Document k9DRN4Y0qYnRaNdrzXm1ZnGXV
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1 Robert D. Bjork, Jr. Dorine R. Kohn
2 BJORK, FLEER & LAWRENCE 483 Ninth Street
3 Oakland, California 94607 Telephone: (415) 632-8134
4 Attorneys for Defendant
5 The Rockbestos Company
6
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BRAYTON *7T~
MAY 2 8 19P1
REC6I7L. To File____________ ClassT::E/D/S>t_ WC/DEF
7030
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6 SUPERIOR COURT OF CALIFORNIA - COUNTY OF SOLANO
9
10 In Re:
No. 2830
11
COMPLEX ASBESTOS LITIGATION
12
THE ROCKBESTOS COMPANY'S RESPONSES TO GENERAL ORDER NO. 30.00 INTERROGATORIES
13 /
14
15 The Rockbestos Company ("Rockbestos"), responds to
16 plaintiffs' standard interrogatories pursuant to General order
17 No. 30.00 as follows:
18
19
20
21
22
j23
Rockbestos objects to the interrogatories on the
jj24 grounds that they exceed the permissible scope of discovery as
25 defined by CCP 2017, and seek information which is neither
ji, .
26 relevant to the subject matter of this action nor reasonably
27 j calculated to lead to the discovery of admissible evidence.
28
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I
SC-ELEC-10030
1 at the hearing on the motion for the order consolidating 2 discovery and has had no opportunity to be heard with regard to 3 that order or to the form of discovery propounded. Rockbestos 4 further objects on the ground that it has never stipulated to 5 adoption of these interrogatories by the Solano County Superior
6 court. As such Rockbestos asserts that any obligation to respond
7 to plaintiff's standard interrogatories is unenforceable under
6 the Code of Civil Procedure and is a denial of due process of
9 law. Thus, to the extent the interrogatories do not comply with
10 the Civil Discovery Act of 1986, C.C.P. Section 2016 et sea..
11 which sets forth the California legislature's governing
12 provisions pertaining to interrogatories, Rockbestos objects.
13
14 More specifically, Rockbestos objects to the
15 interrogatories in that the interrogatories and their subparts
16 exceed the Statutory number permitted by CCP 2030(c). In
17 addition, Rockbestos objects to the interrogatories to the extent
18 that many of the interrogatories are not complete in and of
19 themselves, or contain subparts, are compound, conjunctive or
20 disjunctive in violation of CCP 2030(c)(5). Moreover, the
21 interrogatories contain instructions and "definitions" which do
22 !| not comply with CCP 2030(c)(5), are overbroad, vague, 23 j| inconsistent with normal usage and meaning and are
24 \] unintelligible. Accordingly, the responses utilize those terms
i'i
25 p as they are commonly understood.
26 i11> i,
27
j!
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Rockbestos objects to the interrogatories on the
28 ; grounds that they seek "corporate knowledge" because it is
3
1 impossible for Rockbestos to set forth a collective knowledge of
2 all Rockbestos employees, past and present. The information
3 contained in the interrogatory responses has been assembled by
:
4 authorized employees and counsel for Rockbestos. It is
j
!
5 impossible to reconstruct each step in the information gathering 1
6 process or to state that all pertinent documents have been
j
7 discovered and examined. It is also impossible to state that all
8 individuals with relevant knowledge have been contacted to this 9 point. Investigation continues and Rockbestos specifically 10 reserves the right to revise, correct, supplement and amend these 11 interrogatory responses.
12 13 Rockbestos has never mined asbestos fiber or 14 manufactured asbestos thermal insulation. Many of the
15 interrogatories request information relating to the mining of
16 asbestos and the processes utilized in manufacturing raw
17 asbestos. Rockbestos objects to these and other interrogatories,
18 propounded as a boilerplate set of interrogatories in that they
19 are not designed to' elicit discoverable information from 20 Rockbestos.
21
22 Rockbestos does not waive any objection, on any ground,
23 whether or not asserted herein, to the interrogatories or to the i!
24 admission of the interrogatories and responses at trial.
25 !' Furthermore, Rockbestos reserves the right to assert further
i| 26 jl objections to the interrogatories. The preliminary statement and
27 || general objections contained herein are specifically made a part
28
4
1 of and incorporated by reference into each of the responses set 2 forth below.
3 4 Response to Interrogatory Wo. 1:
5 6 See Preliminary statement and General Objections. 7 Notwithstanding these objections, Rockbestos responds:
8 9 a. George Littlehales;
10 11 b. The Rockbestos company, 285 Nicoll Street, New 12 Haven, Connecticut 06504;
13 14 c. Quality Assurance Manager;
15
16
d. Dates of Employment
Position Held
17
IB
1967-1968
Personnel Mgr.
19
1968-1971
Materials Mgr.
20
1971-1973
Superintendent
21
1973-Present
Quality
Assurance Mgr.
22
23 24 Response to Interrogatory No. 2: 25
26 See preliminary statement and general objections. 27 Notwithstanding these objections, Rockbestos responds: 28
5
1 a. - e. The Rockbestos Company was incorporated on 2 March 1, 1923. It is a Delaware Corporation with its principal 3 place of business at 285 Nicoll Street, New Haven, Connecticut 4 11 06504.
!t
li 5 6 Response to Interrogatory No. 3:
7 8 See Preliminary Statement and General Objections. 9 Notwithstanding these objections, Rockbestos responds:
10
j 11
Rockbestos was known as Rockbestos Products Corporation
!j 12 dating from March 1> 1923. In 1959 it became a division of Cerro
OAKLAND. CALIFORNIA 9-HJO^
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Corporation. In 1984, it became The Rockbestos Company.
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c. 15
Response to Interrogatory No. 4:
16
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17 See Preliminary Statement and General Objections.
ii3 18 Notwithstanding these objections, Rockbestos responds: il
19 !!
20 |S
Rockbestos has maintained a Certificate of Authority to
!I :
21 j: do business in California from January 29, 1981 to the present
22 j I
i
23 i ! 24
date.
.
.
Response to interrogatory No. 5:
25
26 See Preliminary Statement and General Objections. 27 Rockbestos further objects to this interrogatory on the grounds 28
i
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1 that it is overbroad, burdensome and oppressive. Notwithstanding 2 j these objections, Rockbestos responds:
3i j4 i J
Rockbestos has never had a department, division,
1: subdivision, branch or group specifically responsible for the 5
if 6 [ design, development, manufacture, testing and use of
ji
7 asbestos-containing products. Refer to Response to Interrogatory
e No. 8.
9 10 Response to Interrogatory No. 6:
j 11 j
jj12
See Preliminary Statement and General Objections,
iQ3 IMN 4STREET OAKLAND. fJAUFORNIA 9iOT
13 jj Rockbestos further objects to this interrogatory on the grounds
14 ]| that it is overbroad, burdensome and oppressive. The |j
15 |! interrogatory requests detailed information not reasonably
| calculated to lead to the discovery of admissible evidence and 16
17 | which falls outside the scope of this litigation. > I 0 IB | Notwithstanding these objections, Rockbestos responds:
il 19 I !
j1 20 1
!*
21 i
No.
-
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-
22 ji
Response to Interrogatory No- 7:
23 1 !
