do you admit that your company possesses documents which indicate or set forth the opinion that exposure to Vinyl Chloride may cause disorders of the lymphatic system? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission as being irrelevant because it seeks this Defendant to admit facts regarding a condition from which Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 140: Do you admit that your company possesses documents which indicate or set forth the opinion that exposure to Vinyl Chloride may cause brain cancer? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission as being irrelevant because it seeks this Defendant to admit facts regarding a condition from which Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 141: Do you admit that your company possesses documents which indicate or set forth the opinion that exposure to Vinyl Chloride may cause angio sarcoma? - 64 - R&S163168 RESPONSE; Defendant reiterates its general objections. Defendant further objects to this Request for Admission as being irrelevant because it seeks this Defendant to admit facts regarding a condition from which Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 142: Do you admit that your company possesses documents which indicate or set forth the opinion that exposure to Vinyl Chloride may cause astrocytoma? RESPONSE: Denied. REQUEST FOR ADMISSION NO. 143; Do you admit that your company possesses documents which indicate or set forth the opinion that exposure to Vinyl Chloride may cause glioblastoma? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission as being irrelevant to the extent that it seeks this Defendant to admit facts regarding a condition from which Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 144; Do you admit that your company possesses documents which indicate or set forth the opinion that exposure to Vinyl Chloride containing products may cause acute myelogenous leukemia? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission as being irrelevant to the extent that it seeks this Defendant to admit facts regarding a condition from which Plaintiff allegedly does not suffer. - 65 - REQUEST FOR ADMISSION NO. 145; Do you admit that your company possesses documents which indicate or set forth the opinion that exposure to Vinyl Chloride containing products may cause leukemia? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission as being irrelevant to the extent that it seeks this Defendant to admit facts regarding a condition from which Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 146: Do you admit that your company possesses documents which indicate or set forth the opinion that exposure to Vinyl Chloride containing products may cause lymphoma? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission as being irrelevant to the extent that it seeks this Defendant to admit facts regarding a condition from which Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 147: Do you admit that your company possesses documents which indicate or set forth the opinion that exposure to Vinyl Chloride containing products may cause disorders of the hemopoietic system? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission as being irrelevant to the extent that it seeks this Defendant to admit facts regarding a condition from which Plaintiff allegedly does not suffer. - 66 - R&S163170 REQUEST FOR ADMISSION NO. 148: Do you admit that your company possesses documents which indicate or set forth the opinion that exposure to Vinyl Chloride containing products may cause disorders of the lymphatic system? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission as being irrelevant to the extent that it seeks this Defendant to admit facts regarding a condition from which Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 149: Do you admit that your company possesses documents which indicate or set forth the opinion that exposure to Vinyl Chloride containing products may cause brain cancer? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission as being irrelevant to the extent that it seeks this Defendant to admit facts regarding a condition from which Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 150: Do you admit that your company possesses documents which indicate or set forth the opinion that exposure to Vinyl Chloride containing products may cause angio sarcoma? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission as being irrelevant to the extent that it seeks this Defendant to admit facts regarding a condition from which Plaintiff allegedly does not suffer. - 67 - R&St 63171 REQUEST FOR ADMISSION NO. 151: Do you admit that your company possesses documents which indicate or set forth the opinion that exposure to Vinyl Chloride containing products may cause astrocytoma? RESPONSE: Denied. REQUEST FOR ADMISSION NO. 152: Do you admit that your company possesses documents which indicate or set forth the opinion that exposure to Vinyl Chloride containing products may cause glioblastoma? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission as being irrelevant to the extent that it seeks this Defendant to admit facts regarding a condition from which Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 153: Do you admit that your company has never conducted, caused to be conducted, or participated in any type of toxicological testing of Vinyl Chloride? RESPONSE: Denied. REQUEST FOR ADMISSION NO. 154: Do you admit that your company has never conducted, caused to be conducted, or participated in any type of toxicological testing of Vinyl Chloride containing products? RESPONSE: Denied. - 68 - R&S163172 REQUEST FOR ADMISSION NO. 155: Do you admit that your company has never conducted, caused to be conducted, or participated in any type of epidemiological studies of emloyees who may have been exposed to Vinyl Chloride? RESPONSE; Denied. REQUEST FOR ADMISSION NO. 156: Do you admit that your company has never conducted, caused to be conducted, or participated in any type of epidemiological studies of emloyees who may have been exposed to Vinyl Chloride containing products? RESPONSE: Denied. REQUEST FOR ADMISSION NO. 157; Do you admit that your company has never conducted literature searches associated with the safety and health hazards of Vinyl Chloride? RESPONSE: Denied. REQUEST FOR ADMISSION NO. 158; Do you admit that production of Vinyl Chloride is an ultra hazardous activity? RESPONSE; Denied. REQUEST FOR ADMISSION NO. 159; Do you admit that handling Vinyl Chloride containing hydrocarbons is an ultra hazardous activity? - 69 - R&St 63173 RESPONSE: Denied. REQUEST FOR ADMISSION NO. 160: Do you admit that Vinyl Chloride is a hazardous substance? RESPONSE: Defendant objects to Request for Admission No. 160 on the grounds that it is vague and ambiguous. Subject to its objections, Defendant denies this Request for Admission. REQUEST FOR ADMISSION NO. 161: Do you admit that your company has never conducted literature searches associated with the safety and health hazards of Vinyl Chloride containing products? RESPONSE: Denied. REQUEST FOR ADMISSION NO. 162: Do you admit that your company did have a substandard operating procedure relative to the safe use or handling of Vinyl Chloride during the time period: a. 1948 b. 1949 c. 1950 d. 1951 e. 1952 f. 1953 g. 1954 h. 1955 i. 1956 j. 1957 k. 1958 l. 1959 m. 1960 n. 1961 o. 1962 p. 1963 q. 1964 r. 1965 - 70 - R&S163174 s. t. u. v. w. X. yz. aa. bb. cc. dd. ee. ff. gghh. ii. jjkk. 11. mm. nn. oo. pp. qq. rr. ss. tt. 1966 1967 1968 1969 1970 1971 1972 1973 1974 1975 1976 1977 1978 1979 1980 1981 1982 1983 1984 1985 1986 1987 1988 1989 1990 1991 1992 1993 RESPONSE: Defendant reiterates its general objections. Defendant further objects to Request for Admission No. 162 as being irrelevant to the extent that it seeks this Defendant to admit facts for the time frame 1948 through 1968 and 1984 through the present because Plaintiff was not employed by this Defendant at that time. Subject to these objections, Defendant denies this Request for Admission. REQUEST FOR ADMISSION NO. 163: Do you admit that your company did have a substandard operating procedure relative to the safe use or handling of Vinyl Chloride containing products during the time period: a. 1948 b. 1949 R&S163175 - 71 - c. 1950 d. 1951 e. 1952 f. 1953 e- 1954 h. 1955 i. 1956 j- 1957 k. 1958 1. 1959 m. 1960 n. 1961 0. 1962 P- 1963 q- 1964 r. 1965 s. 1966 t. 1967 u. 1968 V. 1969 w. 1970 X. 1971 y* 1972 z. 1973 aa. 1974 bb. 1975 cc. 1976 dd. 1977 ee. 1978 ff. 1979 eg- 1980 hh. 1981 ii. 1982 jj- 1983 kk. 1984 11. 1985 mm. 1986 nn. 1987 oo. 1988 pp. 1989 qq. 1990 rr. 1991 ss. 1992 tt. 1993 RESPONSE: Defendant reiterates its general objections. Defendant further objects to Request for Admission No. 163 as being irrelevant to the extent that it seeks this - 72 - R&S163176 Defendant to admit faets for the time frame 1948 through 1968 and 1984 through the present because Plaintiff was not employed by this Defendant at that time. Subject to these objections, Defendant denies this Request for Admission. REQUEST FOR ADMISSION NO. 164: Do you admit that your company did have a substandard operating procedure relative to the safe use or handling of Vinyl Chloride containing process streams during the time period: a. 1948 b. 1949 c. 1950 d. 1951 e. 1952 f. 1953 g- 1954 h. 1955 i. 1956 j* 1957 k. 1958 1. 1959 m. 1960 n. 1961 o. 1962 P- 1963 q- 1964 r. 1965 s. 1966 t. 1967 u. 1968 V. 1969 w. 1970 X. 1971 y* 1972 2. 1973 aa. 1974 bb. 1975 cc. 1976 dd. 1977 ee. 1978 ff. 1979 gg- 1980 hh. 1981 ii. 1982 jj- 1983 - 73 - R&S163177 kk. 11. mm. nn. oo. PPqq. rr. ss. tt. 1984 1985 1986 1987 1988 1989 1990 1991 1992 1993 RESPONSE: Defendant reiterates its general objections. Defendant further objects to Request for Admission No. 164 as being irrelevant to the extent that it seeks this Defendant to admit facts for the time frame 1948 through 1968 and 1984 through the present because Plaintiff was not employed by this Defendant at that time. Subject to these objections, Defendant denies this Request for Admission. REQUEST POR ADMISSION NO. 165: Do you admit that your company did not conduct and industrial hygiene exposure monitoring surveys relative to the assessment of employee exposure to Vinyl Chloride during the time period: a. 1948 b. 1949 c. 1950 d. 1951 e. 1952 f. 1953 g- 1954 h. 1955 i. 1956 j- 1957 k. 1958 1. 