Document kDqOY00QJMYQ63mLB75KQrxob

IN THE COURT OF COMMON PLEAS CUYAHOGA COUNTY, OHIO IN RE: ALL BARON & BUDD CASES IN WHICH RED SEAL ELECTRIC IS NAMED AS DEFENDANT ASBESTOS MASTER CASE NO. 073958 Plaintiffs, v. JUDGE HARRY A. HANNA A-BEST PRODUCTS COMPANY, et al. Defendants. RESPONSES OF DEFENDANT RED SEAL ELECTRIC COMPANY TO PLAINTIFFS' MASTER SET OF INTERROGATORIES Defendant Red Seal Electric Company ("Red Seal"), by and through its undersigned counsel, responds to Plaintiffs' Master Set of Interrogatories as follows: GENERAL OBJECTIONS 1. Defendant Red Seal objects to the Instructions and Definitions set forth in Plaintiffs' Master Set of Interrogatories to the extent that the plaintiffs seek to impose on Red Seal obligations greater than those set forth in the Ohio Rules of Civil Procedure. 2. Defendant Red Seal objects to Plaintiffs' Master Set of Interrogatories to the extent plaintiffs seek to invade the attorney client and work product privileges. 3. These General Objections are hereby deemed incorporated into each and every response set forth below. INTERROGATORIES 1. For each Interrogatory below, please state the name and last known address of each person answering it, including whether he/she is employed by Defendant and if employed by Defendant include job title, length of time employed by Defendant and a year by year list of all other positions, titles, or jobs held when working for Defendant. ANSWER: S. James Stryffeler. President of Red Seal Electric Company since 1958. 1.1 Please identify all documents used, related to, or referred to in connection with the preparation of or answers to these Interrogatories and state the number of the Interrogatory and its subpart to each such document. ANSWER: See documents produced in response to Plaintiffs' Requests for Production of Documents. 2. Please state whether or not Defendant is a corporation. If so, please state: (a) Your correct corporate name; (b) The state of your incorporation; (c) The address of your principal place of business; 2 (d) Your registered agent for service in the state of Ohio; (e) For each Defendant claiming that this Court lacks personal jurisdiction, list year by year the total amount of income received by the Defendant from entities in Ohio, any and all years that Defendant, as defined, has been licensed to do business in Ohio, and any real property owned at any time by Defendant or its present or past subsidiaries. ANSWER: Yes. (a) Red Seal Electric Company. (b) Ohio. (c) 3835 West 150th Street, Cleveland, Ohio 44111-5891. (d) S. James Stryffeler. (e) Not applicable. 3. State Defendant's complete corporate or business history, including dates of incorporation, mergers, consolidations, reincorporations, and the like. Also provide historical information regarding all predecessors, prior names, asset purchases, acquisitions or spin-offs. In addition: (a) if Defendant or any of its predecessors or subsidiaries at any time purchased, assumed, or in any other manner acquired ANY of the assets and/or liabilities of any corporation or entity at any prior time engaged in any aspect of the placing of asbestos-containing products into the stream of commerce or the insuring of asbestosrelated risks, then please state the following as to each acquisition: 3 (b) the name or description of each corporation, entity or assets acquired by Defendant, that entity's state of incorporation and principal place of business, its date of incorporation, and the name of Defendant at the time of acquisition; (c) the manner by which each such corporation, entity or interest therein, was acquired (e.g., merger, consolidation, change of name, stock sale, transfer or purchase of assets or product line); (d) the date of each such acquisition; (e) the state in which each such acquisition was effected; (f) the state law governing each such acquisition if specified by contract; (g) whether Defendant became legally responsible for the past torts of each such corporation or entity; (h) identify each document reflecting or related to the history and/or transactions(s) set forth in answer to this Interrogatory. ANSWER: Durolet Manufacturing Company was incorporated in 1946. In June 1952, the name of the company was changed to Red Seal Electric Company. Neither company ever acquired any entity that had any involvement with asbestos-containing products. (a)-(h) Not applicable. 4. Please state whether or not Defendant has purchased, assumed, or in any other manner acquired any of the assets and/or liabilities of any corporation or entity (such corporations or entities being limited to those engaged in mining, selling, manufacturing, marketing or distribution of 4 asbestos-containing products.) following: If so, please state the (a) the name or description of each corporation, entity or assets acquired by Defendant, its state of incorporation and principal place of business, its date of incorporation, and the name of Defendant at the time of acquisition; (b) the manner by which each such corporation, entity, or interest therein, was acquired (e.g. merger, consolidation, change of name, stock sale, transfer or purchase of assets or product line); (c) the date of each such acquisition; (d) the state in which each such acquisition was effected; (e) the state law governing each such acquisition if specified by contract; (f) whether Defendant became legally responsible for the past torts of each such corporation or entity; (g) whether the acquisition concerned asbestoscontaining products. ANSWER: No. (a)-(g) Not applicable. 4.1 For each corporation, other than the answering Defendant, that has at any time in the past been involved in the placing of asbestos-containing products into the stream of commerce for which officers of the answering Defendant's corporation have also served as officers, directors or served in any managerial position while employed by the answering defendant, state: (a) the name of the entity involved in the placing of asbestos products into the stream of commerce; 5 (b) the manner in which the entity was involved in the placing of asbestos containing products into the stream of commerce (i.e., mining, milling, manufacturing, distributing, installing, rebranding, etc.); (c) the specific products placed into the stream of commerce by the entity, year by year and by brand or trade name; (d) the name, positions and a brief description of the responsibilities of the person or persons serving the answering Defendant and the entity simultaneously, including the positions held with the entity, and with the answering Defendant. ANSWER: (a)-(d) Not applicable. 