!!
24 1|
. See Preliminary Statement and General Objections.
il
25 ji Rockbestos further objects to this interrogatory on the grounds
'1 26 j' that it is overbroad, burdensome and oppressive. The
27
I ! interrogatory requests detailed information not reasonably
28 | calculated to lead to the discovery of admissible evidence and
7
1 which falls outside the scope of this litigation. 2 Notwithstanding these objections, Rockbestos responds:
3
4
5 6 Response to Interrogatory No. 8:
7
8 See Preliminary Statement and General Objections. The 9 subparts of this interrogatory request information so burdensome 10 to ascertain, as to be unjust, harassing, annoying and oppressive 11 because the information relates to numerous products manufactured 12 during a 61 year period and the request is not limited to 13 products allegedly used by plaintiff/plaintiff's decedent or 14 allegedly sold and/or supplied to plaintiff's/plaintiff's
15 decedent's employers during the period of plaintiff's/plaintiff's 16 decedent's employment. In addition, the interrogatory requests
17 detailed information not reasonably calculated to lead to the
18 discovery of admissible evidence and which falls outside the
19 scope of this litigation. Notwithstanding these objections,
20 Rockbestos responds:
21
22 Plaintiff has not established that
23 plaintiff/plaintiff's decedent utilized any product manufactured
24 by Rockbestos. Rockbestos will attempt to provide all known,
25 pertinent information for products identified by
26 |! plaintiff/plaintiff's decedent.
27 !i
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28 ij
a. Since 1930 Rockbestos has manufactured and marketed
;
8
1 wire and cable products, some of which contained encapsulated and
2 saturated asbestos. These products included: apparatus and
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j3 motor lead wire, appliance and fixture wire, control cable, power
j4 cable, switchboard wire, high temperature wire, furnace and mud
!
5 gun cable, shipboard cable and instrumentation cable, and may
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6 also have been referenced by National Electric Code and other
7 specifications and designations. Rockbestos utilized various
6 brand names and trademarks during this period, including, 9 Firezone, Firewall, Rocktherm, Pyrotrol, Phosroc, Cryozone and
10 H-Zone;
11
12 b. - c. Refer to Response to Interrogatory No. 8 a.;
13
14 Some of the following wire and cable products contained
15 encapsulated and saturated asbestos during the indicated periods.
16
17 Wire/Cable Products
Approx. Dates of Manufacture
18
19 Apparatus wire
1936 to 1985
20 Motor lead wire
1930 to 1985
21 Appliance and fixture wire
1930 to 1985
22 Control cable
1930 to 1985
23 Power cable 24 Switchboard wire * 25 High temperature wire 26 Furnace and mud gun cable 27 Shipboard cable 28 Instrument cable
1930 to 1985 1930 to 1985 1938 to 1985 1974 to 1980 1930 to 1979 1930 to 1977
9
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1
d. (i)-(iii) It would be unduly burdensome to provide the
2 chemical composition of each such product because Rockbestos
3 manufactured many different wire and cable products during the
4 sixty-one year period and the percentage of asbestos utilized in
5 each product varied broadly over time and with the size of the
wire and cable. To the extent possible, Rockbestos will atter.pt
7 to provide this information for products to which
8 plaintiff/plaintiff's decedent alleges exposure. Rockbestos used 9 ii only chrysotile asbestos in manufacturing wire and cable products
10 with insulation containing encapsulated and saturated asbestos.
OAKLAND. CMirO*1NA
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12
The following are examples:
S T R flt
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Yn
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YEAR 1981
er. 11
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* 16
Product
4 0 .1 N
17 #14 Firezone 101 > D 18 (High Temperature TAGT)
19 Components 20 Nickel clad conductor
% 47.4
21 Teflon tape 22 Teflon coated glass yarn 23 Teflon finish compound 24 Glass yarn 25 Silicone and resin finish compounds 26 Lap: Asbestos 27 Other non asbestos components 28
9.3 13.0
1.6 4.99.7 12,1 2.0
10
1 YEAR: 1979
2
3 Product:
4 #14 AVA
5 Components
6 Copper conductor
7 Tape
.
8 Mylar 9 Saturant 10 Varnished cambric tape 11 Lap and yarn: Asbestos 12 Other non-asbestos components
13 14 YEAR: 1981:
15 16 Product
17 #8 AVA 18 Components
.
.
19 Copper conductor
20 Nomex tape
21 Mylar
22 Varnished cambric tape
23 Saturant 24 Lap and yarn: Asbestos 25 Other non-asbestos components 26
27
28 e. Wire and cable;
11
% 55.5
.5
29.5 12.8 23.6
4.1
% 55.5
.4 .5 9.2 18.4 13.4 2.4
; .7]
i
1 f. It would be unduly burdensome to provide a 2 description of the physical appearance and nature of each
3 product. To the extent possible, Rockbestos will attempt to 4 provide this information for products to which
5 plaintiff/plaintiff1s decedent alleges exposure. The wire and
6 cable products generally did not have any external markings,
7 although the boxes, spools or reels containing the products
e generally were marked or tagged with the names Cerro or
9 Rockbestos, the brand or trade names Firezone, Firewall,
10 Rocktherm, Pyrotrol, Phosroc, Cryozone or H-Zone, an hourglass
11 within a circle or other distinctive markings. In general, wire
12 and cable products were marked internally with marker threads;
13
14 g. It would be unduly burdensome to provide a
15 detailed description of the intended use of each product. To the
16 extent possible, Rockbestos will attempt to provide this
17 information for products to which plaintiff/plaintiff's decedent
18 alleges exposure. The intended use of wire and cable products
19 with insulation containing encapsulated and saturated asbestos is
20 in those applications requiring resistance to high temperature
21 and flame, and as required in military, government and trade
22 specifications for certain wire and cable construction; 23
24 h. - i. The suppliers of asbestos containing products
25 include:
`
26 1. Raybestos-Manhattan Corp. 27 Products: Lap, roving yarn. 26 Oates: 1945-1986
12
1 2. Amatex Corp. 2 Products: Roving yarn. 3 Dates: 1976-1986 4 3. Harco chemical 5 Products: Cable filler 6 Dates: 1950-1986 7 4. Manning Paper Co. B Products: S.A. Asbestos tape 9 Dates: 1970-1986 10 5. Facile Div. Sun Chemical Corp. 11 Products: AM - Asbestos Mylar Tape 12 Dates: 1970-1986 13 6. Johns-Manville Corp. 14 Products: AM - Asbestos Mylar Tape IS Dates: 1976-1986 16 17 j. Currently unknown, but investigation is continuing. 16 19 Response to Interrogatory Mo. 9: 20 21 See Preliminary Statement and General Objections. 22 Rockbestos further objects to this interrogatory on the grounds 23 that it is overbroad, burdensome and oppressive. The 24 interrogatory requests detailed information not reasonably
25 calculated to lead to the discovery of admissible evidence and 26 which falls outside the scope of this litigation. 27 Notwithstanding these objections, Rockbestos responds: 28 No.