1959 m. 1960 n. 1961 0. 1962 P* 1963 q- 1964 r. 1965 s. 1966 t. 1967 R&S163178 - 74 - u. 1968 V. 1969 w. 1970 X. 1971 y- 1972 z. 1973 aa. 1974 bb. 1975 cc. 1976 dd. 1977 ee. 1978 ff. 1979 gg- 1980 hh. 1981 ii. 1982 jj- 1983 kk. 1984 11. 1985 mm. 1986 nn. 1987 00. 1988 pp. 1989 qq. 1990 rr. 1991 ss. 1992 tt. 1993 RESPONSE; Defendant reiterates its general objections. Defendant further objects to Request for Admission No. 165 as being irrelevant to the extent that it seeks this Defendant to admit facts for the time frame 1948 through 1968 and 1984 through the present because Plaintiff was not employed by this Defendant at that time. Subject to these objections, Defendant denies this Request for Admission. REQUEST FOR ADMISSION NO. 166: Do you admit that your company did not conduct and industrial hygiene exposure monitoring surveys relative to the assessment of employee exposure to Vinyl Chloride containing products during the time period; a. 1948 b. 1949 c. 1950 d. 1951 - 75 - R&S163179 e. f. gh. i. jk. 1. m. n. o. Pqr. s. t. u. V. w. X. yz. aa. bb. cc. dd. ee. ff. gghh. ii. jjkk. 11. mm. nn. oo. pp. qq. rr. ss. tt. 1952 1953 1954 1955 1956 1957 1958 1959 1960 1961 1962 1963 1964 1965 1966 1967 1968 1969 1970 1971 1972 1973 1974 1975 1976 1977 1978 1979 1980 1981 1982 1983 1984 1985 1986 1987 1988 1989 1990 1991 1992 1993 RESPONSE: Defendant reiterates its general objections. Defendant further objects to Request for Admission No. 166 as being irrelevant to the extent that it seeks this Defendant to admit facts for the time frame 1948 through 1968 and 1984 through the R&S163180 - 76 - present because Plaintiff was not employed by this Defendant at that time. Subject to these objections, Defendant denies this Request for Admission. REQUEST FOR ADMISSION NO. 167: Do you admit that your company did not conduct any industrial hygiene exposure monitoring surveys relative to the assessment of employee exposure to Vinyl Chloride containing process during the time period: a. 1948 b. 1949 c. 1950 d. 1951 e. 1952 f. 1953 g- 1954 h. 1955 i. 1956 j- 1957 k. 1958 1. 1959 m. 1960 n. 1961 o. 1962 P- 1963 q- 1964 r. 1965 s. 1966 t. 1967 u. 1968 V. 1969 w. 1970 X. 1971 y- 1972 z. 1973 aa. 1974 bb. 1975 cc. 1976 dd. 1977 ee. 1978 ff. 1979 gg- 1980 hh. 1981 ii. 1982 jj- 1983 kk. 1984 11. 1985 - 77 - R&S163181 mm. 1986 nn. 1987 00. 1988 pp. 1989 qq. 1990 rr. 1991 ss. 1992 tt. 1993 RESPONSE; Defendant reiterates its general objections. Defendant further objects to Request for Admission No. 167 as being irrelevant to the extent that it seeks this Defendant to admit facts for the time frame 1948 through 1968 and 1984 through the present because Plaintiff was not employed by this Defendant at that time. Subject to these objections, Defendant denies this Request for Admission. REQUEST FOR ADMISSION NO. 168: Do you admit that operators at defendant's Vinyl Chloride facility were included in a medical surveillance program for personnel exposed to Vinyl Chloride during the time period: a. 1948 b. 1949 c. 1950 d. 1951 e. 1952 f. 1953 g* 1954 h. 1955 i. 1956 j- 1957 k. 1958 1. 1959 m. 1960 n. 1961 0. 1962 P- 1963 q- 1964 r. 1965 s. 1966 t. 1967 u. 1968 V. 1969 - 78 - R&S163182 w. X. y* z. aa. bb. cc. dd. ee. ff. gghh. ii. jjkk. 11. mm. nn. oo. pp. qq. rr. ss. tt. 1970 1971 1972 1973 1974 1975 1976 1977 1978 1979 1980 1981 1982 1983 1984 1985 1986 1987 1988 1989 1990 1991 1992 1993 RESPONSE: Defendant reiterates its general objections. Defendant further objects to Request for Admission No. 168 as being irrelevant to the extent that it seeks this Defendant to admit facts for the time frame 1948 through 1968 and 1984 through the present because Plaintiff was not employed by this Defendant at that time. Subject to these objections, Defendant denies this Request for Admission. REQUEST FOR ADMISSION NO. 169: Do you admit that operators at defendants Vinyl Chloride facility were included in a medical surveillance program for personnel exposed to Vinyl Chloride containing products during the time period: a. 1948 b. 1949 c. 1950 d. 1951 e. 1952 f. 1953 e8L91S'?H - 79 - g* 1954 h. 1955 i. 1956 j. 1957 k. 1958 1. 1959 m. 1960 n. 1961 o. 1962 P. 1963 q> 1964 r. 1965 s. 1966 t. 1967 u. 1968 V. 1969 w. 1970 X. 1971 y. 1972 z. 1973 aa. 1974 bb. 1975 cc. 1976 dd. 1977 ee. 1978 ff. 1979 gg- 1980 hh. 1981 ii. 1982 jj- 1983 kk. 1984 11. 1985 mm. 1986 nn. 1987 oo. 1988 pp. 1989 qq. 1990 rr. 1991 ss. 1992 tt. 1993 RESPONSE: Defendant reiterates its general objections. Defendant further objects to Request for Admission No. 169 as being irrelevant to the extent that it seeks this Defendant to admit facts for the time frame 1948 through 1968 and 1984 through the - 80 - R&S163184 present because Plaintiff was not employed by this Defendant at that time. Subject to these objections, Defendant denies this Request for Admission. REQUEST FOR ADMISSION NO. 170: Do you admit that operators at defendants Vinyl Chloride facility were included in a medical surveillance program for personnel exposed to Vinyl Chloride containing process streams during the time period: a. 1948 b. 1949 c. 1950 d. 1951 e. 1952 f. 1953 g* 1954 h. 1955 i. 1956 j- 1957 k. 1958 1. 1959 m. 1960 n. 1961 o. 1962 P- 1963 q- 1964 r. 1965 s. 1966 t. 1967 u. 1968 V. 1969 w. 1970 X. 1971 y- 1972 z. 1973 aa. 1974 bb. 1975 cc. 1976 dd. 1977 ee. 1978 ff. 1979 gg* 1980 hh. 1981 ii. 1982 jj- 1983 kk. 1984 11. 1985 mm. nn. oo. pp. qq. rr. ss. tt. 1986 1987 1988 1989 1990 1991 1992 1993 RESPONSE: Defendant reiterates its general objections. Defendant further objects to Request for Admission No. 170 as being irrelevant to the extent that it seeks this Defendant to admit facts for the time frame 1948 through 1968 and 1984 through the present because Plaintiff was not employed by this Defendant at that time. Subject to these objections, Defendant denies this Request for Admission. REQUEST FOR ADMISSION NO. 171; Do you admit that the following areas are or have been designated as "regulated areas" pursuant to 29 CFR 1910.1017(s)(e) at any period of time from 1963 through 1993: a) Areas within Vinyl Chloride facility. b) Your entire Vinyl Chloride facility. c) Facilities in the United States other than your Vinyl Chloride. RESPONSE: Defendant reiterates its general objections. Subject to those objections, Defendant admits Request for Admission No. 171(a). Defendant denies Request for Admission No. 171(b). Defendant objects to Request for Admission No. 171(c) as being ambiguous and irrelevant. R&S163186 - 82 - REQUEST FOR ADMISSION NO. 172; Do you admit that Defendant failed to comply with O.S.H.A. regulations pertaining to threshold limit values for Vinyl Chloride at your Vinyl Chloride facility for any period of time between 1970 and present? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission as being irrelevant to the extent that it seeks this Defendant to admit facts for the time frame 1984 through the present because Plaintiff was not employed by this Defendant at that time. Defendant states that it has had an insufficient amount of time to review all of these documents and meet with all of its personnel to gather information sufficient enough to respond to Request for Admission No. 172. Based on the information that it has currently compiled, Defendant denies Request for Admission No. 172. REQUEST FOR ADMISSION NO. 173: Do you admit that Defendant failed to comply with O.S.H.A. regulations pertaining to threshold limit values for Vinyl Chloride containing products at your Vinyl Chloride facility for any period of time between 1970 and present? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission as being irrelevant to the extent that it seeks this Defendant to admit facts for the time frame 1984 through the present because Plaintiff was not employed by this Defendant at that time. Defendant states that it has had an insufficient amount of time to review all of these documents and meet with all of its personnel to gather information sufficient enough to respond to Request for Admission - 83 - R&S163187 No. 173. Based on the information that it has currently compiled, Defendant denies Request for Admission No. 173. REQUEST FOR ADMISSION NO, 174; Do you admit that Defendant failed to comply with O.S.H.A. regulations pertaining to work place environmental an/or exposure monitoring for Vinyl Chloride at your Vinyl Chloride facility for any period of time between 1970 and present? RESPONSE; Defendant reiterates its general objections. Defendant further objects to this Request for Admission as being irrelevant to the extent that it seeks this Defendant to admit facts for the time frame 1984 through the present because Plaintiff was not employed by this Defendant at that time. Defendant states that it has had an insufficient amount of time to review all of these documents and meet with all of its personnel to gather information sufficient enough to respond to Request for Admission No. 174. Based on the information that it has currently compiled, Defendant denies Request for Admission No. 174. REQUEST FOR ADMISSION NO. 175; Do you admit that Defendant failed to comply with O.S.H.A. regulations pertaining to work place environmental an/or exposure monitoring for Vinyl Chloride containing products at your Vinyl Chloride facility for any period of time between 1970 and present? RESPONSE; Defendant reiterates its general objections. Defendant further objects to this Request for Admission as being irrelevant to the extent that it seeks this Defendant to admit facts for the time frame 1984 through the present because Plaintiff was not employed by this Defendant at that time. Defendant states that it has had an - 84 - R&S163188 insufficient amount of time to review all of these documents and meet with all of its personnel to gather information sufficient enough to respond to Request for Admission No. 175. Based on the