5. Has Defendant ever engaged in the mining, manufacturing, selling, marketing, installation or distribution of asbestoscontaining products? If so, please state the following: (a) The name of the company engaged in the activity (whether it is Defendant, Defendant's predecessor, or Defendant's subsidiary or some other entity related to Defendant); (b) As to each product mined, manufactured, sold, marketed, installed or distributed, please state the following: (1) The trade or brand name. (2) Its identification number (model, serial number, etc.). (3) The time period it was manufactured, mined, marketed, distributed or sold. (4) Its physical description including color, general composition, and form. (5) A detailed description of its intended use and purpose. 6 (6) A detailed description of the type package in which it was sold, listing the dates of each type of package used, physical description of the package, and a description of any printed material or trademarks that appeared thereon. (7) The percent of asbestos which it contained. (8) The percent of asbestos by asbestos type (amosite, crocidolite, tremolite, anthophyllite, chrysotile). (c) The time period during which each of these products were on the market; (d) The material components/ingredients of each such product, giving specific or approximate percentage both by weight and by volume of each material component/ingredient (this interrogatory is not limited to the asbestos component of the product but seeks information as to the nature, weight and volume of non-asbestos ingredients, as well) of each such product; (e) How each of these asbestos-containing products can be distinguished from those of competitors; (f) A description of the physical appearance of such product; (g) A detailed description of the intended uses. ANSWER: Red Seal previously sold, marketed and distributed certain asbestos-containing products. Red Seal did not mine, manufacture or install asbestos-containing products. (a) Red Seal Electric Company. (b) In approximately mid 1957, Red Seal began to sell asbestos-containing cement board products. The 7 names of the primary products sold were Johns- Manville Transite, Johns-Manville Marinite, Johns-Manville Millboard, Johns-Manville Flexboard, Johns-Manville Ebony Asbestos, Johns- Manville Ohmstone and Johns-Manville Colorith. A preliminary review of Red Seal's sales records has revealed a limited number of sales of other asbestos-containing products. The sale of asbestos-containing products ceased in 1986. Product Descriptions: Transite: hard, dense, gray colored; flat sheets, corrugated sheets, rods and tubes Marinite: rigid, flat off-white to white sheet material Millboard: flat, semi-rigid sheet material; off-white to gray in color Ebony Asbestos: hard, dense board; black in color Ohmstone: hard, dense board; grayish brown Colorith: hard, dense, slate appearing sheets Except for those products that were sold pursuant to customer specifications, Red Seal did not have specific information as to the intended 8 use of the products. The products were generallyused as heat insulating materials. Ebony Asbestos and Ohmstone were used for electrical purposes. The products were shipped on pallets or skids. Individual or smaller pieces may have been shipped in cardboard boxes. Red Seal would include a shipping label with the pallets or on the boxes. As a distributor, Red Seal had no direct information as to the amount or type of asbestos in these products. (c) Unknown as Red Seal was not the manufacturer of the products it sold. (d) Unknown as Red Seal was not the manufacturer of the products it sold. (e) Red Seal has insufficient knowledge concerning the products sold by all manufacturers and therefore cannot respond to this Interrogatory. (f) See above. (g) See above. 6. Does Defendant or any of its subsidiary companies claim that any patent would cover any product listed in answer to Interrogatory No. 5? If so, please state the following: (a) The date of each patent; 9 (b) The date same was issued; (c) The number of each patent application that is pending. ANSWER; No. Red Seal was not the manufacturer of any asbestoscontaining products. (a)-(c) Not applicable. 7. Have any of the products listed above in answer to Interrogatory No. 5 been altered in chemical composition since first being marketed? If so, please state the following: (a) The trade name of each such product/ (b) The date each such product was altered; (c) The nature of the alteration; ANSWER: (d) The reason for the alteration. Unknown. Red Seal was not the manufacturer of any asbestos-containing products. (a)-(d) Not applicable. 8. Have any of the asbestos-containing products listed in response to Interrogatory No. 5 ever been marketed, distributed, packaged, labeled, and/or sold by any other company or business? If so, please state the following: (a) The name and address of each such company. (b) The names and address of Defendant's distributors in Ohio, West Virginia, Pennsylvania and Kentucky since 1940. (c) The date of each sale. 10 (d) The name of the person at each location with whom you primarily dealt. (e) A list of all asbestos-containing products that you sold to each location from 1945 to 1980. (f) The amount of each asbestos product sold to each location during this period. (g) Please identify all documents relating to this distributor for the particular location. ANSWER: Yes. Red Seal was not the manufacturer of the asbestoscontaining products it sold. Red Seal does not have information as to the other distributors of the products. (a)-(g) Not applicable. 8.01 Has Defendant ever purchased asbestos-containing products from any other Defendant? ANSWER: None from the defendants named in the cases in which Red Seal has been named. The primary products that it sold were purchased from Johns-Manville. 8 .. 02 If the answer to the preceding Interrogatory is please state the following: (a) name each Defendant from whom this defendant purchased any asbestos containing product; (b) list each product purchased from each co-Defendant; (c) list the dates of each purchase of asbestoscontaining products from each co-Defendant. 11 ANSWER: See response to Interrogatory 8.01. 8.03 Has Defendant ever sold asbestos-containing products to any other Defendant? ANSWER: This Interrogatory is overbroad, unduly burdensome, seeks information that is not relevant and is not reasonably calculated to lead to the discovery of admissible evidence in that it is not limited in time or scope. Plaintiffs' Interrogatory is not limited to exposures and sales relevant to any plaintiffs at issue in the cases against this defendant. 8.04 If the answer to the preceding Interrogatory is yes, please state the following: (a) name each Defendant to whom this Defendant sold any asbestos containing product; (b) list each product sold to each co-Defendant; (c) list the dates of each sale of asbestos- containing products to each co-Defendant. ANSWER: See response to Interrogatory 8.03. 