13
1 Response to Interrogatory Mo. 10: 2 3 See Preliminary Statement and General Objections. 4 Rockbestos further objects to this interrogatory on the grounds 5 that it is overbroad, burdensome and oppressive. The 6 interrogatory requests detailed information not reasonably 7 calculated to lead to the discovery of admissible evidence and 6 which falls outside the scope of this litigation. Notwithstanding 9 these objections, Rockbestos responds: 10 11 No. 12 13 Response to interrogatory No. li:
14 15 See Preliminary Statement and General Objections. 16 Rockbestos further objects to this interrogatory on the grounds 17 that it is overbroad, burdensome and oppressive. The 18 interrogatory requests detailed information not reasonably 19 calculated to lead to the discovery of admissible evidence and 20 which falls outside the scope of this litigation. 21 Notwithstanding these objections, Rockbestos responds: 22 23 No. 24
25 Response to Interrogatory No. 12;
26 27 See Preliminary Statement and General Objections. 28 Rockbestos further objects to this interrogatory on the grounds
14
1 that it is overbroad, burdensome and oppressive. The 2 interrogatory requests detailed information not reasonably 3 calculated to lead to the discovery of admissible evidence and 4 which falls outside the scope of this litigation. 5 Notwithstanding these objections, Rockbestos responds:
6 7 No.
8 9 Response to Interrogatory No. 13:
10 11 See Preliminary Statement and General Objections. 12 Rockbestos further objects to this interrogatory on the grounds 13 that it is overbroad, burdensome and oppressive. The 14 interrogatory requests detailed information not reasonably
15 calculated to lead to the discovery of admissible evidence and
16 which falls outside the scope of this litigation. 17 Notwithstanding these objections, Rockbestos responds:
18
19 No.
20
21 Response to Interrogatory No. 14:
22
23 See Preliminary Statement and General Objections.
24 Rockbestos further objects to this interrogatory on the grounds
25 that it is overbroad, burdensome and oppressive. The
26 interrogatory requests detailed information not reasonably
27 calculated to lead to the discovery of admissible evidence and
28 which falls outside the scope of this litigation.
'
15
1 Notwithstanding these objections, Rockbestos responds:
2 3 Currently unknown, but investigation is continuing.
4 5 Response to Interrogatory Mo, 15:
6 7 See Preliminary Statement and General Objections. 8 Rockbestos further objects to this interrogatory on the grounds 9 that it is overbroad, burdensome and oppressive. The 10 interrogatory requests detailed information not reasonably 11 calculated to lead to the discovery of admissible evidence and 12 which falls outside the scope of this litigation.
13 Notwithstanding these objections, Rockbestos responds:
14
15 285 Nicoll Street
16 New Haven, Connecticut 06504
17
18
Response to Interrogatory Wo. 16:
_
19
20 See Preliminary Statement and General Objections.
21 Rockbestos further objects to this interrogatory on the grounds
22 that it is overbroad, burdensome and oppressive. The
23 interrogatory requests detailed information not reasonably 24 calculated to lead to the discovery of admissible evidence and 25 which falls outside the scope of this litigation.
26 Notwithstanding these objections, Rockbestos responds: 27
28 a. Approximately 1920;
16
1 b. They continue to operate today? 2 c. Refer to Response to Interrogatory No. 8.
3 4 Response to interrogatory Ko. 17;
5 6 See Preliminary Statement and General Objections. 7 Rockbestos further objects to this interrogatory on the grounds
6 that it is overbroad, burdensome and oppressive. The 9 interrogatory requests detailed information not reasonably 10 calculated to lead to the discovery of admissible evidence and 11 which falls outside the scope of this litigation. 12 Notwithstanding these objections, Rockbestos responds:
13 14 Currently unknown, but investigation is continuing.
15 16 Response to Interrogatory No. 18t
17
18 See Preliminary Statement and General Objections.
19 Rockbestos further objects to this interrogatory on the grounds
20 that it is overbroad, burdensome and oppressive. The
21 i interrogatory requests detailed information not reasonably |
22 i calculated to lead to the discovery of admissible evidence and
23 j which falls outside the scope of this litigation.
1 24 | Notwithstanding these objections, Rockbestos responds:
25 ii i
26 j
a. - g.
February 7, 1967;
Patent # 3,303,270
i`
27 i
28
! 17
1 Response to interrogatory No. .19;
2 3 See Preliminary Statement and General Objections. 4 Rockbestos further objects to this interrogatory on the grounds
5 that it is overbroad, burdensome and oppressive. The 6 interrogatory requests detailed information not reasonably 7 calculated to lead to the discovery of admissible evidence and
.
i
I
8 which falls outside the scope of this litigation. In addition,
9 this information is equally available to plaintiffs by inquiry to
10 the United States Patent and Trademark Office in Washington, D.C.
11 Notwithstanding these objections, Rockbestos responds:
12
13 Refer to Response to Interrogatory No. 8 for trademark
14 names, other information is currently unknown, but investigation
15 is continuing.
16
17 Response to Interrogatory No. 20:
16
19 See Preliminary Statement and General Objections.
20 Rockbestos further objects to this interrogatory on the grounds
21 that it is overbroad, burdensome and oppressive. The 22 interrogatory requests detailed information not reasonably
23 calculated to lead to the discovery of admissible evidence and 24 which falls outside the scope of this litigation. 25 Notwithstanding these objections, Rockbestos responds: 26
27 No. 28
If
18
1 Response to Interrogatory Ko. 21s 2 3 See Preliminary Statement and General Objections. 4 Rockbestos further objects to this interrogatory on the grounds 5 that it is overbroad, burdensome and oppressive. The 6 interrogatory requests detailed information not reasonably 7 calculated to lead to the discovery of admissible evidence and 8 which falls outside the scope of this litigation. 9 Notwithstanding these objections, Rockbestos responds: 10 11 Currently unknown, but investigation is continuing. 12 13 Response to Interrogatory Mo. 22:
14 15 See Preliminary Statement and General Objections. 16 Rockbestos further objects to this interrogatory on the grounds 17 that it is overbroad, burdensome and oppressive. The 18 interrogatory requests detailed information not reasonably 19 calculated to lead to the discovery of admissible evidence and 20 which falls outside the scope of this litigation. 21 Notwithstanding these objections, Rockbestos responds: 22 23 a. A compilation of sales data for the period 19S1 to 24 1985 is maintained by Rockbestos. Pre-1980 sales records and 25 data for California are not in existence with the exception of 26 some records reflecting sales of wire and cable products, some of
27 which contained encapsulated and saturated asbestos, to nuclear 28 power plants;
19
1 b. The Rockbestos Company, 285 Nicoll Street, New 2 Haven Connecticut, 06504;
3 4 c. Edward Randall.
5
6 Response to Interrogatory Ho. 23:
:
7 iI lI
8
See Preliminary Statement and General Objections.
j
9 Rockbestos further objects to this interrogatory on the grounds
10 that it is overbroad, burdensome and oppressive. The
11 interrogatory requests detailed information not reasonably
12 calculated to lead to the discovery of admissible evidence and
13 which falls outside the scope of this litigation.
14 Notwithstanding these objections, Rockbestos responds:
15 16 Numerous uncatalogued documents responsive to this 17 request are maintained at The Rockbestos Company, 285 Nicoll
18 Street, New Haven, Connecticut 06504 and arrangements may be made
19 to inspect these documents at that location.
