Document k9VrkBeNdgMxJ73JoLd4VKazb
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IN THE UNITED STATES DISTRICT -COURT FOR THE NORTHERN DISTRICT OF OHIO WESTERN DIVISION
HERMAN A. DENDINGER, et al., Plaintiffs,
vs. CHRYSLER PLASTIC PRODUCTS CORPORATION, et al.,
Defendants.
) Case No. C 84-7854
) [Hon. .Nicholas J. Walinski]
) ) . RESPONSE OF DEFENDANT THE
) GOODYEAR TIRE & RUBBER
) COMPANY TO PLAINTIFFS'
) REQUESTS FOR PRODUCTION
) OF DOCUMENTS DIRECTED TO
) ALL DEFENDANT PVC
) MANUFACTURERS
_______
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Now comes 'defendant,' T^he Goodyear' Tire & Rubber
Company, and for.its response,to plaintiffs' requests for production of documents states as follows:
1. All records of sales, direct or indirect, of Polyvinyl Chloride (PVC) resin from you to Chrysler Plastic Products Corporation (Chrysler) between January 1, 1967 and December 31, 1980.
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ANSWER: See sales reports attached as Attachment 1. 2. "A11 documents indicating the extent to which PVC resin sales to Chrysler during the time period indicated above, represented sales of PVC resin manufactured in the: (a) suspension; (b) emulsion; (c) bulk; or, (d) solution process.
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ANSWER:
This is indicated by the product, code numbers on .tfie sales reports, see Attachment I and response to Interrogatory No. 8.
3. All documents indicating the extent to which PVC
resin sales to.Chrysler during the time period specified in
request number 1, were of (a) Homopolymer; (b) copolymer; or, (c)
terpolymer.
ANSWER:
This i.s indicated by the product code numbers on- the sales reports, see Attachment 1 and response to Interrogatory No. 11..
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4. All written documents indicating* with respect to' PVC resin sold to Chrysler during the time period specified
above, the size (in microns) of the resin sold.
ANSWER: We have none. 5. All written documents indicating the results of any tests done on any PVC resin by you or any other entity to determine, the concentration (in parts per million) of residual vinyl chloride monomer in PVC resin of the type sold to Chrysler during the time period specified in request number 1.
ANSWER: See reports attached as Attachment 2.
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6. All Material Safety Data Sheets published by you prior to January 1, 1986, relating to any PVG resin manufactured by you.
ANSWER:
Objection, any Material Safety Data Sheet published subsequent to 1980, the last date of exposure in this case, is irrelevant* Attached as Attachment 3.
7. All documents in your possession indicating the
dates of manufacture and the dates of shipment of PVC resin sold
to Chrysler.
ANSWER:
'
None other than the attached sales reports' which show sales by product and-by year, see Attachment 1. .
8. All written results of any testing done on the PVC
resin identified in the prior request to determine the
concentration of residual vinyl chloride monomer.
ANSWER:
None now in existence except as indicated in 5 above, see Attachment 2.
9. All documents sent by you to the Occupational
Safety & Heatth Administration, relating, in any way, to PVC.
ANSWER: None to our knowledge. 10. All documents reporting or summarizing efforts taken by you, at any time since January 1, 1967 to reduce the
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045346
percentage of residual vinyl chloride monomer in PVC resin manufactured by you.
ANSWERi
A search was made of company files but we were not able to locate any such documents, see response to Interrogatory No. 19.
11. Each and every document sent to Chrysler,
informing Chrysler of any known or potential human health hazard
relating to exposure or over exposure to vinyl chloride monomer.
ANSWER: -- ---------
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We believe that Chrysler was supplied- with all or most of.the Material Safety Data Sheets attached hereto as Attachment 3 and also received the customer letter dated May 8, 1974, attached as Attachment 4.
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045847
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AS TO OBJECTIONS:
Of Counsel For Defendants The BFGoodrich Co., The Goodyear Tire & Rubber Co., Firestone Tire & Rubber Co., Conoco, Inc., Uniroyal, Inc., Union Carbide Corp., and Diamond Shamrock Corp.:
FULLER & HENRY 1200 Edison Plaza 300 Madison Avenue P.O. Box 2088 Toledo, Ohio 43603
Robert A.'Bunda
/
1200 Edison Plaza
300 Madison Avenue
P.O. Box 2088
Toledo, Ohio 43603
Telephone: (419) 255-8220
Attorney for Defendants
The BFGoodrich Co., The
Goodyear Tire & Rubber Co.,
Firestone Tire & Rubber Co.,
Conoco, Inc., Uniroyal, Inc.,
Union Carbide Corp., and
Diamond Shamrock Corp.
CERTIFICATE OF SERVICE
I hereby certify that a copy of the foregoing Responses
to Plaintiff's Requests for Production of Documents Directed to
all Defendant PVC Manufacturers was mailed by United States
mail, postage prepaid, to Kirk J. Delli Bovi, Esq., attorney for
plaintiff, at his office located at Murray & Murray Co., L.P.A.,
300 Central Avenue, Sandusky, Ohio 44870, and to defense counsel
as set forth in the attached Schedule of Service this
t
day
of October, 1986.
Company, The BFGoodrich Company, Firestone Tire & Rubber Company, Conoco, Inc., Uniroyal, Inc., Union Carbide Corporation, and Diamond Shamrock Corp.
SCHEDULE OF SERVICE
M. Donald Carmin, Esq. 800 United Savings Building Toledo, Ohio 43604 Attorney for Defendants Chrysler Plastic Products
Corporation Norman P. Phillips Albert W. Cramer Robert D. Gustine William C. Holsapple Ron C. Abbott
Willis P. Jones, Jr., Esq. 200 Toledo Legal Building 416 N. Erie Street Toledo, Ohio 43624 Attorney for Defendant DiversiTech General, Inc.
S. Stuart Eilers, Esq. Douylas N. Barr, Esq. Timothy J. Coughlin, Esq. 1100 National City Bank Bldg. Cleveland, Ohio 44114 Attorney for Defendant Stauffer Chemical Company
H. William Bamman, Esq. 414 K. Erie Street Toledo, Ohio 43624 Attorney for Defendant A. Schulman, Inc.
Ellis F. Robinson, Esq. 610 United Savings Building Toledo, Ohio 43604 Attorney for Defendant Shintech, Inc.