8.05 Has Defendant engaged in the manufacture and/or sale and/or distribution and/or marketing and/or supply and/or purchase and/or use of non-asbestos-containing products for use in connection with temperatures above 125 Fahrenheit since 1930. If so, please state: (a) the date such activity began; 12 (b) the years during which such activity took place; (c) the date when such activity was terminated; (d) if such activity was terminated, the reason(s) why; (e) the geographical area into which you claim the product(s) were sold, purchased, or used; (f) identify the organizational unit of Defendant so engaged; (g) the site(s) at which each such product was manufactured; (h) the material components of each such product, giving specific or approximate percentage both by weight and by volume of each material component of each such product; (i) the temperature ranges for which each product(s) was intended to be used; (j) the product's generic name; (k) the product's trade or brand name; (l) the container in which the product was shipped (i.e., paper bags, cardboard boxes) including the size and amount of the container; (m) a description of any logos, writing impressions or identifying markings which appeared on the product, as well as a description of the package used, the dates that type of package was used, and any logos, product names, trademarks, etc. which appeared on the package; (n) whether the words "non-asbestos" or "asbestos free" were used on the package; (o) a detailed description of the intended method of preparation and application of the product; (p) a description of the physical appearance of the product, including size, shape, color and texture. 13 ANSWER: Yes. (a) 1946 to present. (b) 1946 to present. (c) Not applicable. (d) Not applicable. (e) United States and foreign countries. (f) Red Seal Electric Company. (g) Unknown as Red Seal was not the manufacturer. (h) Unknown as Red Seal was not the manufacturer. (i) Unknown. (j) Marinite and Transite. (k) Marinite and Transite. (l) The products were shipped on pallets or skids. Individual or smaller pieces may have been shipped in cardboard boxes. (m) In later years, the shipping address label had a red seal in the left top corner. (n) No. (o) Unknown as Red Seal was not the manufacturer of the products. (p) Marinite: rigid flat off-white to white sheet material Transite: hard, dense gray colored 14 8.06 Did Defendant ever market or distribute any asbestoscontaining product manufactured in whole or in part by someone else? If so, please state the following for each such product: (a) the name and address of the manufacturer; (b) the product's trade and brand name; (c) the organizational unit of Defendant who did so; (d) date(s) beginning, ending and during which the marketing or distributing took place; (e) whether the product was distributed through the same channels as those used for products manufactured by Defendant, and if not, please explain the exact channels of distribution; ANSWER: (f) identify all documents relating the marketing or distribution. Yes. All asbestos-containing products sold by Red Seal were manufactured by someone else. (a)-(d) See response to Interrogatory 5. (e) Not applicable as Red Seal did not manufacture any asbestos-containing products. (f) Documents relating to the distribution of asbestos- containing products are being produced in response to Plaintiffs' Requests for Production of Documents. 8.1 Does Defendant have reason to believe that any of the asbestos-containing products listed in response to Interrogatory No. 5 were used at any of the sites listed on Exhibit A, attached hereto. If your answer is "yes", please state: (a) The basis of your answer. (b) Please state which of Defendant's asbestos- 15 containing products listed in Interrogatory Wo. 5 were used at each job site listed on Exhibit A. ANSWER: Red Seal objects to Plaintiffs' Interrogatory as overbroad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Exhibit A consists of over 400 work sites on eleven pages. Requiring Red Seal to review all of its voluminous sales records to determine whether it had sales to each of these locations is overbroad and unduly burdensome. Furthermore, Red Seal objects to this Interrogatory in that it is not limited in time or scope. Red Seal lacks information as to whether the plaintiffs worked at any or all of these locations. Plaintiffs have further improperly failed to limit the information sought for each of these over 400 sites to time frames when plaintiffs allegedly worked at these locations. 8.2 For each company or business that Defendant knows may have marketed, distributed, installed, and/or sold, those products listed in response to Interrogatory No. 5, please state the following as to each job site listed on Exhibit A: (a) The name and address of each such company; (b) The date of each sale from Defendant to such other company; (c) The name of the person at each other company with whom Defendant primarily dealt. (d) Names and quantities of the asbestos-containing products that you marketed, distributed, installed, and/or sold to each such company from 1950 to 1974. 16 (e) Identify all documents relating to the sales to each such company. ANSWER: Unknown. Red Seal was not the manufacturer of the asbestos- containing products it sold. (a)-(e) Not applicable. 8.3 If you do not know any business that may have marketed, distributed, installed, and/or sold the products listed in response to Interrogatory No. 5 to any of the job sites listed on Exhibit A, please state the names and last known addresses of those companies who Defendant knows marketed, distributed, installed and/or sold their asbestos-containing products in Ohio from 1950 to 1974. For each of those companies, pjease state the following: (a) Name and address of each such company; (b) The dates of each sale from Defendant to such other company; (c) The name of the person of each other company with whom Defendant primarily dealt; ANSWER: (d) The names of the asbestos-containing products that Defendant marketed, distributed, and/or sold to each such company from 1950 to 1974. Red Seal did not have any distributors of the asbestos- containing products it sold. Red Seal was not the manufacturer of the asbestos-containing products it sold. (a)-(d) Not applicable. 