information that it has currently compiled, Defendant denies Request for Admission No. 175. REQUEST FOR ADMISSION NO. 176; Do you admit that Defendant failed to comply with O.S.H.A. regulations pertaining to work place environmental an/or exposure monitoring for Vinyl Chloride containing process streams at your Vinyl Chloride facility for any period of time between 1970 and present? RESPONSE; Defendant reiterates its general objections. Defendant further objects to this Request for Admission as being irrelevant to the extent that it seeks this Defendant to admit facts for the time frame 1984 through the present because Plaintiff was not employed by this Defendant at that time. Defendant states that it has had an insufficient amount of time to review all of these documents and meet with all of its personnel to gather information sufficient enough to respond to Request for Admission No, 176. Based on the information that it has currently compiled, Defendant denies Request for Admission No. 176. REQUEST FOR ADMISSION NO. 177; Do you admit that you are aware of employees or former employees of your company other than plaintiff, who have been diagnosed with; a. acute myelogenous leukemia b. leukemia c. lymphoma d. multiple myeloma e. disorder of the hemopoietic system f. disorder of the lymphatic system g. brain cancer h. astrocytoma - 85 - R&S163189 i. glioblastoma j. angio sarcoma RESPONSE: Defendant reiterates its general objections. Defendant further objects to Request for Admission No. 177(a)-(g) and 177(i)-(j) as being irrelevant to the extent that they seek this Defendant to admit facts regarding conditions from which Plaintiff allegedly does not suffer. Subject to its objections, Defendant states that it has not had enough time to review all of its documentation and meet with all witnesses necessary to respond to Request for Admission No. 177(h). Subject to these objections, Defendant denies Request for Admission No. 177(h). REQUEST FOR ADMISSION NO. 178: Do you admit that you are aware of employees or former employees of your company who have been diagnosed with: a. acute myelogenousleukemia b. leukemia c. lymphoma d. multiple myeloma e. disorder of the hemopoietic system f. disorder of the lymphaticsystem g. brain cancer h. astrocytoma i. glioblastoma j. angio sarcoma RESPONSE: Defendant reiterates its general objections. Defendant further objects to Request for Admission No. 178(a)-(g) and 178(i)-(j) as being irrelevant to the extent that they seek this Defendant to admit facts regarding conditions from which Plaintiff allegedly does not suffer. Subject to its objections, Defendant states that it has not had enough time to review all of its documentation and meet with all witnesses necessary to respond to Request for Admission No. 178(h). Subject to these objections, Defendant denies Request for Admission No. 178(h). - 86 - R&S163190 REQUEST FOR ADMISSION NO. 179: Do you admit that plaintiff was exposed to Vinyl Chloride in the following years: a. 1966 b. 1967 c. 1968 d. 1969 e. 1970 f. 1971 g- 1972 h. 1973 i. 1974 i- 1975 k. 1976 1. 1977 m. 1978 n. 1979 o. 1980 P* 1981 <3- 1982 r. 1983 s. 1984 t. 1985 u. 1986 V. 1987 w. 1988 X. 1989 y* 1990 z. 1991 aa. 1992 bb. 1993 RESPONSE: Defendant reiterates its general objections. Defendant further objects to Request for Admission No. 179(a)-(c) and (s)-(bb) as being irrelevant for the reason the Plaintiff was not employed by this Defendant at that time. Furthermore, Defendant objects on the basis that this request is ambiguous in that the term "exposed" is not defined. Subject to these objections, Defendant denies Request for Admission No. 179(d)-(r). - 87 - R&S163191 REQUEST FOR ADMISSION NO. 180; Do you admit that plaintiff was exposed to Vinyl Chloride containing products in the following years: a. 1966 b. 1967 c. 1968 d. 1969 e. 1970 f. 1971 & 1972 h. 1973 i. 1974 ]* 1975 k. 1976 1. 1977 m. 1978 n. 1979 o. 1980 P* 1981 <3- 1982 r. 1983 s. 1984 t. 1985 u. 1986 V. 1987 w. 1988 X. 1989 y- 1990 z. 1991 aa. 1992 bb. 1993 RESPONSE: Defendant reiterates its general objections* Defendant further objects to Request for Admission No. 180(a)-(c) and (s)-(bb) as being irrelevant for the reason the Plaintiff was not employed by this Defendant at that time. Furthermore, Defendant objects on the basis that this request is ambiguous in that the term "exposed" is not defined. Subject to these objections, Defendant denies Request for Admission No. 180 (d)-(r). - 88 - R&S163192 REQUEST FOR ADMISSION NO. 181; Do you admit that plaintiff was exposed to Vinyl Chloride containing process streams in the following years: a. 1966 b. 1967 c. 1968 d. 1969 e. 1970 f. 1971 g. 1972 h. 1973 i. 1974 j. 1975 k. 1976 l. 1977 m. 1978 n. 1979 o. 1980 p. 1981 q. 1982 r. 1983 s. 1984 RESPONSE: Defendant reiterates its general objections. Defendant further objects to Request for Admission No. 181(a)-(c) and (s) as being irrelevant for the reason the Plaintiff was not employed by this Defendant at that time. Furthermore, Defendant objects on the basis that this request is ambiguous in that the term "exposed" is not defined. Subject to these objections, Defendant denies Request for Admission No. 181(dMr). REQUEST FOR ADMISSION NO. 182: Do you admit that plaintiff was an "authorized person" within the meaning of 29 CFR 1910.1017 et seq during the following years: a. 1966 b. 1967 c. 1968 d. 1969 - 89 - C6t9lSl?B e. 1970 f. 1971 g- 1972 h. 1973 i. 1974 j- 1975 k. 1976 1. 1977 m. 1978 n. 1979 o. 1980 P- 1981 q* 1982 r. 1983 s. 1984 RESPONSE Defendant reiterates its general objections. Defendant further rejects to Request for Admission No. 182(a)-(c) and (s) as being irrelevant for the reason that Plaintiff was not employed by this Defendant during that time frame. Subject to its objections, Defendant admits Request for Admission No. 182(d)~(r). REQUEST FOR ADMISSION NO. 183: Do you admit that the plaintiff was exposed to Vinyl Chloride by direct contact with liquid Vinyl Chloride in the following years: a. 1966 b. 1967 c. 1968 d. 1969 e. 1970 f. 1971 g- 1972 h. 1973 i. 1974 j- 1975 k. 1976 1. 1977 m. 1978 n. 1979 o. 1980 P- 1981 q- 1982 r. 1983 s. 1984 - 90 - R&S163194 RESPONSE: Defendant reiterates its general objections. Defendant further objects to Request for Admission No. 183(a)-(e) and (s) as being irrelevant for the reason that Plaintiff was not employed by this Defendant during that time frame. Subject to its objections, Defendant denies Request for Admission No. 183(d)-(r). REQUEST FOR ADMISSION NO. 184: Do you admit that plaintiff was exposed to Vinyl Chloride containing products by direct contact with liquid Vinyl Chloride containing process streams in the following years: a. 1966 b. 1967 c. 1968 d. 1969 e. 1970 f. 1971 g* 1972 h. 1973 i. 1974 j. 1975 k. 1976 1. 1977 m. 1978 n. 1979 o. 1980 P* 1981 q* 1982 r. 1983 s. 1984 RESPONSE: Defendant reiterates its general objections. Defendant further objects to Request for Admission No. 184(a)-(c) and (s) as being irrelevant for the reason that Plaintiff was not employed by this Defendant during that time frame- Subject to its objections, Defendant denies Request for Admission No. 184(d)-(r). - 91 - R&S163195 REQUEST FOR ADMISSION NO. 185; Do you admit that the plaintiff was exposed to Vinyl Chloride containing process streams by direct contact with liquid Vinyl Chloride containing process streams in the following years: a. 1966 b. 1967 c. 1968 d. 1969 e. 1970 f. 1971 g- 1972 h. 1973 i. 1974 j- 1975 k. 1976 1. 1977 m. 1978 n. 1979 o. 1980 P- 1981 q- 1982 r. 1983 s. 1984 RESPONSE: Defendant reiterates its general objections. Defendant further objects to Request for Admission No. 185(a)-{c) and (s) as being irrelevant for the reason that Plaintiff was not employed by this Defendant during that time frame. Subject to its objections, Defendant denies Request for Admission No, 185(d)-(r). REQUEST FOR ADMISSION NO. 186: Do you admit that at any time between 1970 and present it was a practice of employees at your Vinyl Chloride facility not to report to OSHA all employee exposures to Vinyl Chloride which exceeded OSHA's threshold limit value? RESPONSE: Denied. - 92 - R&SI 63196 REQUEST FOR ADMISSION NO. 187: Do you admit that any time between 1970 and present your company did not report to QSHA all employee exposures to Vinyl Chloride which exceeded OSHA's threshold limit value which occurred at your Vinyl Chloride facility? RESPONSE: Denied. REQUEST FOR ADMISSION NO. 188; Do you admit that at any time between 1970 and present it was the practice of employees at your Vinyl Chloride facility not to report to OSHA all employee exposures to Vinyl Chloride containing products which exceeded OSHA's threshold limit value? RESPONSE: Denied. REQUEST FOR ADMISSION NO. 189: Do you admit that at any time between 1970 and present it was the practice of employees at your Vinyl Chloride facility not to report to OSHA all employee exposures to Vinyl Chloride containing process streams which exceeded OSHA's threshold limit value? RESPONSE: Denied. REQUEST FOR ADMISSION NO. 190: Do you admit that at any time between 1970 and present it was the policy of your company not to report to OSHA all employee exposures to Vinyl Chloride which exceeded OSHA's threshold limit value? - 93 - R&St 63197 RESPONSE; Denied. REQUEST FOR ADMISSION NO. 191: Do you admit that at any time between 1970 and present it was the policy of your company not to report to OSHA all employee exposures to Vinyl Chloride containing products which exceeded OSHA's threshold limit value? RESPONSE; Denied. REQUEST FOR ADMISSION NO. 192: Do you admit that at any time between 1970 and present it was the policy of your company not to report to OSHA all employee exposures to Vinyl Chloride containing process streams which exceeded OSHA's threshold limit value? RESPONSE: Denied. REQUEST FOR ADMISSION NO. 193: Do you admit that plaintiff suffers from astrocytoma? RESPONSE: Defendant has insufficient information to allow it to either admit or deny this Request for Admission, and, therefore, denies same. REQUEST FOR ADMISSION NO. 194: Do you admit that you conducted an investigation