20
21 Response to Interrogatory No. 24:
22
23 See Preliminary Statement and General Objections.
24 Rockbestos further objects to this interrogatory on the grounds
25 that it is overbroad, burdensome and oppressive. The
26 interrogatory requests detailed information not reasonably 27 calculated to lead to the discovery of admissible evidence and
28 which falls outside the scope of this litigation.
|
20
1 Notwithstanding these objections, Rockbestos responds:
2
3 Numerous uncatalogued documents responsive to this
4 request are maintained at The Rockbestos Company, 285 Nicoll
5 Street, New Haven, Connecticut 06504 and arrangements may be made
6 to inspect these documents at that location.
7 8 Response to interrogatory No. 25i
i \ L
9
so See Preliminary Statement and General Objections. 11 Rockbestos further objects to this interrogatory on the grounds 12 that it is overbroad, burdensome and oppressive. The 13 interrogatory requests detailed information not reasonably
14 calculated to lead to the discovery of admissible evidence and
15 which falls outside the scope of this litigation.
16 Notwithstanding these objections, Rockbestos responds:
17
18 a. The Rockbestos -Company, 285 Nicoll Street, New
19 Haven, Connecticut, 06504;
20 b. Edward Randall.
21
22 Response to interrogatory No. 26;
23
24 See Preliminary Statement and General Objections. 25 Rockbestos further objects to this interrogatory on the grounds 26 that it is overbroad, burdensome and oppressive. The 27 interrogatory requests detailed information not reasonably 28 calculated to lead to the discovery of admissible evidence and
|
21
1 which falls outside the scope of this litigation. 2 Notwithstanding these objections, Rockbestos responds: 3 4 Not applicable. 5 6 Response to Interrogatory No. 27; 7 e See Preliminary Statement and General Objections. 9 Rockbestos further objects to this interrogatory on the grounds 10 that it is overbroad, burdensome and oppressive. The 11 interrogatory requests detailed information not reasonably 12 calculated to lead to the discovery of admissible evidence and 13 which falls outside*the scope of this litigation. 14 Notwithstanding these objections, Rockbestos responds: 15 16 Not applicable. 17 18 Response to Interrogatory No. 2B; 19 20 See Preliminary Statement and General Objections. The 21 interrogatory requests detailed information not reasonably 22 calculated to lead to the discovery of admissible evidence and 23 ; which falls outside the scope of this litigation. In addition, 24 j the information sought is so burdensome to ascertain as to be 25 | unjust, harassing, annoying and oppressive because it relates to 26 ; numerous products manufactured during a 61 year period and is not
!'
27 i limited to products allegedly used by plaintiff/plaintiff's 23 j decedent or allegedly sold and/or supplied to
22
1 plaintiff's/plaintiff's decedent's employer during the period of
2 plaintiff's/plaintiff's decedent's employment. Notwithstanding 3 these objections, Rockbestos responds:
4
5
Rockbestos is without sufficient information to
j
6 describe each package or container which contained products sold \
7 and/or distributed by Rockbestos. Over the years the containers
8 consisted of boxes, spools, or reels in various materials,
9 dimensions, shapes and colors which were marked or tagged with *
10 the names Cerro or Rockbestos, or the brand or trade names
11 previously identified.
12 13 Plaintiff has not established that
14 plaintiff/plaintiff's decedent utilized any product manufactured
16 by Rockbestos, Rockbestos will attempt to provide all known,
16 pertinent information for products identified by
17 plaintiff/plaintiff's decedent.
18
19 Response to Interrogatory No. 29i
20
21 See Preliminary Statement and General Objections. The
22 interrogatory requests detailed information not reasonably
23 calculated to lead to the discovery of admissible evidence and
24 which falls outside the scope of this litigation. In addition,
25 the information sought is so burdensome to ascertain as to be
26 unjust, harassing, annoying and oppressive because it relates to 27 numerous products manufactured during a 61 year period and is not 28 limited to products allegedly used by plaintiff/plaintiff's
23
1 decedent or allegedly sold and/or supplied to 2 plaintiff's/plaintiff's decedent's employer during the period of 3 plaintiff's/plaintiff's decedent's employment. Notwithstanding 4 these objections, Rockbestos responds: 5 6 Rockbestos is without sufficient information to 7 describe each product's logo, design, marking or printing. 6 During the defined time period packaging or containers for 9 Rockbestos products, some of which contained encapsulated and 10 saturated asbestos, included boxes, spools, or reels which were 11 marked or tagged with the names Cerro or Rockbestos, the brand or 12 trade names Firezone, Firewall, Rocktherm, Ryrotrol, Phosroc, 13 Cryozone or H-zone, an hourglass within a circle or other 14 distinctive markings. 15 16 Plaintiff has not established that 17 plaintiff/plaintiff-'s decedent utilized any product manufactured 16 by Rockbestos. Rockbestos will attempt to provide all known, 19 pertinent information for products identified by 20 plaintiff/plaintiff's decedent. 21 22 Response to Interrogatory No. 30: 23 24 See Preliminary Statement and General Objections. 25 Rockbestos further objects to this interrogatory on the grounds 26 that it is overbroad, burdensome and oppressive. The 27 interrogatory requests detailed information not reasonably 28 calculated to lead to the discovery of admissible evidence and
24
1 which falls outside the scope of this litigation.
2 Notwithstanding these objections, Rockbestos responds; 3 4 a. - b. Examples of packaging or containers
5 substantially similar to those utilized by Rockbestos during the
6 defined time period may be inspected at the Rockbestos Company, 7 285 Nicoll Street, New Haven Connecticut 06504; 8 9 c. Edward Randall. 10 11 pesp<?.ne to itterrpgatorY.ijrffj, ju 12 13 See Preliminary Statement and General Objections. 14 Rockbestos further objects to this interrogatory on the grounds 15 that it is overbroad, burdensome and oppressive. The
16 interrogatory requests detailed information not reasonably
17 calculated to lead to the discovery of admissible evidence and 18 which falls outside the scope of this litigation. 19 Notwithstanding these objections, Rockbestos responds: 20 21 Not applicable. 22 23 Response to Interrogatory No. 32: 24 25 See Preliminary Statement and General Objections. 26 Rockbestos further objects to this interrogatory on the grounds 27 that it is overbroad, burdensome and oppressive. The 28 interrogatory requests detailed information not reasonably
25
1 calculated to lead to the discovery of admissible evidence and 2 which falls outside the scope of this litigation. This 3 interrogatory incorrectly assumes that wire and cable products; 4 with insulation containing encapsulated and saturated asbestos, 5 were hazardous. Notwithstanding these objections, Rockbestos responds: 7 e a. - c. A warning was included between 1979 and 1986. 9 Refer to Exhibit 1; Between 1979 and 1986 a warning was included 10 on all boxes, spools or reels of cable and wire products ii containing insulation with encapsulated and saturated asbestos. 12 13 Response to Interrogatory No. 33: 14 15 See Preliminary Statement and General Objections. 16 Rockbestos further objects to this interrogatory on the grounds 17 that it is overbroad, burdensome and oppressive. The 18 interrogatory requests detailed information not reasonably 19 calculated to lead to the discovery of admissible evidence and 20 which falls outside the scope of this litigation. In addition, 21 this interrogatory incorrectly assumes that wire and cable 22 products, with insulation containing encapsulated and saturated 23 asbestos, were hazardous. Notwithstanding these objections, 24 Rockbestos responds: 25 26 No such brochures or pamphlets relating to Rockbestos 27 products were distributed. 28
26
1 Response to Interrogatory No. 34 2 3 See Preliminary Statement and General Objections. 4 Rockbest-os further objects to this interrogatory on the grounds 5 that it is overbroad, burdensome and oppressive. The 6 interrogatory requests detailed information not reasonably 7 calculated to lead to the discovery of admissible evidence and 8 which falls outside the scope of this litigation. 9 Notwithstanding these objections, Rockbestos responds: 10 11 Rockbestos has never had contract units. Refer to 12 Response to Interrogatory No. 32, a. - c. relating to warnings. 13 14 Response to Interrogatory No. 3St
15 16 See Preliminary Statement and General Objections. 17 Rockbestos further objects to this interrogatory on the grounds 18 that it is overbroad, burdensome and oppressive_ The 19 interrogatory requests detailed information not reasonably 20 calculated to lead to the discovery of admissible evidence and 21 which falls outside the scope of this litigation. Notwithstanding 22 these objections, Rockbestos responds: 23 24 Not as far as is currently known, but investigation is 25 continuing. 26 27 28
27
1 Response to interrogatory No. 36:
i
2i i
3
See Preliminary Statement and General Objections.