8.4 Does Defendant have records and/or any knowledge that reflects sales of their asbestos-containing products to any of the 17 sites listed on Exhibit A, attached hereto? If so, please state the following as to each job site listed on Exhibit A: (a) The names and last known addresses of those people with such knowledge. (b) The location of such records. ANSWER: Red Seal objects to Plaintiffs' Interrogatory as overbroad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Exhibit A consists of over 400 work sites on eleven pages. Requiring Red Seal to review all of its voluminous sales records to determine whether it had sales to each of these locations is overbroad and unduly burdensome. Furthermore, Red Seal objects to this Interrogatory in that it is not limited in time or scope. Red Seal lacks information as to whether the plaintiffs worked at any or all of these locations. Plaintiffs have further improperly failed to limit the information sought for each of these over 400 sites to time frames when plaintiffs allegedly worked at these locations. 9. Did Defendant or any of Defendant's distributors, as listed in response to Interrogatory Nos. 8.1, 8.2, and/or 8.3 have sales representatives who specifically called on the sites listed on Exhibit A, attached hereto, from 1945 to 1975? If your response is yes, as to each site listed on Exhibit A, please state the following: (a) The name and last known address of each such representative and whether they are still employed by Defendant; (b) The period of time they acted as your 18 representative; (c) Their general responsibility as to each facility; (d) Whether that person is still alive; and (e) Any documents relating, referring or pertaining thereto. ANSWER: (a)-(e) Red Seal did not have any distributors of the asbestos-containing products it sold. Red Seal did not have any employees who specifically called on various work sites. Sales representatives of the manufacturer worked on occasion under contract to Red Seal for the purpose of soliciting sales of the products sold by Red Seal. Red Seal does not recall the names of these individuals and has no documents relating to their activities. 9.1 Identify all managers and sales personnel responsible for your sales or installation of any asbestos-containing products in Ohio from 1930 to the present and state their position, last known address and the local or regional office through which they were employed. ANSWER: Red Seal did not begin to sell asbestos-containing products until approximately mid 1957. Red Seal did not install any asbestos-containing products. The following individuals had responsibilities relating to sales: S. James Stryffeler, President, Red Seal Electric Company 19 William Lowery, Vice President in charge of sales until his death in 1993. C.M. Ogrin - assisted Mr. Lowery; present address unknown. 10. Did Defendant ever have any division or subsidiary engaged in the contract business of applying or removing asbestoscontaining products? If so, please state: (a) The name of each subdivision; (b) The full address of the home office and the date such subdivision or subsidiary was engaged in this contracting business; and (c) Whether said division or subsidiary conducted such business at any of the sites listed on Exhibit A from 1940 to 1975? If so7 please state the following as to each job site listed on Exhibit A: (1) The dates of such contracts; (2) The specific asbestos-containing products that were used or removed in each contract. ANSWER: No. (a)-(c) Not applicable. 11. Did Defendant ever have any division or subsidiary engaged in the contract business of applying or removing asbestoscontaining refractory? If so, please give the name of each subdivision, the full address of the home office and the date such subdivision or subsidiary was engaged in this contracting business. ANSWER: No. 20 iz . Please identity by location and product produced, each plant in which products listed in your answer to Interrogatory No. 5 have been manufactured and/or assembled and the dates said plants have been in operation. ANSWER: Not applicable. Red Seal did not manufacture any asbestos - containing products. 13. Has Defendant, at any time, entered into a "rebranding" agreement with any other company, either as a buyer or a seller, concerning any asbestos-containing products and/or materials? If so, please state-. (a) The name of the company manufacturing the asbestos products under such agreement; (b) The trade name affixed to such products; (c) The periods of time covered by each such agreement; (d) The volume (in dollars amounts) of each such transaction; (e) The purchaser of such products; (f) Does Defendant currently have in its possession any of the writings or contracts concerning such rebranding agreement? ANSWER: No. (a)-(f) Not applicable. 13.1 Have you ever owned or operated a business or portion thereof which engaged in construction, erection or tear-out of furnaces, pipes, boilers, turbines, lehrs, ovens, kilns, etc? If so, please state: (a) the name of said business,- 21 (b) the date of commencing business and cessation of business, if applicable; (c) type of construction or tear-out performed; (d) state whether said business installed or supplied asbestos-containing products on the furnaces, pipes, boilers, turbines, lehrs, etc., i.e., gaskets, pipecovering, block, cement, rope, cloth, clothes, etc., containing asbestos, asbestos pipe, board, etc.; (e) state the trade name and/or manufacturer of any asbestos-containing product which you installed or supplied to any site on Exhibit A. (f) provide the dates for the applicable construction, installation or tear-out project. ANSWER: No. (a)-(f) Not applicable. 13.2 Do you have within your custody, possession, or control any packages that presently or formerly packaged asbestoscontaining products or were produced for the purpose of packaging asbestos-containing products contemporaneous with your manufacture sale or distribution of such asbestos-containing products? If so, provide the following: (a) a description of each such package; (b) the present location and custodian of each such package; (c) the date or approximate date on which each such package was produced. ANSWER: No. (a)-(c) Not applicable. 22 14. What is the name, address and job title of each individual who participated in the design and preparation of manufacturing specifications for each such product listed above in answer to Interrogatory No. 5? ANSWER: Unknown. Red Seal did not manufacture any products containing asbestos. 15. As to each product listed in response to Interrogatory No. 5, please describe how each product was to be cut, shaped, scribed, mixed and applied on the job. In answering this question, give particular reference as to whether or not the materials were to be sawed or cut on the job, blown into confined areas, mixed with water in a cement or paste. ANSWER: Unknown. Red Seal was not the manufacturer or installer of any products containing asbestos. 