into the circumstances of the plaintiff's possible Vinyl Chloride exposure after learning that he had developed astrocytoma? - 94 - R&S) 63198 RESPONSE: Defendant reiterates its general objections. Subject to its objections, Defendant further states that it has had an insufficient amount of time to review all of its documents and discuss this matter with all relevant personnel and therefore, despite reasonable inquiry, is unable at this time to either admit or deny this Request for Admission, and, therefore, denies same. REQUEST FOR ADMISSION NO. 195: Do you admit that you first disseminated literature or other information to your employees relating the possible relationship between Vinyl Chloride exposure and astrocytoma after you became aware that the plaintiff had contracted that disease? RESPONSE: Denied. REQUEST FOR ADMISSION NO. 196: Do you admit that you first disseminated literature or other information to your employees relating the possible relationship between Vinyl Chloride containing products exposure and astrocytoma after you became aware that the plaintiff had contracted that disease? RESPONSE: Denied. REQUEST FOR ADMISSION NO. 197: Do you admit that you first disseminated literature or other information to your employees relating the possible relationship between Vinyl Chloride containing process streams exposure and astrocytoma after you became aware that the plaintiff had contracted that disease? - 95 - R&S163199 RESPONSE: Denied. REQUEST FOR ADMISSION NO. 198: Do you admit that you never informed plaintiff that there was a possible causal relationship between Vinyl Chloride exposure and the development of acute myelogenous leukemia? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission as being irrelevant to the extent that it seeks this Defendant to admit facts regarding a condition from which Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 199: Do you admit that you never informed plaintiff that there was a possible causal relationship between Vinyl Chloride exposure and the development of leukemia? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission as being irrelevant to the extent that it seeks this Defendant to admit facts regarding a condition from which Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 200: Do you admit that you never informed plaintiff that there was a possible causal relationship between Vinyl Chloride exposure and the development of lymphoma? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission as being irrelevant to the extent that it seeks this Defendant to admit facts regarding a condition from which Plaintiff allegedly does not suffer. - 96 - REQUEST FOR ADMISSION HO. 201; Do you admit that you never informed plaintiff that there was a possible causal relationship between Vinyl Chloride exposure and the development of disorders of the hemopoietic system? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission as being irrelevant to the extent that it seeks this Defendant to admit facts regarding a condition from which Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 202: Do you admit that you never informed plaintiff that there was a possible causal relationship between Vinyl Chloride exposure and the development of disorders of the lymphatic system? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission as being irrelevant to the extent that it seeks this Defendant to admit facts regarding a condition from which Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 203: Do you admit that you never informed plaintiff that there was a possible causal relationship between Vinyl Chloride exposure and the development of brain cancer? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission as being irrelevant to the extent that it seeks this Defendant to admit facts regarding a condition from which Plaintiff allegedly does not suffer. Defendant further objects to this Request for Admission as being improperly vague and ambiguous. - 97 - R&S163201 REQUEST FOR ADMISSION NO. 204: Do you admit that you never informed plaintiff that there was a possible causal relationship between Vinyl Chloride exposure and the development of angio sarcoma? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission as being irrelevant to the extent that it seeks this Defendant to admit facts regarding a condition from which Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 205: Do you admit that you never informed plaintiff that there was a possible causal relationship between Vinyl Chloride exposure and the development of astrocytoma? RESPONSE: Admitted. REQUEST FOR ADMISSION NO. 206: Do you admit that you never informed plaintiff that there was a possible causal relationship between Vinyl Chloride exposure and the development of glioblastoma? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission as being irrelevant to the extent that it seeks this Defendant to admit facts regarding a condition from which Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 207: Do you admit that you never informed plaintiff that there was a possible causal relationship between Vinyl Chloride containing products exposure and the development of acute myelogenous leukemia? - 98 - RESPONSE; Defendant reiterates its general objections. Defendant further objects to this Request for Admission as being irrelevant to the extent that it seeks this Defendant to admit facts regarding a condition from which Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 208; Do you admit that you never informed plaintiff that there was a possible causal relationship between Vinyl Chloride containing products exposure and the development of leukemia? RESPONSE; Defendant reiterates its general objections. Defendant further objects to this Request for Admission as being irrelevant to the extent that it seeks this Defendant to admit facts regarding a condition from which Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 209; Do you admit that you never informed plaintiff that there was a possible causal relationship between Vinyl Chloride containing products exposure and the development of lymphoma? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission as being irrelevant to the extent that it seeks this Defendant to admit facts regarding a condition from which Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 210; Do you admit that you never informed plaintiff that there was a possible causal relationship between Vinyl Chloride containing products exposure and the development of disorders of the hemopoietic system? - 99 - R&St 63203 RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission as being irrelevant to the extent that it seeks this Defendant to admit facts regarding a condition from which Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 211; Do you admit that you never informed plaintiff that there was a possible causal relationship between Vinyl Chloride containing products exposure and the development of disorders of the lymphatic system? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission as being irrelevant to the extent that it seeks this Defendant to admit facts regarding a condition from which Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 212: Do you admit that you never informed plaintiff that there was a possible causal relationship between Vinyl Chloride containing products exposure and the development of brain cancer? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission as being irrelevant to the extent that it seeks this Defendant to admit facts regarding a condition from which allegedly does not suffer. Defendant further objects to this Request for Admission as being improperly vague and ambiguous. - 100 - e33 C02O5? sro REQUEST FOR ADMISSION NO. 213: Do you admit that you never informed plaintiff that there was a possible causal relationship between Vinyl Chloride containing products exposure and the development of angio sarcoma? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission as being irrelevant to the extent that it seeks this Defendant to admit facts regarding a condition from which Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 214: Do you admit that you never informed plaintiff that there was a possible causal relationship between Vinyl Chloride containing products exposure and the development of astrocytoma? RESPONSE: Defendant reiterates its general objections. Defendant would further state that it has had insufficient time to review all documents and talk to all people who may have personal knowledge regarding the subject matter of this Request for Admission. Defenadnt is unable to either admit or deny this Request for Admission, despite reasonable inquiry, and therefore, denies same. REQUEST FOR ADMISSION NO. 215: Do you admit that you never informed plaintiff that there was a possible causal relationship between Vinyl Chloride containing products exposure and the development of glioblastoma? - 101 - R&S163205 RESPONSE; Defendant reiterates its general objections. Defendant further objects to this Request for Admission as being irrelevant to the extent that it seeks this Defendant to admit facts regarding a condition from which Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 216; Do you admit that you never informed plaintiff that there was a possible causal relationship between Vinyl Chloride containing process streams exposure and the development of acute myelogenous leukemia? RESPONSE; Defendant reiterates its general objections. Defendant further objects to this Request for Admission as being irrelevant to the extent that it seeks this Defendant to admit facts regarding a condition from which Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 217; Do you admit that you never informed plaintiff that there was a possible causal relationship between Vinyl Chloride containing process streams exposure and the development of leukemia? RESPONSE; Defendant reiterates its general objections. Defendant further objects to this Request for Admission as being irrelevant to the extent that it seeks this Defendant to admit facts regarding a condition from which Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 218; Do you admit that you never informed plaintiff that there was a possible causal relationship between Vinyl Chloride containing process streams exposure and the development of lymphoma? - 102 - R&S163206 RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission as being irrelevant to the extent that it seeks this Defendant to admit facts regarding a condition from which Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 219: Do you admit that you never informed plaintiff that there was a possible causal relationship between Vinyl Chloride containing process streams exposure and the development of disorders of the hemopoietic system? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission as being irrelevant to the extent that it seeks this Defendant to admit facts regarding a condition from which Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 219: (sic) Do you admit that you never informed plaintiff that there was a possible causal relationship between Vinyl Chloride containing process streams exposure and the development of disorders of the lymphatic system? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission as being irrelevant to the extent that it seeks this Defendant to admit facts regarding a condition from which Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 220: Do you admit that you never informed plaintiff that there was a possible causal relationship between Vinyl Chloride containing process streams exposure and the development of brain cancer? - 103 - R&S163207 RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission as being irrelevant to the extent that it seeks this Defendant to admit facts regarding a condition from which Plaintiff allegedly does not suffer. Defendant further objects to this Request for Admission as being improperly vague and ambiguous. REQUEST FOR ADMISSION NO. 221: Do you admit that you never informed plaintiff that there was a possible causal relationship between Vinyl Chloride containing process streams exposure and the development of angio sarcoma? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission as being irrelevant to the extent that it seeks this Defendant to admit facts regarding a condition from which Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 222: Do you admit that you never informed plaintiff that there was a possible causal relationship between Vinyl Chloride containing process streams exposure and the development of astrocytoma? RESPONSE: Admitted. REQUEST FOR ADMISSION NO. 223: Do you admit that you never informed plaintiff that there was a possible causal relationship between Vinyl Chloride containing process streams exposure and the development of glioblastoma? - 104 - R&S163208 RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission as being irrelevant to the extent that it seeks this Defendant to admit facts regarding a condition from which Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 224; D;. you admit that the defendant failed to comply with OSHA regulations pertaining to threshold limit values or permissible exposure limits for Vinyl Chloride at your Vinyl Chloride facility for any period of time between 1963 and 1984? RESPONSE: Defendant reiterates its general objections. Defendant further objects to Request for Admission No. 224 as being irrelevant for the years 1963 through 1968 and 1984 to the present for the reason the Plaintiff was not employed by this Defendant at that time. Defendant further objects to Request for Admission No. 224 as being improperly vague and ambiguous in failing to define pertinent terms, delineate areas of the facility requested, etc. REQUEST FOR ADMISSION NO. 225: Do you admit that your company had contracts with any agency of the United States of America for the manufacture or furnishing of any materials, supplied, articles or equipment in an amount exceeding $10,000.00 during the years: a. 1959 b. 1960 c. 1961 d. 1962 e. 1963 f. 1964 & 1965 h. 1966 i. 1967 j* 1968 k. 1969 1. 1970 - 105 - m. 1971 0. 1972 P* 1973 q* 1974 r. 1975 s. 1976 t. 1977 u. 1978 V. 1979 w. 1980 X. 1981 y- 1982 z. 1983 aa. 1984 bb. 1985 cc. 1986 dd. 1987 ee. 1988 ff. 1989 ge- 1990 RESPONSE: Defendant reiterates its general objections. Defendant further objects to Request for Admission No. 225(a)-(j) and (aa)-(gg) as irrelevant inasmuch as it asks this Defendant to admit facts regarding a time frame during which Plaintiff was not employed by this Defendant. Subject to those objections, Defendant admits this Request for Admission No. 225(k)-(z). REQUEST FOR ADMISSION NO. 226: Do you admit that defendant failed to comply with the regultaion promulgated pursuant to the Wash Healey Act (Section 540-204.275) pertaining to the threshold limit values for Vinyl Chloride at your Vinyl Chloride facility for any period of time between 1960 and 1990? RESPONSE: Defendant reiterates its general objections. Defendant further objects to Request for Admission No. 226 as irrelevant for that period of time during which - 106 - R&.S163210 Plaintiff was not employed by this Defendant. Subject to these objections, Defendant denies Request for Admission No. 226. REQUEST FOR ADMISSION NO. 227; Do you admit that your company was subject to the provisions of the Wash Healey Public Contracts Act between 1960 and 1990? RESPONSE: Defendant reiterates its general objections. Defendant further objects to Request for Admission No. 227 on the ground that it is irrelevant as to that period of time referenced during which Plaintiff was not employed by this Defendant. Subject to its objections, Defendant admits for Request for Admission No. 227. REQUEST FOR ADMISSION NO. 228: Do you admit that your company did not employ an industrial hygienist at its Vinyl Chloride facility before at least 1970? RESPONSE: Denied as written. REQUEST FOR ADMISSION NO. 229: Do you admit that you have no evidence that your company performed industrial hygiene monitoring (this is not to be interpreted as including testing for explosion hazards) relative to your employees possible Vinyl Chloride exposure at your Vinyl Chloride facility in: a. 1948 b. 1949 c. 1950 d. 1951 e. 1952 f. 1953 g- 1954 h. 1955 i. 1956 j- 1957 - 107 - Vt29lS'8H k. 1. m. n. o. Pqr. s. t. u. V. w. X. yz. aa. bb. cc. dd. ee. ff. gghh. ii. jj* kk. 11. mm. nn. oo. pp. qq. rr. ss. tt. 1958 1959 1960 1961 1962 1963 1964 1965 1966 1967 1968 1969 1970 1971 1972 1973 1974 1975 1976 1977 1978 1979 1980 1981 1982 1983 1984 1985 1986 1987 1988 1989 1990 1991 1992 1993 RESPONSE* Defendant reiterates its general objections. Defendant further objects to Request for Admission No. 229(a)-(u) and (kk)-(tt) as being irrelevant inasmuch as it seeks this Defendant to admit facts regarding a time frame during which Plaintiff was not employed by this Defendant. Subject to its objections, Defendant admits that it has evidence regarding industrial hygiene monitoring during certain of the years which are relevant to this action. R&S163212 - 108 - REQUEST FOR ADMISSION NO. 230; Do you admit that you have no evidence that your company performed industrial hygiene monitoring (this is not to be interpreted as including testing for explosion hazards) relative to your employees possible Vinyl Chloride containing products exposure at your Vinyl Chloride facility in: a. b. c. d. e. f. &* h. i. jk. 1. m. n. 0. Pqr. s. t. u. v. w. X. yz. aa. bb. cc. dd. ee. ff. gghh. ii. jj* kk. 11. mm. nn. 1948 1949 1950 1951 1952 1953 1954 1955 1956 1957 1958 1959 1960 1961 1962 1963 1964 1965 1966 1967 1968 1969 1970 1971 1972 1973 1974 1975 1976 1977 1978 1979 1980 1981 1982 1983 1984 1985 1986 1987 R&S163213 - 109 - oo. 1988 pp. 1989 qq. 1990 rr. 1991 ss. 1992 tt. 1993 RESPONSE: Defendant reiterates its general objections. Defendant further objects to Request for Admission No. 230(a)-(u) and (kk)-(tt) as being irrelevant inasmuch as it seeks this Defendant to admit facts regarding a time frame during which Plaintiff was not employed by this Defendant. Subject to its objections, Defendant admits that it has evidence regarding industrial hygiene monitoring during certain of the years which are relevant to this action. REQUEST FOR ADMISSION NO. 231; Do you admit that you have no evidence that your company performed industrial hygiene monitoring (this is not to be interpreted as including testing for explosion hazards) relative to your employees possible Vinyl Chloride containing process streams at your Vinyl Chloride facility in: a. 1948 b. 1949 c. 1950 d. 1951 e. 1952 f. 1953 g- 1954 h. 1955 i. 1956 j- 1957 k. 1958 1. 1959 m. 1960 n. 1961 0. 