|
4 Rockbestos further objects to this interrogatory on the grounds
5 that it is overbroad, burdensome and oppressive. The
6 interrogatory requests detailed information not reasonably
7 calculated to lead to the discovery of admissible evidence and
e which falls outside the scope of this litigation. 9 Notwithstanding these objections, Rockbestos responds:
10 11 None.
12 13 Response to interrogatory No. 37:
14
15 See Preliminary Statement and General Objections.
16 Rockbestos further objects to this interrogatory on the grounds
17 that it is overbroad, burdensome and oppressive. The
18 interrogatory requests detailed information not .reasonably
19 calculated to lead to the discovery of admissible evidence and
20 which falls outside the scope of this litigation.
21 Notwithstanding these objections, Rockbestos responds:
22
23 (i) b. IHF 1987 to currently unknown,
24 h. AIA 1979 to 1982. 25
26 Response to interrogatory No. 38:
27
28 See Preliminary Statement and General Objections.
28
1 Rockbestos further objects to this interrogatory on the grounds
2 that it is overbroad, burdensome and oppressive. The
3 interrogatory requests detailed information not reasonably 4 calculated to lead to the discovery of admissible evidence and
5 which falls outside the scope of this litigation. 6 Notwithstanding these objections, Rockbestos responds:
7
6 a. Refer to Response to Interrogatory No. 37;
9
10 b. - c. Currently unknown, but investigation is
11 continuing.
12
13 Response to Interrogatory Ho. 39;
14
15 See Preliminary Statement and General Objections,
16 Rockbestos further objects to this interrogatory on the grounds
17 that it is overbroad, burdensome and oppressive. The
18 interrogatory requests detailed information not reasonably
19 calculated to lead to the discovery of admissible evidence and
20 which falls outside the scope of this litigation.
21 Notwithstanding these objections, Rockbestos responds:
22
23 No such documents were received by Rockbestos on or 24 near the dates of their dissemination by the Saranac Laboratory 25 at the Trudeau Foundation. 26
27 a. Not applicable; 28
29
1 b. - c. Currently unknown/ but investigation is 2 continuing;
3 4 Response to Interrogatory No. 40: 5 6 See Preliminary Statement and General Objections. 7 Rockbestos further objects to this interrogatory on the grounds
8 that it is overbroad, burdensome and oppressive. The 9 interrogatory requests detailed information not reasonably 10 calculated to lead to the discovery of admissible evidence and 11 which falls outside the scope of this litigation. 12 Notwithstanding these objections, Rockbestos responds:
13 14 No. 15 16 Response to Interrogatory Ko. 41: 17 18 See Preliminary Statement and General Objections. 19 Rockbestos further objects to this interrogatory on the grounds 20 that it is overbroad, burdensome and oppressive. The 21 interrogatory requests detailed information not reasonably 22 calculated to lead to the discovery of admissible evidence and 23 which falls outside the scope of this litigation. 24 Notwithstanding these objections, Rockbestos responds:
25 26 No. 27 28
30
1
Response to Interrogatory
42:
2 3 See Preliminary Statement and General Objections. 4 Rockbestos further pbjects to this interrogatory on the grounds 5 that it is overbroad, burdensome and oppressive. The 6 interrogatory requests detailed information not reasonably 7 calculated to lead to the discovery of admissible evidence and
e which falls outside the scope of this litigation. 9 Notwithstanding these objections, Rockbestos responds:
10 ii No.
12 13 Response to Interrogatory No. 43:
14
15 See Preliminary statement and General Objections.
16 Rockbestos further objects to this interrogatory on the grounds
17 that it is overbroad, burdensome and oppressive. The
18 interrogatory requests detailed information not reasonably
19 calculated to lead to the discovery of admissible evidence and
20 which falls outside the scope of this litigation.
21
22 Response to Interrogatory No. 44:
23
24 See Preliminary Statement and General Objections. 25 Rockbestos further objects to this interrogatory on the grounds 26 that it is overbroad, burdensome and oppressive. The 27 interrogatory requests detailed information not reasonably 28 calculated to lead to the discovery of admissible evidence and
31
1 which falls outside'the scope of this litigation. 2 Notwithstanding these objections, RocJcbestos responds:
3 4 No. 5 6 Response to Interrogatory No. 45: 7
6 See Preliminary Statement and General Objections. 9 RocJcbestos further objects to this interrogatory on the grounds 10 that it is overbroad, burdensome and oppressive. The 11 interrogatory requests detailed information not reasonably 12 calculated to lead to the discovery of admissible evidence, is 13 violative of the critical self-evaluation privilege and which 14 falls outside the scope of this litigation.
15 16 Response to Interrogatory No. 47: 17 18 See Preliminary Statement and General ..Objections, 19 RocJcbestos further objects to this interrogatory on the grounds 20 that it is overbroad, burdensome and oppressive. The 21 interrogatory requests detailed information not reasonably 22 calculated to lead to the discovery of admissible evidence and 23 which falls outside-the scope of this litigation. 24 Notwithstanding these objections, RocJcbestos responds: 25 26 Refer to Response to Interrogatory No. 32, a. - c. 27 28
32
1 Response to Interrogatory o. 48: 2 3 See Preliminary Statement and General Objections. 4 Rockbestos further objects to this interrogatory on the grounds 5 that it is overbroad, burdensome and oppressive. The 6 interrogatory requests detailed information not reasonably 7 calculated to lead to the discovery of admissible evidence and B which falls outside the scope of this litigation. 9 Notwithstanding these objections, Rockbestos responds:
10 11 No. 12
13 Response to Interrogatory No. 49;
14 15 See Preliminary Statement and General Objections. 16 Rockbestos further objects to this interrogatory on the grounds 17 that it is overbroad, burdensome and oppressive. The 18 interrogatory requests detailed information not reasonably 19 calculated to lead to the discovery of admissible evidence and 20 which falls outside the scope of this litigation. 21 Notwithstanding these objections, Rockbestos responds: 22 23 No. 24
25 Response to Interrogatory Mo. SO:
26 27 See Preliminary Statement and General Objections. 28 Rockbestos further objects to this interrogatory on the grounds
33
1 that it is overbroad, burdensome and oppressive. The 2 interrogatory requests detailed information not reasonably 3 calculated to lead to the discovery of admissible evidence and 4 which falls outside the scope of this litigation. 5 Notwithstanding these objections, Rockbestos responds:
; .