16. Based upon the material contents of the asbestoscontaining products, the method of manufacturing, and the method of application, please state which products listed in Interrogatory No. 5 could be applied by a worker without creating dust. ANSWER: Unknown. Red Seal was not the manufacturer or installer of any products containing asbestos. 17. Do any documents, including but not limited to, written memoranda, specifications, recommendations, blueprints or other written materials of any kind or character now exist relating to the design and preparation of the products listed in answer to Interrogatory No. 5? If so, please: (a) List each such written material or document; 23 (b) Identify the person or persons presently in possession of each such document; (c) State where each such document is located. ANSWER: No. Red Seal did not design or manufacture any products containing asbestos and therefore has no documents relating to the design or manufacture of the products. (a)-(c) Not applicable. 18. Prior to releasing the products listed in Interrogatory No. 5 for sale and usage, were any tests (either animal or human) conducted on said products to determine potential health hazards involved in the use of, or exposure to, the materials and/or products? If so, please state: (a) The name of the products tested and the date of each test. (b) The name, address, and job classification of each individual who conducted such tests; (c) The results of such tests. ANSWER: Red Seal did not manufacture any products containing asbestos. No tests were performed by Red Seal. Red Seal does not know what tests were performed by the manufacturer. (a)-(c) Not applicable. 18.1 Prior to releasing any products for sale and usage (whether asbestos-containing or not), were any tests (either animal or human) conducted on said products to determine potential health hazards involved in the use of, or exposure to, the materials and/or products? If so, please state: 24 (a) The name of the products tested and the date of each test. (b) The name, address, and job classification of each individual who conducted such tests; (c) The results of such tests. ANSWER: Red Seal did not manufacture any products containing asbestos. No tests were performed by Red Seal. Red Seal does not know what tests were performed by the manufacturer. (a)-(c) Not applicable. 19. Does Defendant have or control any documents, including but not limited to, written memoranda, specifications, recommendations, blueprints or other written materials of any kind or character relating to the testing of the products listed in Interrogatory No. 5 hereinabove? (a) Identify each such written material or document; (b) Identify each person who presently has possession of each such document; (c) State where each such document is located. ANSWER: No. (a)-(c) Not applicable. 20. Were any design changes or modifications made as a result of such tests listed in answer to Interrogatory No. 18 hereinabove? If so, please state: (a) The trade name of the product changed or modified; (b) The nature of the change made and the date of such 25 changes or modifications; (c) The name, address, and job classification of each person in charge of making a change. ANSWER: Unknown. (a)-(c) Not applicable. 21. After releasing for sale, distribution or marketing the products listed in answer to Interrogatory No. 5, did Defendant conduct any tests (either on animals or humans) to determine potential health hazards involved in the use of said materials and/or products? (a) The names of the products tested and the dates of said tests; (b) The name, address, and job classification of each person and/or agency conducting said tests; (c) The results of said tests; (d) Whether, as a result of any tests conducted, any products were removed from the market; (e) The names of all products removed from the market as a result of said tests. ANSWER: No. (a)-(e) Not applicable. 22. Has Defendant ever conducted or caused to be conducted any studies concerning the effects of the inhalation of asbestos dust and/or fibers on workers or other persons applying, using and/or working around any of the asbestos products manufactured, sold, distributed and/or relabeled for distribution by you or your predecessor? If so, please state: (a) The dates and nature of such studies; 26 (b) The names and addresses of persons conducting such studies; (c) The purpose of such studies; (d) Identify and list those persons to whom such reports were given and the date of such dissemination; (e) State any publication or other written dissemination of the results of such studies; (f) State the nature of any action to eliminate or minimize the inhalation of asbestos dust fibers; and (g) Attach a copy of reports based upon such studies. ANSWER: No. (a)-(g) Not applicable. 23. Before placing in the market the asbestos-containing products that Defendant mined, manufactured, sold, marketed, installed or distributed on the market, did Defendant make or cause to be made, any studies to determine whether their asbestoscontaining products would be hazardous to people? If so, please state: (a) The date of said studies; (b) ' What studies were done; and ANSWER: (c) The titles of each study. Defendant Red Seal did not mine, manufacture or install any products containing asbestos. By way of further response, no. (a)-(c) Not applicable. 27 24. Please state whether or not Defendant ever conducted or caused to be conducted any tests in the field (where asbestoscontaining products were applied, removed or utilized) to determine the nature and extent of asbestos dust and/or fiber exposure to insulators, applicators, fellow employees, or other workers removing and/or tearing out asbestos-containing products, and/or other workers in the vicinity thereof? If so, please identify: (a) The date, place and nature of each and every test; (b) The particular asbestos-containing products to which each test was applied; (c) The results of each test with particular reference to the number of asbestos fibers per cubic centimeter of air found at each site; and (d) The persons to whom the results said tests were given and the date of such dissemination. ANSWER: No. (a)-(d) Not applicable. 25. Please state whether or not Defendant ever obtained any knowledge concerning the likelihood of asbestos being hazardous to human health. If so, please state: (a) When Defendant first became aware of the hazardous hazardous potential of asbestos dust and asbestos fibers; (b) The manner in which the Defendant, Defendant's predecessor, or Defendant's subsidiary companies first obtained this knowledge and became aware of said hazards and from what source this information was obtained; (c) What information was disseminated within Defendant's company, or its subsidiary or predecessor regarding such adverse consequences or effects; 28 (d) Whether any such information is still maintained by Defendant or its subsidiary or predecessor in any written form; (e) The name, address and job classification of the custodian of such information. ANSWER: Yes. (a) The early 1970's. (b) From receipt of regulations from the Occupational Safety and Health Administration. (c) The employees were notified of Occupational Safety and Health Administration regulations and saw warnings on products being sold. (d) Yes. (e) S. James Stryffeler, President, Red Seal Electric Company. 