1962 P- 1963 q- 1964 r. 1965 s. 1966 t. 1967 - 110 - R&S163214 u. v. w. X. y- z. aa. bb. cc. dd. ee. ff. gghh. ii. jjkk. 11. mm. nn. oo. pp. qq. rr. ss. tt. 1968 1969 1970 1971 1972 1973 1974 1975 1976 1977 1978 1979 1980 1981 1982 1983 1984 1985 1986 1987 1988 1989 1990 1991 1992 1993 RESPONSE: Defendant reiterates its general objections. Defendant further objects to Request for Admission No. 231(a)-(u) and (kk)-(tt) as being irrelevant inasmuch as it seeks this Defendant to admit facts regarding a time frame during which Plaintiff was not employed by this Defendant. Subject to its objections, Defendant admits that it has evidence regarding industrial hygiene monitoring during certain of the years which are relevant to this action. REQUEST EQR ADMISSION NO. 232: Do you admit that you currently posses (sic) no information which indicates or sets forth the opinion that there is not an association between exposure to Vinyl Chloride and the development of: a. acute myelogenous leukemia b. leukemia c. lymphoma - Ill - d. multiple myeloma e. disorder of the hemopoietic system f. disorder of the lymphatic system g. brain cancer h. astrocytoma i. glioblastoma j. angio sarcoma RESPONSE: Defendant objects to Request for Admission No. 232 on the grounds that it is irrelevant to the extent that it asks this Defendant to admit facts regarding conditions or illnesses from which this Plaintiff does not suffer. Subject to its objections, Defendant denies Request for Admission No. 232. REQUEST FOR ADMISSION NO. 233 Do you admit that your company did not have a standard operating procedure relative to the safe use or handling of Vinyl Chloride: a. Before b. Before c. Before d. Before e. Before f. Before g. Before h. Before i. Before j. Before RESPONSE: 1945 1950 1955 1960 1965 1970 1975 1980 1985 1990 Defendant reiterates its general objections. Defendant further objects to Request for Admission No. 233 as being overly broad, vague, subject to different interpretation, duplicitous and irrelevant as to certain time frames during which Plaintiff was not an employee of Defendant. Subject to its objections, Defendant denies Request for Admission No. 233. R&S163216 - 112 - REQUEST FOR ADMISSION NO, 234: Do you admit that your company did not have a standard operating procedure relative to the safe use or handling of Vinyl Chloride containing products: a. Before 1945 b. Before 1950 e. Before 1955 d. Before 1960 e. Before 1965 f. Before 1970 g. Before 1975 h. Before 1980 i. Before 1985 j. Before 1990 RESPONSE; Defendant reiterates its general objections. Defendant further objects to Request for Admission No. 234 as being overly broad, vague, subject to different interpretation, duplicitous and irrelevant as to certain time frames during which Plaintiff was not an employee of Defendant. Subject to its objections, Defendant denies Request for Admission No. 234. REQUEST FOR ADMISSION NO. 235; Do you admit that your company did not have a standard operating procedure relative to the safe use or handling of Vinyl Chloride containing process streams: a. Before 1945 b. Before 1950 c. Before 1955 d. Before 1960 e. Before 1965 f. Before 1970 g. Before 1975 h. Before 1980 i. Before 1985 j. Before 1990 - 113 - R&S163217 RESPONSE: Defendant reiterates its general objections. Defendant further objects to Request for Admission No. 235 as being overly broad, vague, subject to different interpretation, duplicitous and irrelevant as to certain time frames during which Plaintiff was not an employee of Defendant. Subject to its objections, Defendant denies Request for Admission No. 235. REQUEST FOR ADMISSION NO. 236: Do you admit that you cannot name a single witness who will testify that a rule requiring your employees to wear respirators in all operations where there was dust, smoke or fumes present in very light concentrations was ever enforced at your Vinyl Chloride facility in: a. 1940's b. 1950's c. 1960's d. 197 0's e. 1980's f. 1990's RESPONSE: Defendant reiterates its general objections. Defendant further objects to Request for Admission No. 236(a)-(c) and (e)-(f) as being irrelevant for those periods of time during which Plaintiff was not employed by this Defendant. Subject to its objections, Defendant would state it has had an insufficient amount of time to review its documents and meet with those individuals with personal knowledge and therefore, despite reasonable inquiry, Defendant is unable to either admit or deny the relevant portion of this Request, and, therefore, denies same. REQUEST FOR ADMISSION NO. 237: Do you admit that you cannot name a single witness who will testify that a rule requiring your employees to wear gas masks (canister type) in all cases where toxic - 114 - gases or chemicals might be present in open areas and low concentrations was ever enforced at your Vinyl Chloride facility in the: a. 1940's b. 1950's c. 1960's d. 1970's e. 1980's f. 1990's RESPONSE: Defendant reiterates its general objections. Defendant further objects to Request for Admission No. 237(a)-(c) and (e)-(f) as being irrelevant for those periods of time during which Plaintiff was not employed by this Defendant. Subject to its objections, Defendant would state it has had an insufficient amount of time to review its documents and meet with those individuals with personal knowledge and therefore, despite reasonable inquiry, Defendant is unable to either admit or deny the relevant portion of this Request, and, therefore, denies same. REQUEST FOR ADMISSION NO. 238: Do you admit that you cannot name a single witness who will testify that a rule requiring the use of gas masks (hose or fresh air type) in all cases where toxic gases or chemicals were present in hazardous concentrations and in all closed places, such as towers, vessels, storage tanks, tank cars, man holes, etc., where there might be heavy smoke or a deficiency of oxygen was ever enforced at your Vinyl Chloride facility in the: a. 1940's b. 195Q's c. 1960's d. 19 7 0's e. 1980's f. 1990's - 115 - RESPONSE: Defendant reiterates its general objections. Defendant further objects to Request for Admission No. 238(a)-(c) and (e)-(f) as being irrelevant for those periods of time during which Plaintiff was not employed by this Defendant. Subject to its objections, Defendant would state it has had an insufficient amount of time to review its documents and meet with those individuals with personal knowledge and therefore, despite reasonable inquiry, Defendant is unable to either admit or deny the relevant portion of this Request, and, therefore, denies same. REQUEST FOR ADMISSION NO. 239: Do you admit that you are aware of epidemiological studies indicating excess exposures to Vinyl Chloride at Rail loading facilities? RESPONSE: Defendant reiterates its general objections. Defendant further objects to Request for Admission No. 239 on the grounds that it is vague, ambiguous and nonsensical. REQUEST FOR ADMISSION NO. 240: Do you admit that the plaintiff was exposed to Vinyl Chloride in excess of OSHA'S threshold limit value while working at the Conoco/Vista PVC Plant in Aberdeen, Mississippi during the years: a. 1966 b. 1967 c. 1968 d. 1969 e. 1970 f. 1971 e* 1972 h. 1973 i. 1974 j- 1975 k. 1976 1. 1977 - 116 - R&S163220 m. 1978 n. 1979 o. 1980 P- 1981 <3- 1982 r. 1983 s. 1984 RESPONSE: Defendant reiterates its general objections. Defendant further objects to Request for Admission No. 240 as being irrelevant for those periods of time during which Plaintiff was not employed by this Defendant. Subject to these objections, Defendant denies Request for Admission No. 240. REQUEST FOR ADMISSION NO. 241: Do you admit that the plaintiff was exposed to Vinyl Chloride containing products in excess of OSHA's threshold limit value while working at the Conoco/Vista PVC Plant in Aberdeen, Mississippi during the years: a. 1966 b. 1967 c. 1968 d. 1969 e. 1970 f. 1971 S- 1972 h. 1973 i. 1974 j- 1975 k. 1976 1. 1977 m. 1978 n. 1979 o. 1980 P- 1981 q- 1982 r. 1983 s. 1984 RESPONSE- Defendant reiterates its general objections. Defendant further objects to Request for Admission No. 241 as being irrelevant for those periods of time during - 117 - R&S163221 which Plaintiff was not employed by this Defendant. Subject to these objections, Defendant denies Request for Admission No. 241. REQUEST FOR ADMISSION NO. 242; Do you admit that the plaintiff was exposed to Vinyl Chloride containing process streams in excess of OSHA'S threshold limit value while working at your Vinyl Chloride facility during the years: a. 1966 b. 1967 c. 1968 d. 1969 e. 1970 f. 1971 g- 1972 h. 1973 i. 1974 j- 1975 k. 1976 1. 1977 m. 1978 n. 1979 o. 1980 P- 1981 q- 1982 r. 1983 s. 1984 RESPONSE: Defendant reiterates its general objections. Defendant further objects to Request for Admission No. 242 as being irrelevant for those periods of time during which Plaintiff was not employed by this Defendant. Subject to these objections, Defendant denies Request for Admission No. 242. REQUEST FOR ADMISSION NO. 243: Do you admit that you did not provide the plaintiff with adequate medical surveillance as required by 29 CFR 1910.1017 et seq during the years: a. 1966 b. 1967 - 118 - R&S163222 c. 1968 d. 1969 e. 1970 f. 1971 B- 1972 h. 1973 i. 1974 ] 1975 k. 1976 1. 1977 m. 1978 n. 1979 0. 1980 P* 1981 q- 1982 r. 1983 s. 1984 RESPONSE: Defendant reiterates its general objections. Defendant further objects to Request for Admission No. 243(a)-(c) and (s) as being irrelevant inasmuch as it seeks this Defendant to admit to facts for a time frame during which Plaintiff was not employed by this Defendant. Subject to its objections, Defendant denies that it failed to comply with 29 C.F.R. 1910.1017, et seq. REQUEST FOR ADMISSION NO. 244: Do you admit that you did not provide the plaintiff with medical monitoring required by 29 CFR 1910.1017 et seq during the years: a. 1966 b. 1967 c. 1968 d. 1969 e. 1970 f. 1971 B* 1972 h. 1973 i. 1974 j- 1975 k. 1976 1. 1977 m. 1978 n. 1979 0. 1980 - 119 - R&Sf 63223 ) p- 1981 q* 1982 r. 1983 s. 1984 t. 1985 u. 1986 V, 1987 w. 1988 X. 1989 y- 1990 z. 1991 aa. 1992 bb. 1993 RESPONSE: Defendant reiterates its general objections. Defendant further objects to Request for Admission No. 244(a)-(c) and (s) as being irrelevant inasmuch as it seeks this Defendant to admit to facts for a time frame during which Plaintiff was not employed by this Defendant. Subject to its objections, Defendant denies that it failed to comply with 29 C.F.R. 1910.1017, et seq, REQUEST FOR ADMISSION NO. 245: Do you admit that your company never provided the plaintiff with personal monitoring devices evidencing his level of exposure to Vinyl Chloride while working at your Conoco/Vista PVC Plant in Aberdeen, Mississippi during the years: a. 1966 b. 1967 c. 1968 d. 1969 e. 1970 f. 1971 g- 1972 h. 1973 i. 1974 j- 1975 k. 1976 1. 1977 m. 1978 n. 1979 0. 1980 P- 1981 q- 1982 - 120 - Si 63224 r. 1983 s. 1984 RESPONSE: Defendant reiterates its general objections. Defendant further objects to Request for Admission No. 245 as being irrelevant for those periods of time during which Plaintiff was not employed by this Defendant. Defendant further states that it has had insufficient time to review all of its relevant documents and meet with individuals with personal knowledge and, therefore, despite reasonable inquiry to date, is unable to either admit or deny the relevant portions of Request for Admission No. 245. REQUEST FOR ADMISSION NO. 246: Do you admit that your company never warned the public at large of the hazards associated with exposure to Vinyl Chloride containing products manufactured, sold, and/or distributed by your company during the years: a. 1948 b. 1949 c. 1950 d. 1951 e. 1952 f. 1953 & 1954 h. 1955 i. 1956 j- 1957 k. 1958 1. 