6 i
7 Rockbestos has received numerous written communications | i
8 relating to lawsuits in which such allegations have purportedly j
been made. 9
j
10 11 Rockbestos is currently unable to identify the first 12 such written communication, but investigation is continuing.
13 14 Response to Interrogatory o. 51;
15
16 See Preliminary Statement and General Objections.
17 Rockbestos further objects to this interrogatory on the grounds
18 that it is overbroad, burdensome and oppressive. The
19 interrogatory requests detailed information not reasonably
20 calculated to lead to the discovery of admissible evidence and
21 which falls outside the scope of this litigation. 22 Notwithstanding these objections, Rockbestos responds:
23 24 Yes
25
26 a. - f. Currently unknown, but investigation is 27 continuing. 28
i
34
1 Response to Interrogatory No. 52: 2 3 See Preliminary Statement and General Objections. 4 Rockbestos further objects to this interrogatory on the grounds 5 that it is overbroad, burdensome and oppressive. The 6 interrogatory reguests detailed information not reasonably 7 calculated to lead to the discovery of admissible evidence and 8 which falls outside the scope of this litigation. 9 Notwithstanding these objections, Rockbestos responds:
10 11 Yes. 12 13 a. - f. Currently unknown, but investigation is 14 continuing. 15
16 Response to Interrogatory No. 53:
17
18 See Preliminary Statement and General Objections. 19 Rockbestos further objects to this interrogatory on the grounds 20 that it is overbroad, burdensome and oppressive. The 21 interrogatory requests detailed information not reasonably 22 calculated to lead to the discovery of admissible evidence and 23 which falls outside the scope of this litigation. 24 Notwithstanding thefee objections, Rockbestos responds:
25 26 27
28
35
i I
j
A f T O N t > l AW
4 0 3 N th il , .E C T O A K L A M O . C A tltO W N IA **S O *
l
1 i;
Rockbestos contends it had general liability coverage
2 for the relevant time periods; the extent and application of
3 insurance coverage is currently disputed.
4 5 1930 - 1943, unknown; 6 1943 - 1959, Travelers; 7 1959 - 1976, Liberty Mutual;
8 1/1/76 - 9/1/76, Home;
9 9/1/76- Present, Self insured.
10
11 Response to interrogatory No. 54; .
12 13 See Preliminary Statement and General Objections. 14 Rockbestos further objects to this interrogatory on the grounds
15 that it is overbroad, burdensome and oppressive. The 16 interrogatory requests detailed information not reasonably 17 calculated to lead to the discovery of admissible evidence and
18 which falls outside the scope of this litigation-.
19 i i Notwithstanding these objections, Rockbestos responds:
i'
20 '
21 No.
22 . I
23
24 :
Response to Interrogatory Mo. 55:
25 :
See Preliminary Statement and General Objections.
26 ! Rockbestos further objects to this interrogatory on the grounds
27 that it is overbroad, burdensome and oppressive. The
28 interrogatory requests detailed information not reasonably
36
1 calculated to lead to the discovery of admissible evidence and 2 which falls outside the scope of this litigation. 3 Notwithstanding these objections, Rockbestos responds:
4 5 No. 6
7 Response to Interrogatory I?o^ _56:
8 9 See Preliminary Statement and General Objections. 10 Rockbestos further objects to this interrogatory on the grounds 11 that it is overbroad, burdensome and oppressive. The 12 interrogatory requests detailed information not reasonably 13 calculated to lead to the discovery of admissible evidence and 14 which falls outside the scope of this litigation. 15 Notwithstanding these objections, Rockbestos responds:
16 17 No.
18
19 Response to interrogatory Mo. 57:
20
21 See Preliminary Statement and General Objections. 22 Rockbestos further objects to this interrogatory on the grounds 23 that it is overbroad, burdensome and oppressive. The 24 interrogatory requests detailed information not reasonably 25 calculated to lead to the discovery of admissible evidence and 26 which falls outside the scope of this litigation.
I 27
!
28 i{ i \ \i i 37
1 | Notwithstanding these objections, Rockbestos responds:
2!
` NO.
3
4
!
5j
6
DATED: May 20, 1991
7
8 BJORK, FLEER & LAWRENCE
9
By. . 1C l--
10 Dorine R. Kohn
11 Attorneys for Defendant The Rockbestos Company
12
13
14
f
15
16
17
18
19
20
l
21
22
23
24
25
26
27
28
38
CAUTION
{ CAL TION
CONTAINS .ttSYOS Mtu 1 AVOID C- JLTJN6 OUST IIIUTHINO A *170$ DUST MAT I CAUSI SHU *0DIU HAtM
CAUTION
: CONTAINS A ESTOS FIBERS AVOID CR-,flNG DUST
BREATHING ASBESTOS DUST MAT CAUSE - : SERIOUS BODILY MBM ~ j
S^^^SSSi-Bj aiS.B ixH: BUS*.iB. -a. iBaBa--jA--UT7AT
CAUTION
. CONTAINS ASBESTOS FIBERS . AVOID CREATING DUST ' BREATHING ASBESTOS DUST MAY. CAUSE
SERIOUS BODILY HARM
* ar
CAUTION
! CONTAINS ASBESTOS FIBERS ! AVOID CREATING DUST BREATHING ASBESlpS DUST MAY : 'CAUSE SERIOUS BODILY HARM
I I
I
1
a
"EXHIBIT 1"
A
w * ^
cv,u:
(Labels Reduced In Size)
vzmricATioif 1
2 s/
\
X, George G. Littlehales, am the Quality Assurance
3
4 Manager for The RocXbestoa Company, a party in the above-entitled
5 action, ind t such aa author!iad to maXe the following
e verification. X have read tha foregoing MXSVOksbs to general
7 OIDBB >0. 30.00 ITAKhAJtD P1AIXTJTT5' IHTZRXOGATORIES and K-r.v th
a eontsnts thereof. Mo single official, employee, or former
kv employee of Tbs StocXhestos Company baa personal Knowledge of all
10 such matters. The information contained herein has beer, compiled
11 at ay diractlon by eounsei for The RocXbestos Company'. t 3r. 12 informed and believe all the responses are true and verify the
13 responses on that basis.
..
14
15 I declare under penalty of perjury under the lavs of the
15 State of California that the foregoing Answers are
na
17 correct, Insofar as it is possible to verify then.
15 19 Executed this 20 Haven, Connecticut*
day of Kay, i&fci, at New
21
22 ________ George littleHales
23
24
25 25 27
1 PROOF OF SERVICE BY MAIL 2 (C.C.P. 1013, 2015.5)
3 I an a citizen of the United States and a resident of
::
4 !Klaipeda County. I am over the age of eighteen years and not a
]j
5.