26. Please state when Defendant first became aware of the possible association between inhalation of asbestos dust and/or fibers and the contraction of asbestosis and cancers including, but not limited to gastrointestinal cancer, laryngeal cancer, renal cancer, lymphoma, lung cancer and mesothelioma. As to each disease or condition, please state the source of that information, including a description of all tests conducted relative to the possibility of such a relationship. ANSWER: Red Seal objects to this Interrogatory to the extent that plaintiffs call for a medical conclusion which Defendant is not qualified to render. By way of further response and without 29 prejudice to or waiver of these objections, Red Seal states that it did not gain specific knowledge concerning the alleged connection between asbestos inhalation and the various diseases listed. Red Seal was not the manufacturer of any products containing asbestos and did not conduct any testing concerning any possible relationship between asbestos inhalation and the diseases listed. 27. Please identify all physicians, industrial hygienists, and other employees (including their names and addresses) who were employed, retained or otherwise engaged by Defendant for research, investigation or study concerning asbestos or asbestos-related diseases. ANSWER: None. 28. As to each person who acted in a medical advisory capacity (as it relates in any way to asbestos) to Defendant, please list their name, the date individual acted in this capacity, and that person's current address and job title. ANSWER: Not applicable. 29. Please state if any medical officer or industrial hygienist or medical consultant ever made at any time any recommendations and/or suggestions to Defendant pertaining to the risks or hazards to persons involved in the manufacture or use of asbestos products and, if so, please state when, by whom or to whom such recommendations and/or suggestions were made and the substance of each recommendation. ANSWER: No. 30 30. Please state the scientific and/or medical periodicals to which Defendant, its medical department, research department, industrial hygiene divisions, engineering department or consulting physicians subscribed between 1945 and 1975. ANSWER: None. 30.1 Please state whether Defendant, its medical officer or industrial hygienist or medical consultant or physicians were ever involved in testing or received literature or correspondence from the Mellon Institute. ANSWER: No. 30.2 Has Defendant, or any engineer, industrial hygienist or physician in Defendant's employ, been a member in any professional group, trade group or any of the following groups: American Ceramics Society Asbestos Textile Institute National Insulation Manufacturers Association Thermal Insulation Manufacturers Association Quebec Asbestos Information Association Asbestos Information Association Industrial Health Foundation Industrial Hygiene Foundation Iron and Steel Institute National Safety Counsel Refractories Institute Air Hygiene Foundation of America, Inc. Sprayed Mineral Fiber Association American Society of Mechanical Engineers If the answer is yes, state the following: (a) The name of the group or groups in which Defendant or individual(s) were members; (b) The name and position of individual(s) within the Defendant, as defined, who were members; 31 (c) The years Defendant or individual(s) were members of the groups; ANSWER: (d) Whether Defendant paid the individual(s) dues or membership fees or reimbursed the individual(s) for dues or membership fees in the group. No. (a)-(d) Not applicable. 31. State in detail what test, if any, Defendant ever made with regard to the quantity, quality, or threshold limit values of asbestos dust, fibers or particles to which workers were exposed while using, working with and/or around, installing and/or applying your asbestos-containing products. ANSWER: Monitoring was conducted at Red Seal Electric Company for compliance with Occupational Safety and Health Administration air quality standards. 32. For each test described in Interrogatory No. 31, please give the name of the person conducting the test, the date of the test, and attach true copies of any documents, including but not limited to, reports, findings or memoranda concerning such tests or studies. ANSWER: Red Seal believes these tests were conducted in the early 1970's. No documents exist concerning these studies. Red Seal believes that no threshold limits were exceeded. 33. Please state the year that Defendant was first advised of either threshold limit values or maximum allowable concentrations of both asbestos dust and total dust by the 32 American (.omerence of Governmental Industrial Hygienists and state the name of the employee/official or the company receiving such advice. ANSWER: S. James Stryffeler first learned of limits in the early 1970's upon receipt of Occupational Safety and Health Administration regulations. 33.1 State whether Defendant at any time conducted, caused to be conducted, or had conducted on any job site, or at any of Defendant's plants or buildings, any air sampling, dust counts, dust observations, dust sampling tests or other activities to determine air quality. If your answer is in the affirmative, please indicate: (a) the date of any such air samples, tests, or activities; (b) by whom such activities were performed; (c) where such activities were performed; ANSWER: (d) the results of any such activities. Red Seal objects to Plaintiffs' Interrogatory as improperly not limited to exposures relevant to the underlying plaintiff. Without prejudice to or waiver of these objections and subject to the General Objections set forth above, see responses to Interrogatories 31 and 32. In addition, in 1985, the EPA conducted activities at Red Seal Electric Company. Violations were found in connection with the disposal of waste material. 33 34. Does Defendant maintain a library dealing with industrial hygiene, medicine, safety and engineering and/or research? If so, state: (a) The date each such library was established; (b) The location of each library; (c) The name(s) of the librarians(s) since 1930; (d) List all journals subscribed to by you concerning asbestos, industrial hygiene, medicine, safety, and/or engineering; (e) List all books and articles dealing with asbestos and asbestos-related diseases and the date acquired. ANSWER: No. (a)- (e) Not applicable. 