1959 m. 1960 n. 1961 o. 1962 P- 1963 q- 1964 r. 1965 s. 1966 t. 1967 u. 1968 V. 1969 w. 1970 X. 1971 - 121 - 63225 y* 1972 2. 1973 aa. 1974 bb. 1975 cc. 1976 dd. 1977 ee. 1978 ff. 1979 eg- 1980 hh. 1981 ii. 1982 ii- 1983 kk. 1984 11. . 1985 mm. 1986 nn. 1987 oo. 1988 pp. 1989 qq. 1990 rr. 1991 ss. 1992 tt. 1993 RESPONSE Defendant reiterates its general objections. Defendant further objects to Request for Admission No. 246(a)-(u) and (kk)-(tt) as being irrelevant in that it seeks this Defendant to admit facts for a time frame during which Plaintiff was not employed by Defendant. Defendant further objects to the remainder of Request for Admission No. 246 as being irrelevant to the allegations as pled by Plaintiff. REQUEST FOR ADMISSION NO. 247: Do you admit that Vinyl Chloride is unreasonably dangerous per se? RESPONSE: Denied. REQUEST FOR ADMISSION NO. 248: Do you admit that Vinyl Chloride containing products are dangerous per se? RESPONSE: Denied. R&S163226 - 122 - REQUEST FOR ADMISSION NO. 249: Do you admit that Vinyl Chloride containing process streams are dangerous per se? RESPONSE: Denied. REQUEST FOR ADMISSION NO. 250: Do you admit that you did not anticipate this litigation until you were served with a copy of the Plaintiff's Original Petition to perpetuate testimony which was filed on or about July 5, 1992? RESPONSE: Defendant reiterates its general objections. Defendant further objects to Request for Admission No. 250 on the grounds that it is irrelevant to the claims currently pled by Plaintiff. REQUEST FOR ADMISSION NO. 251: Do you admit that your company did not disseminate information concerning the health hazards associated with exposure to Vinyl Chloride to its employees in: a. 1947 b. 1948 c. 1949 d. 1950 e. 1951 f. 1952 e- 1953 h. 1954 i. 1955 j- 1956 k. 1957 1. 1958 m. 1959 n. 1960 0. 1961 P* 1962 q- 1963 r. 1964 - 123 - R&S163227 s. t. u. V. w. X. yz. aa. bb. cc. dd. ee. ff. gg* hh. ii. jjkk. 11. mm. nn. oo. pp. qq. rr. ss. tt. uu. 1965 1966 1967 1968 1969 1970 1971 1972 1973 1974 1975 1976 1977 1978 1979 1980 1981 1982 1983 1984 1985 1986 1987 1988 1989 1990 1991 1992 1993 RESPONSE: Defendant reiterates its general objections- Defendant further objects to Request for Admission No. 251(a)-(v) and (ll)-(uu) as being irrelevant in that it seeks this Defendant to admit facts for a time frame during which the Plaintiff was not employed by Defendant. Defendant further objects to Request for Admission No. 251 as being overly broad, vague and ambiguous. Subject to its objections, Defendant denies Request for Admission No. 251. REQUEST FOR ADMISSION NO. 252; Do you admit that the defendant exposed the plaintiff to Vinyl Chloride without his consent during the years: a. 1966 R&Sj 63228 - 124 - b. 1967 c. 1968 d. 1969 e. 1970 f. 1971 g- 1972 h. 1973 i. 1974 j- 1975 k. 1976 1. 1977 m. 1978 n. 1979 o. 1980 P- 1981 q. 1982 r. 1983 s. 1984 RESPONSE** Denied. REQUEST FOR ADMISSION NO. 253: Do you admit that the defendant exposed the plaintiff to Vinyl Chloride containing products without his consent during the years: a. 1966 b. 1967 c. 1968 d. 1969 e. 1970 f. 1971 g- 1972 h. 1973 i. 1974 j* 1975 k. 1976 1. 1977 m. 1978 n. 1979 o. 1980 P- 1981 q* 1982 r. 1983 s. 1984 - 125 - 63229 RESPONSE: Denied. REQUEST FOR ADMISSION NO. 254: Do you admit that the defendant exposed the plaintiff to Vinyl Chloride containing process streams without his consent during the years: a. 1966 b. 1967 c. 1968 d. 1969 e. 1970 f. 1971 g- 1972 h. 1973 i. 1974 3- 1975 k. 1976 1. 1977 m. 1978 n. 1979 0. 1980 P- 1981 <3- 1982 r. 1983 s. 1984 RESPONSE** Denied. REQUEST FOR ADMISSION NO. 255: Do you admit that the sewage ditch located at your Vinyl Chloride facility was contaminated with Vinyl Chloride for the years: a. 1966 b. 1967 c. 1968 d. 1969 e. 1970 f. 1971 g- 1972 h. 1973 i. 1974 j- 1975 - 126 - R&S163230 k. 1976 1. 1977 m. 1978 n. 1979 0. 1980 P* 1981 q- 1982 r. 1983 s. 1984 t. 1985 u. 1986 V. 1987 w. 1988 X. 1989 y- 1990 z. 1991 aa. 1992 bb. 1993 RESPONSE* Defendant reiterates its general objections. Defendant objects to this Request for Admission as being irrelevant for those years during which Plaintiff was not employed by this Defendant. Defendant objects to this Request for Admission as being improperly vague and ambiguous. Defendant further states that it has had insufficient time to review all documents or speak with all persons who may have personal knowledge of the facts sought in this Request for Admission and, despite reasonable inquiry, is unable to either admit or deny this Request for Admission and, therefore, denies same. REQUEST FOR ADMISSION NO. 256; Do you admit that the sewage ditch located at your Vinyl Chloride facility was contaminated with Vinyl Chloride containing products for the years: a. 1966 b. 1967 c. 1968 d. 1969 e. 1970 f. 1971 g- 1972 h. 1973 - 127 - R&S163231 i. 1974 j* 1975 k. 1976 1. 1977 m. 1978 n. 1979 o. 1980 P- 1981 q- 1982 r. 1983 s. 1984 t. 1985 u. 1986 V. 1987 w. 1988 X. 1989 y* 1990 z. 1991 aa. 1992 bb. 1993 RESPONSE*# Defendant reiterates its general objections. Defendant objects to this Request for Admission as being irrelevant for those years during which Plaintiff was not employed by this Defendant. Defendant objects to this Request for Admission as being improperly vague and ambiguous. Defendant further states that it has had insufficient time to review all documents or speak with all persons who may have personal knowledge of the facts sought in this Request for Admission and, despite reasonable inquiry, is unable to either admit or deny this Request for Admission and, therefore, denies same. REQUEST FOR ADMISSION NO. 257: Do you admit that the sewage ditch located at your Vinyl Chloride facility was contaminated with Vinyl Chloride containing process streams for the years: a. 1966 b. 1967 c. 1968 d. 1969 e. 1970 f. 1971 - 128 - R&S163232 g* h. i. j- k. 1. m. n. o. Pq- r. s. t. . u. V. w. X. y- 2. aa. bb. 1972 1973 1974 1975 1976 1977 1978 1979 1980 1981 1982 1983 1984 1985 1986 1987 1988 1989 1990 1991 1992 1993 RESPONSE* Defendant reiterates its general objections. Defendant objects to this Request for Admission as being irrelevant for those years during which Plaintiff was not employed by this Defendant. Defendant objects to this Request for Admission as being improperly vague and ambiguous. Defendant further states that it has had insufficient time to review all documents or speak with all persons who may have personal knowledge of the facts sought in this Request for Admission and, despite reasonable inquiry, is unable to either admit or deny this Request for Admission and, therefore, denies same. REQUEST FOR ADMISSION NO. 258i Do you admit that you released Vinyl Chloride containing products (including, but not limited to resins) into the ambient air during the years: a. 1966 b. 1967 c. 1968 d. 1969 R&Sl 63233 - 129 - e. 1970 f. 1971 S- 1972 h. 1973 i. 1974 j* 1975 k. 1976 1. 1977 m. 1978 n. 1979 o. 1980 P- 1981 q* 1982 r. 1983 s. 1984 t. 1985 u. 1986 V. 1987 w. 1988 X. 1989 y- 1990 z. 1991 aa. 1992 bb. 1993 RESPONSE: Denied. REQUEST FOR ADMISSION NO. 259: Do you admit that you released Vinyl Chloride into the ambient air during the years: a. 1966 b. 1967 c. 1968 d. 1969 e. 1970 f. 1971 g- 1972 h. 1973 i. 1974 j* 1975 k. 1976 1. 1977 m. 1978 n. 1979 o. 1980 P- 1981 - 130 - R&S163234 q- 1982 r. 1983 s. 1984 t. 1985 u. 1986 V. 1987 w. 1988 X. 1989 y- 1990 z. 1991 aa. 1992 bb. 1993 RESPONSE; Denied. REQUEST FOR ADMISSION NO. 260; Do you admit that you supplied any Vinyl Chloride to the Conoco/Vista PVC Plant in Aberdeen, Mississippi during the years: a. 1966 b. 1967 e. 1968 d. 1969 e. 1970 f. 1971 1972 h. 1973 i. 1974 j* 1975 k. 1976 1. 1977 m. 1978 n. 1979 o. 1980 P- 1981 q- 1982 r. 1983 s. 1984 t. 1985 u. 1986 V. 1987 w. 1988 X. 1989 y- 1990 z. 1991 aa. 1992 bb. 1993 - 131 - R&S163235 RESPONSE; Defendant reiterates its general objections. Defendant objects to Request for Admission No. 260 for those years during which Plaintiff was not employed by this Defendant. Subject to its objections, Request for Admission No. 260 is admitted. REQUEST FOR ADMISSION NO. 261; Do you admit that plaintiff, while employed by defendant at its Vinyl Chloride facility, was included in a medical surveillance program for personnel exposed to Vinyl Chloride for the period of time; a. 1966 b. 1967 c. 1968 d. 1969 e. 1970 f. 1971 S- 1972 h. 1973 i. 1974 ]' 1975 k. 1976 1. 1977 m. 1978 n. 1979 o. 1980 P- 1981 q- 1982 r. 1983 s. 1984 t. 1985 u. 1986 V. 1987 w. 1988 X. 1989 y- 1990 z. 1991 aa. 1992 bb. 1993 RESPONSE: Defendant reiterates its general objections. Defendant further objects to Request for Admission No. 261 as being irrelevant for those years during which 132 - R&S163236 Plaintiff was not employed by this Defendant, Subject to its objections, Defendant admits that Plaintiff's health and medical condition were monitored. REQUEST FOR ADMISSION NO. 262: Do you admit that plaintiff, while employed by defendant at its Vinyl Chloride facility, was included in a medical surveillance program for personnel exposed to Vinyl Chloride containing products for the period of time: a. 1966 b. 1967 c. 1968 d. 1969 e. 1970 f. 1971 e- 1972 h. 1973 i. 1974 j- 1975 k. 1976 1. 1977 m. 1978 n. 1979 o. 1980 P- 1981 q* 1982 r. 1983 s. 1984 t. 1985 u. 1986 V. 1987 w. 1988 X. 1989 y- 1990 z. 1991 aa. 1992 bb. 1993 RESPONSE : Defendant reiterates its general objections. Defendant further objects to Request for Admission No. 262 as being irrelevant for those years during which Plaintiff was not employed by this Defendant. Subject to its objections, Defendant admits that Plaintiff's health and medical condition were monitored. - 133 - R&Sl 63237 REQUEST FOR ADMISSION NO. 263: Do you admit that plaintiff, while employed by defendant at its Vinyl Chloride facility, was included in a medical surveillance program for personnel exposed to Vinyl Chloride containing process streams for the period of time: a. 1966 b. 1967 c. 1968 d. 1969 e. 1970 f. 1971 S- 1972 h. 1973 i. 1974 j- 1975 k. 1976 1. 