Fl |party
to
the
within
action;
my
business
address
is
483
Ninth
6 (street, Oakland, California 94607.
7
6 j|
On the date below, I served this The Rockbestos
Ii
9 jpompany's Responses To General Order 30.00 Interrogatories by
10 (placing a true copy thereof enclosed in a sealed envelope with
11
I| I' ;postage thereon fully prepaid, in the United States mail at
12
!j
jpakland, Alameda County,
California, addressed as follows:
13
t A1 *M n 3 P Q l 1 4
4 3 *tM S T B U t
O A K L A N D . C A L ltO ^ N fA 9 ^ 6 0 ^
rS AT LAW
At1
14 SEE ATTACHED LIST(S)
15
!i
i
|i ;:
16 j;
I declare under penalty of perjury that the above is
17 M jltrue and correct.
.
18 j
19 i;
20
Executed at Oakland, California on May 24, 1991.
21
22 23
iOiFt. IL
24 David W. Shelley g
25
26 27
2B
IN RE COMPLEX ASBESTOS LITIGATION - ALAMEDA COUNTY DEFENSE COUNSEL SERVICE LIST
Otis McGee, Jr., Esq. Marty Everson, Esq. Anderson, Galloway ( Lucchese 1676 w. California Blvcf, Ste. 500 Walnut Creek, CA 94596-4642
Attorneys for: Babcock i Wilcox Company
Rand Chritton, Esq.
Archer, McComas 1 cegescn
2033 N. Main Street, Suite 800
P.O. Box 8035
walnut Creek, CA 94596
Attorneys for: Carliisle/ualdron Duffy
Elaine McMahan, Esq. Berry t Berry Station 0 P.O. Box 70250 Oakland, CA 94612-0250
lesignated Defense Counsel
Maureen Brooks, Esq. Bennett, Samuelsen, Reynolds
8 Allard 1951 Webster St., Ste. 200 Oakland, CA 94612-2909
Attorneys for: US Mineral Prod. Co./ Dinwiddie Construction/ World Wide Trading/ worth American Refractories Co.
henry D. Rome, Esq. Branson, Fitzgerald 8 Howard 643 Bair Island Road, Suite 400 P.O. Box 2189 Redwood City, CA 94064
Attorneys for: Svnkcloid Company
Bronson, Bronson 8 McKinnon 100 B Street, Ste. 400 Santa Rosa, CA 95401
Attorneys for: Sacomo-Sierra/ Sacomo Mfo./Parker-Hannifin/ Airco Ueld
Kathleen Farley, Esq. tumhill, Morehouse, turford,
Schofield 1 Schiller 1220 Oakland Blvd., Ste. 200 P.O. Box 5168 walnut Creek, CA 94596
Attorneys for: Kelly Moore Paint Co.
John Dittoe, Eaq. Croaby, Heafey, Roach 8 May 1999 Harrison Street Oakland, CA 94612
Attorneys for; Worldbestos/toyel >nd./So. Pacific/ Chrvster/Westinohouse/Chevron/Shelt Oil Conoany!Shier lean Motors Corporation
Michael Boltchowski, Esq. Orevlow, Murray 8 Payne 4000 Civic Canter Drive, Suite 209 Ban Rafael, CA 94903
Attorneys for: Plsnt Insulation Co.
Rod Pryor Ericksen, Arbuthnot, Brown,
Kitduff 8 Day toxic Tort litigation Unit 1304 Willow Street Martinet, CA 94553
Attorneys for: Iridflestone/Firestone. Inc./Goodyear Tire 8 Rubber Co./Swioerton 8 Ualbera/ African Biltrite
Floyd White, Eaq. Finan, White 8 Peetzold 150 Spear Street Suite 1725 San Francisco, CA 94105-1541
Attorneys for: Alaska Packers/E.J. IsrteUs/Phetps feodae Corp./Phelps Dodae IntSjstries
Tie Minor, Esq. Cities 8 Nicora 1900 Eabarcadero, Sta. 300 Oakland, CA 94606
Attorneys for: Thiokot Coro.
Tonda Reed, Esq. Glaspy 8 Glaspy 201 NO. Civic Drive, Ste. 245 Walnut Creek, CA 94596
Attorneys for: Gar lock Industrics/CC. t '.nd.f J.T. Thorpe, Inc.
Michael lucty, Esq. Gordon 8 Reas Eabareadero Center west 275 Battery Street, 20th Floor San Francisco, CA 94111
Attorneys for; W.R. Crace-Conn/Bendix (Allied Corp.)/Allied-Sianat tnc.fFoseco. In Rapid-American Coro./unior oil Conoa ef California, d/b/a uwoCal
Paul J. Kill ion, Esq. Hancock, Rothert 8 Bunshoft 4 Eabarcadero Center Suite 1000 San Francisco. CA 94111-4138
Attorneys for: General Cable Coro.
Eugene Brown, Esq. Hardin, Cook, Loper,
Engel 8 Btrgez Lake Merritt Plaza 1999 Harrison Street, 18th Fir. Oakland, CA 94612-3508
Attorneys for: Western MacArthuf/spencer Turbina Conoany
Bill Finney, Esq. Herrington, foxx, Oubrow 8 Canter AT8T Center 611 W. Sixth Street 30th Floor Los Angelas, CA 90017
Attorneys for: Havistar/lnternaticnal Harvester
Phil ward. Esq.
Hsssard, Bonnington, Rogers 4 Huber
5 Fremont Center 50 Fremont Street, Suite 3400 Sen Francisco, CA 94105
Attorneys for: Pirtsbura-Corninc
Nancy E. Hudgins, Esq. 605 Market Street, Suite 700 San Francisco, CA 94105
Attorney for: Uni rove 1
Gabriel A, Jackson, Esq, Jackson, Wallace 4 Hayden 33 New Montgomery Street IBth Floor San Francisco, CA 94105
Attorneys for: Eeale-Picher Ind./Okonite
Andrew Schneider jedeikin, Green, Sprague 4 Bishop 300 Montgomery Street Suite 450 San Francisco, CA 94104-1906
Attorneys for; Ericsson. Inc/Asbestos Coro./ Anaconda/Cook Rubber Company
Willism K. Bissetl, Esq. Kincaid, Gisnunzio,
Caudle 4 Hubert 200 Webster Street, Suite 200 9.0. Box 1S2E Oaklana, CA 94604-0626
Attorneys for: Kaiser Cement/Kaiser Gvosun/Gasket Soecialties/Georae Short Co./Don'tar/ Permanent^ SreaHKhin
Rupert fticksen, Esq. Knox, Ricksen, Snook, Anthony,
Harper 4 Robbins 1999 Harrison Street, Suite 1700 Oakland, CA 94612-3500
Attorneys for: Comb. Ena/Foster wheeler/ S.K. weltman/j.T. Thorpe
Ann Payne, Esq. Landels, Ripley 4 Diamond Hills Plaza 350 Steuart Street San Francisco, CA 94105-1250
Attorneys for: The FIintkote Co.. !nc. Genstar Comoanv/BIue Diamond Corp./ Dow Chemical Company
Vincent McLorg, Esq. KcGlym, McLorg 4 McDowell Bayside Plata 188 Eabareadero #200 San Francisco, CA 94105-1211
Attorneys for: Soro-Uarner/Shell/Stoody Co./ Triple A Machine Shoo
Douglas McClure McNamara, Houston, Dodge, McClure
4 Hey 1211 Newell Avenue, Suite 202 F.O. Box 5266 Walnut Creek, CA 94596
Attorneys for: Anchor Packino Company/ Unirovel/Bendix {Allied Corp.)
jeon Bertrand Morgenstrin 4 Jubelirtr Federal Reserve Sank Building 101 Market Street, Sixth Floor San frenciseo, CA 9410S
Attorneys for: ACands/Owens-Illinois/ Keene
John Krebs, Esq. Periehan, kenberg, Crossman
4 Harvey 2350 west Shaw, Suite 130 Fresno, CA 93711
Attorneys for: General Motors Coro.