35. Did Defendant in the 1920's or 1930's commission, or participate in the arrangements with Metropolitan Life Insurance Company for studies at the Trudeau Foundation at Saranac Lake, New York, concerning the effect of inhalation or ingestion of asbestos fibers upon human and/or animal bodies. ANSWER: No. By way of further response, Durolet Manufacturing Company was not formed until 1946. 36. When was Defendant first aware of reports of studies of the Trudeau Foundation at Saranac Lake, New York, entitled "Effects of the Inhalation of Asbestos Dust in the Lungs of Asbestos Workers" by A.J. Lanza, Assistant Medical Director published in the J. Public Health Report, Vol. 50, No. 1, dated January 4, 1935 ("Lanza Report")? ANSWER: 34 Red Seal has no knowledge concerning these reports or studies. 36.1 Did Defendant ever contract with Saranac Laboratories to study the hazards of any dust producing product manufactured by you (whether asbestos containing or not)? If so, identify by date and author all documents concerning or any way related to such study. ANSWER: No. 36.2 Did Defendant ever contract with Saranac Laboratories to analyze dust or products? If so, identify by date and author all documents concerning or any way related to such analysis. ANSWER: No. 37. Please state whether Defendant at any time has been a member of any "trade organization" or "trade association" composed by other manufacturers, miners, distributors, and/or sellers of asbestos-containing products and, if so, please identify the name and address of each such association or organization, the dates of membership, and the names of any publications issued or written by such association or organization. ANSWER: Yes. National Association of Cement Board Fabricators (now known as the National Association of Composite Board Fabricators). Approximately 1971 to present. No known publications. 38. With respect to each trade organization or association listed in answer to Interrogatory No. 37, please state whether the minutes of the group's meetings and any correspondence between the 35 members of such groups concerning the hazards of asbestos exposure are available. ANSWER: Red Seal is unaware of any meeting minutes or correspondence relating to the alleged hazards of asbestos exposure. 39. Please identify by name the technical and trade association periodicals to which Defendant subscribed, and state whether Defendant had knowledge of any articles being printed, or withheld from printing, in said periodicals pertaining to the potential hazards of asbestos. If so, please state the following: (a) The title of each such article; (b) The periodical in which each such article was published; (c) The date each such article was published; (d) A detailed explanation of the reason for withholding any such article for printing; ANSWER: (e) Produce documentation which refers, alludes or mentions articles which were withheld for publication. Red Seal does not recall the names of the various periodicals it received. Red Seal has no knowledge concerning any articles relating to the alleged hazards of asbestos. (a)-(e) Not applicable. 36 40. Please state whether, prior to 1975, Defendant sponsored, or attended any meeting, seminar, conference, convention or legislative hearing where the subject of occupational health exposure to asbestos was discussed and, if so, please state the date and place of such meeting and the name and address of any speakers or participants. ANSWER: The Occupational Safety and Health Administration regulations may have been discussed at a meeting of the National Association of Cement Board Fabricators. No further details are recalled at this time. 41. As to each product listed in response to Interrogatory No. 5, please state whether Defendant, at any time, published and/or distributed any printed materials, including but not limited to brochures, pamphlets, catalogs, packagings or other written materials of any kind or character that contain any warnings, cautions, caveats or directions concerning the possible health effects of the products on a person. If so, please state as to each product: (a) The name of each relevant product; (b) The wording of each such warning; (c) A description of each such printed material; (d) The method used to distribute the warning to persons who are likely to use the products; (e) The date each such warning was issued; (f) Whether any warning accompanied any of your asbestos-containing products' sales literature, handout or pamphlets; (g) Please attach a copy of the warning and date said warning was issued; (h) The name, address, and job classification of each person who presently has possession of the 37 above-described documents; ANSWER: (i) The name or names and addresses of the company who provided, produced, or manufactured the boxes or containers on which the warning appeared and dates these boxes with the warnings appeared. Yes. (a) See response to Interrogatory 5. (b) CAUTION CONTAINS ASBESTOS FIBERS AVOID CREATING DUST BREATHING ASBESTOS DUST MAY CAUSE SERIOUS BODILY HARM Warnings were also placed on the products by the manufacturer. (c)-(d) Packing lists were stamped. Where possible, yellow warning labels were placed on the products by Red Seal. (e) In the 1970's. (f) Red Seal does not recall if any warnings were contained in the product literature of Johns-Manvi1le. Upon request, Red Seal sent Material Safety Data Sheets with products being sold. (g) See documents produced in response to Plaintiffs' Requests for Production of Documents. (h) S. James Stryffeler, Red Seal Electric Company. (i) Not applicable. 38 42. Has sales material been prepared by Defendant or its agents for purposes of marketing or advertising the asbestos products listed in answer to Interrogatory No. 5? If so, please state: (a) The name and address of each person or entity who prepared same; (b) The name, address and job title of each person who presently has possession of same; (c) The date same was prepared; ANSWER: (d) The media used to disseminate the sales material. No. (a)-(d) Not applicable. 