1977 m. 1978 n. 1979 0. 1980 P* 1981 q- 1982 r. 1983 s. 1984 t. 1985 u. 1986 V. 1987 w. 1988 X. 1989 y* 1990 z. 1991 a a. 1992 bb. 1993 RESPONSE ** Defendant reiterates its general objections. Defendant further objects to Request for Admission No. 263 as being irrelevant for those years during which Plaintiff was not employed by this Defendant. Subject to its objections, Defendant admits that Plaintiff's health and medical condition were monitored. - 134 - R&S163238 REQUEST POR ADMISSION NO. 264; Do you admit that plaintiff, while employed at your Vinyl Chloride facility, was included in a medical surveillance program for personnel exposed to any chemical substance other than Vinyl Chloride for any period of time from 1963 through 1993? RESPONSE: Defendant reiterates its general objections. Defendant further objects to Request for Admission No. 264 as being irrelevant for those years during which Plaintiff was not employed by this Defendant. Subject to its objections, Defendant admits that Plaintiff's health and medical condition were monitored. REQUEST FOR ADMISSION NO. 265: Do you admit that plaintiff was not the first employee or former employee at your Vinyl Chloride facility to be diagnosed with acute myelogenous leukemia? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission as being irrelevant in that it seeks Defendant to admit facts regarding a disease or illness from which Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 266: Do you admit that plaintiff was not the first employee or former employee at your Vinyl Chloride facility to be diagnosed with leukemia? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission as being irrelevant in that it seeks Defendant to admit facts regarding a disease or illness from which Plaintiff allegedly does not suffer. - 135 - R&S163239 REQUEST FOR ADMISSION NO. 267; Do you admit that plaintiff was not the first employee or former employee at your Vinyl Chloride facility to be diagnosed with lymphoma? RESPONSE; Defendant reiterates its general objections. Defendant further objects to this Request for Admission as being irrelevant in that it seeks Defendant to admit facts regarding a disease or illness from which Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 268: Do you admit that plaintiff was not the first employee or former employee at your Vinyl Chloride facility to be diagnosed with multiple myeloma? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission as being irrelevant in that it seeks Defendant to admit facts regarding a disease or illness from which Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 269: Do you admit that plaintiff was not the first employee or former employee at your Vinyl Chloride facility to be diagnosed with disorders of the hemopoietic system? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission as being irrelevant in that it seeks Defendant to admit facts regarding a disease or illness from which Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 270: Do you admit that plaintiff was not the first employee or former employee at your Vinyl Chloride facility to be diagnosed with disorders of the lymphatic system? - 136 - RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission as being irrelevant in that it seeks Defendant to admit facts regarding a disease or illness from which Plaintiff does allegedly not suffer. REQUEST FOR ADMISSION NO. 271: Do you admit that plaintiff was not the first employee or former employee at your Vinyl Chloride facility to be diagnosed with brain cancer? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission as being irrelevant in that it seeks Defendant to admit facts regarding a disease or illness from which Plaintiff allegedly does not suffer. Defendant further objects to this Request for Admission as being improperly vague and ambiguous. REQUEST FOR ADMISSION NO. 272: Do you admit that plaintiff was not the first employee or former employee at your Vinyl Chloride facility to be diagnosed with angio sarcoma? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission as being irrelevant in that it seeks Defendant to admit facts regarding a disease or illness from which Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 273: Do you admit that plaintiff was not the first employee or former employee at your Vinyl Chloride facility to be diagnosed with astrocytoma? - 137 - RESPONSE: Defendant reiterates its general objections. Furthermore, Defendant has had insufficient time to review its records and meet with individuals who have personal knowledge and, despite the reasonable inquiry made so far, Defendant is unable to either admit or deny this Request for Admission, and, therefore, denies same. REQUEST FOR ADMISSION NO. 274: Do you admit that plaintiff was not the first employee or former employee at your Vinyl Chloride facility to be diagnosed with glioblastoma? RESPONSE: Defendant reiterates its general objections. Defendant further objects to this Request for Admission as being irrelevant in that it seeks Defendant to admit facts regarding a disease or illness from which Plaintiff allegedly does not suffer. REQUEST FOR ADMISSION NO. 275: Do you admit that plaintiff was employed by you and was assigned to your Vinyl Chloride facility at any time between 1963 and 1984? RESPONSE: Admitted. REQUEST FOR ADMISSION NO. 276: Do you admit that plaintiff was exposed to Vinyl Chloride in excess of OSHA threshold limit value while employed at the defendant's Vinyl Chloride facility at any time between? a. 1966 b. 1967 c. 1968 d. 1969 e. 1970 f. 1971 g- 1972 h. 1973 - 138 - R&S163242 i. 1974 j- 1975 k. 1976 1. 1977 m. 1978 n. 1979 0. 1980 P* 1981 <3- 1982 r. 1983 s. 1984 RESPONSE: Defendant reiterates its general objections. Defendant further objects to Request for Admission No. 276(a-c) and (s) as being irrelevant inasmuch as it seeks this Defendant to admit to facts for a time frame during which Plaintiff was was not employed by this Defendant. Defendant further states that it has had insufficient time to review its documents and meet with individuals who have personal knowledge sufficient to allow Defendant to respond to this Request for Admission. Therefore, despite such reasonable inquiry to date, Defendant is unable to either admit or deny Request for Admission No. 276(d-r), and, therefore, denies same. REQUEST FOR ADMISSION NO. 277: Do you admit that plaintiff was exposed to Vinyl Chloride containing products in excess of OSHA threshold limit value while employed at the defendants Vinyl Chloride facility at any time between: a. 1966 b. 1967 c. 1968 d. 1969 e. 1970 f. 1971 % 1972 h. 1973 i. 1974 ] 1975 k. 1976 1. 1977 m. 1978 - 139 - n. 1979 o. 1980 P- 1981 q* 1982 r. 1983 s. 1984 RESPONSE* Defendant reiterates its general objections. Defendant further objects to Request for Admission No. 277(a-c) and (s) as being irrelevant inasmuch as it seeks this Defendant to admit to facts for a time frame during which Plaintiff was was not employed by this Defendant. Defendant further states that it has had insufficient time to review its documents and meet with individuals who have personal knowledge sufficient to allow Defendant to respond to this Request for Admission. Therefore, despite such reasonable inquiry to date, Defendant is unable to either admit or deny Request for Admission No. 277(d-r), and, therefore, denies same. REQUEST FOR ADMISSION NO. 278: Do you admit that plaintiff was exposed to Vinyl Chloride containing process streams in excess of OSHA threshold limit value while employed at the defendant's Vinyl Chloride facility at any time between: a. 1966 b. 1967 c. 1968 d. 1969 e. 1970 f. 1971 g- 1972 h. 1973 i. 1974 j- 1975 k. 1976 1. 1977 m. 1978 n. 1979 o. 1980 P- 1981 q* 1982 r. 1983 - 140 - R&SI 63244 s. 1984 RESPONSE; Defendant reiterates its general objections. Defendant further objects to Request for Admission No. 278(a-c) and (s) as being irrelevant inasmuch as it seeks this Defendant to admit to facts for a time frame during which Plaintiff was was not employed by this Defendant. Defendant further states that it has had insufficient time to review its documents and meet with individuals who have personal knowledge sufficient to allow Defendant to respond to this Request for Admission. Therefore, despite such reasonable inquiry to date, Defendant is unable to either admit or deny Request for Admission No. 278(d~r), and, therefore, denies same. REQUEST FOR ADMISSION NO. 279: Do you admit that the plaintiff was exposed to Vinyl Chloride in excess of OSHA's threshold limit values while employed at your Vinyl Chloride facility in: a. 1980 b. 1981 c. 1982 d. 1983 e. 1984 f. 1985 g- 1986 h. 1987 i. 1988 j- 1989 k. 1990 RESPONSE : Defendant reiterates its general objections. Defendant further objects to Request for Admission No. 279(e-k) as being irrelevant inasmuch as it seeks this Defendant to admit to facts for a time frame during which Plaintiff was not employed by the Defendant. Defendant further states that it has had insufficient time to review its documents and meet with individuals who have personal knowledge sufficient to allow Defendant to respond to this Request for Admission. Therefore, despite such - 141 - R&S163245 reasonable inquiry to date, Defendant is unable to either admit or deny Request for Admission No. 279(a-d), and, therefore, denies same. REQUEST FOR ADMISSION NO. 280: Do you admit that your company is successor in interest to Conoco Oil Company, Conoco Chemical and Monroe Manufacturing PVC plant located in Aberdeen, Monroe County, Mississippi? RESPONSE: Denied. Respectfully submitted DEBORAH D. KUCHLER (17013) Abbott it Meeks 400 Lafayette Street, Suite 200 New Orleans, Louisiana 70130 Telephone: 504/568-9393 Attorneys for Defendants, Conoco Inc. and E. Marcus Smith CERTIFICATE OF SERVICE I DO HEREBY CERTIFY that I have on this jay of October, 1993, served the foregoing pleading on all counsel of record by placing a copy of same in the United States Mail, properly addressed and first class postage prepaid, or by hand delivery. j6dbWidtjh Jo. khddiAy /pi R&St 63246 - 142 -