Daniel E. Alberti, Esq. Ropers, Majeski, Kohn,
Bentley, Wagner 4 Kane 1001 Marshall Street Redwood City, CA 94063
Attorneys for: Monvitle Trust/Westinohouse Electric
tsrfi
J. Lawrence Judy, Esq. Shield 4 Smith 580 California St., Ste. 1400 San Freneisco, CA 94104
Attorneys for: A.P. Green Refractories.
Af*FV:,ora-U2t.l9UffljTrit11
Inc.. Flexitatlie Gasket. 6A_F. Corp./Center for Claims Resolution
Thoeias J. Friel, Jr. Skjerven, Morrill, MacPherson, Frankl:
4 Friel 601 Montgomery, #1900 San Francisco, CA 94111
Attorneys for: Rome Cable Corp.
trad Thomas, Esq. Stimbos 4 Mason P.0. Box 866 Sacramento. CA 95804
Attorneys for:
fsttWr
Robert E. Paterson, Esq. Sullivan, Roche 4 Johnson 333 tush st,, 18th Floor San Francisco, CA 94104
Attorneys for: Abox Corporation
Allison Gold, Esq. Thelen, Marrin, Johnson 4 Bridges One Kaiser Plate, Suite 1950 Oakland, CA 94612
Attorneys for: Hiser atunirasr 4 Chen'cal Corp./ Motional Refractories 4 w-ne-ats cor
Phillip Bonotto, Esq. Thompson 4 Heller 3500 American River Drive Suite #101 Sacramento, CA 95864
Attorneys for: Lear Siealer/Roval Ind./World Bestos CP./Hooeman Brothers, irit.
Eugene Brown, Esq. Hardin, Cook, Loper,
Engel 4 Sergez Lake Merritt Plaza 1999 Harrison Street, 16th Fir, Oakland, CA 94612-3506
Attorneys for: Western KacArthur/Spencer turbine tSSESIO!
Franklin E. Bondonno, Esq. Popatka, Allard, McCowan 4 Jones 160 West Santa Clara Street 13th Floor San Jose, CA 95113
Attorneys for: ftiens-Corninc fiberolas Core.
freeman Cut loot, Esq. McDonald l Cullont 635 Sacramento St., Ste 720 San Francisco, CA 94111
Attorneys for: Crane Packino/John-Crane*Houdaitie
Wilkes. Morgan, Esq. Bronson, Bronson 4 McKinnon 100 B Street, Ste. 400 Santa Sosa, CA 95401
Attorneys for: Sacomo-Sierra/ Sacomo Hfo./Parker-Hannifin/
Airco Held
John Ladd, Esq. 1683 fotsom Street San Francisco, CA 94102
Phillip Bonotto, Esq. Thompson l Heller 3500 American River Drive Suite *101 Sacramento, CA 95864
Attorneys for: Lear Sieoier/Roval tnd./world Bestos Co./Honemafi Brothers. Inc.
1ichard J. Hildebrandt, Esq. Hildebrand! 4 Calatrello 757 West Ninth Street San Pedro, CA 90731
Attorneys for: Thorpe Insulation Co.
Bob Channel, Esq. WalsNorth, franklin 4 Bevins 111 Sutter Street, 19th floor San Francisco, CA 94104
Attorneys for: Hamilton Materials. Inc./Dee Engineering Co.
Anthony Griffin, Esq, St. Clair, Zappettini,
McFetridge 4 Griffin Telesis Toner One Montgomery Street Suite 1400 San Francisco, CA 94104
Attorneys for:
Hicotet
IS RE-COMPLEX ASBESTOS, LI!I!IGATJ^_^_SgIANQ__C.OUMXY PLAINTIFF COUNSEL SERVICE LIST
Law Offices of Bruce L. Ahnfeldt P.0. Box 6078 Nape, CA 945B1
Alan (t, Brayton, Esq. Brayton Associates 999 Orsnt Avenue P.0. Box 2109 Novato, CA 94948
Frank h. Finney, Esq. Broun & Finney Peri Executive Center 2033 North Main Street, Suite 430 Walnut Creex, CA 94596
Merry F. tfertnick. Esq. Cartwright, Slobodin, Bokelman,
Borovsky, Uartniek, Moore i Harris 101 California St., Suite 2600 San Francisco, CA 94111
Richard F. Gerry, Esq. sey, Gerry, Casey, Westbrook, Reed Hughes
i10 Laurel Street San Diego, California 92101
Richard K. Brody, Esq. Casey, Gerry, Casey,
Westbrook, Reed t Hughes 781 Tuloiime Vallejo, CA 94590
Law Offices of Jack K. Clapper A Professional Corporation 62 Princess Street Sausalito, CA 94965
Herron Herron Ronald K. Herron 600 Montgomery Street, 33rd floor San Francisco, CA 94111
Davis Ihomas 2121 Avenue Of The Stars Suite 3100 Los Angeles, CA 90067-5010
Christopher Grail, Esq. The Monadnoek Building 685 Market Street, Suite 340 San-Francisco, CA 94105
Law Offices of Jeffrey B. Harrison
A law Corporation One Daniel Burnham Court Suite 220-C San Francisco, CA 94109*5460
Hoberg, Finger, Brown, Cox t Motti 703 Market 18th Floor San Francisco, CA 94103
Law Office Of Cloria J. Musick 7080 DonIon Way Suite 222 Dublin, CA 94568
Jarvis, Miller, Brodsky Bask'n 21 Main Street, *1001 San Francisco, CA 94105
David M. McClain, Esq. Kazan, McClain, Edises sincA Professional Law Corporation 171 Twelfth Street, Ste. 300 Oakland, California 94612
George W. Ktlbourne, Esq. 3755 Alhambra Ave., *9 Martinez, CA 94553
Kenneth l. Knapp 1109 fiuail Street Newport Beach, CA 92660
McCarthy, Johnson ( Miller 595 Market Street Suite 2200 San Francisco, CA 94105
Law Offices of John C. Rcb'-nser A Professional Corporation 365 Notre Dame Drive Vallejo, CA 94589
Law Offices of Sterns, Walker i Lods
100 First Street, Ste. 2300 San Francisco, CA 94105
Gerald J. tiernan 165 fell Street San franeiseo, CA 94102