43. Has any written material of any kind or character been prepared by Defendant, Defendant's predecessor or any of Defendant's subsidiary companies or their agents indicating how the products listed in answer to Interrogatory No. 5 should be used or maintained by the ultimate user or those working in facilities or at job sites where the product was used, installed or removed, including, but not limited to, those sites listed on the job site list attached as Exhibit A. If so, please state the following: (a) The name, address and job classification of each person who prepared same; (b) The name, address and job classification of each person who presently has possession of same; ANSWER: (c) The dates and manner in which said material was distributed to purchasers of the products in answer to Interrogatory No. 5. No. (a)-(c) Not applicable. 39 44. Was any written material of any kind prepared by Defendant and distributed to those individuals listed in response to Interrogatory No. 9? If so, please state the following: (a) Identify the written material by content and date; (b) To whom was it delivered. ANSWER: Yes. (a) Note pads. The date the pads were prepared is unknown. (b) Unknown. 45. Does Defendant contend that asbestos-containing products can be manufactured so as to eliminate all potential health hazards to persons working with or around, installing or applying If so, please state the following: (a) The date that Defendant first determined that another product could be used in place of asbestos; (b) The chemical of the substitute; (c) Whether the substitute is suitable for the purpose for which they are to be used; (d) Whether Defendant used the substitute for asbestos to 1971; ANSWER: (e) Whether Defendant ever used the substitute for asbestos for high or low heat insulation. Unknown. Red Seal was not the manufacturer of any products containing asbestos. (a)-(e) Not applicable. 40 46. Did Defendant give any warnings to any individuals at the sites listed on Exhibit A, including any individuals who owned, operated, or managed the facilities at the sites listed on Exhibit A, regarding the potential health hazards of any product listed in response to Interrogatory No. 5. If yes, please state: (a) Name of person most knowledgeable about this communication. (b) Name of person at the sites listed on Exhibit A, attached hereto most knowledgeable about this communication. (c) Dates of each communication. (d) Contents of each communication. ANSWER: Warnings were stamped on packing lists. Where possible, yellow warning labels were placed on the products. Warnings were also affixed to products by the manufacturer. (a)-(d) Red Seal has no specific recollection of individual communications with representatives of the various work sites. 47. Did any person prior to 1970, file a claim against any Workers' Compensation carrier covering Defendant alleging that he or she contracted a disease as a result of exposure to asbestos? If so, please state the following: (a) A list of each such claim by claimant's name, date filed, the caption and jurisdiction involved; (b) The disease alleged in each such claim; (c) A brief summary of the disposition of each such claim; (d) The name, address and job classification of the person or persons having custody of the records pertaining to each such claim. 41 ANSWER: No. (a)-(d) Not applicable. 47.1 Please identify all documents concerning or in any way related to any decisions made by you to cease manufacturing asbestos-containing products. ANSWER: Not applicable. Red Seal did not manufacture any asbestoscontaining products. 47.2 Has any person or company from which you purchased asbestos-containing products ever issued a recall of their products or taken any action to take those products off the market after said products were in your possession? If so, provide: (a) the date of said recall; (b) the name of the company which issued the recall; (c) a copy of the recall. ANSWER: Not to the knowledge of Red Seal. (a)-(c) Not applicable. 47.3 State what action, if any, you have ever taken since 1930 to minimize or eliminate any risk of occupational disease or pneumoconiosis to those at any time engaged in the manufacture or production of asbestos-containing products. ANSWER: Not applicable. 42 47.4 State what action, if any, you have ever taken since 1930 to minimize or eliminate any risk of occupational disease or pneumoconiosis to those at any time engaged in the use, as distinguished from the manufacture, or exposed to the use of asbestos-containing or industrial insulation products or who were otherwise exposed to asbestos-containing or industrial insulation products. (a) describe such action; (b) state when such action was taken; (c) state what written material exists related to such action; (d) state the names, job titles and last known address of the individuals who undertook such actions. ANSWER: Red Seal placed warnings on packing lists and where possible, attached warning labels to the products it sold. Precautions were also taken at Red Seal Electric Company's facility to minimize the exposure of its employees to dust, including the availability of respiratory protection. (a)-(d) See response to Interrogatory 41. 48. Did Defendant receive notice prior to 1968 that any person was claiming injury or had sustained an abnormal x-ray reading as a result of using asbestos products manufactured, sold, installed, and/or distributed by Defendant? If so, please state: (a) The name and address of each claimant; (b) The date of notice of each claim; (c) A description of the claim; (d) The type of injuries allegedly sustained; (e) The name and address of each attorney representing 43 the individuals making such claims; (f) The style and court number of each such claim; (g) The resolution of each claim. ANSWER: No. (a)-(g) Not applicable. 48.1 Describe the method by which you have maintained records concerning the manufacture, sale, supply, distribution, use, advertising, delivery and/or installation or tear-out of each of asbestos-containing products. For each description provide the following: (a) each present and former company or corporate department, division or subdivision responsible for maintaining such records; (b) the manner in which the records are kept (e.g., boxes, computer tape, microfilm, etc.); (c) the inclusive dates of any such manufacture, sale, supply, distribution, use, advertising, delivery, and/or installation or tear-out which such record keeping system covers; (d) the present location at which all such records are maintained; (e) the identity of each person employed by you at any time from 1930 to the present who is or was responsible for the collection and maintenance of such records. ANSWER: Red Seal Electric has maintained sales records relating to the sale of asbestos-containing products. (a) Red Seal Electric Company. (b) In boxes. 44 (c) Approximately mid 1957 to 1986. (d) The original records are maintained at Red Seal Electric Company. (e) S. James Stryffeler is the custodian of these records. 48.2 State whether any records concerning the manufacture, sale, supply, distribution, advertising, delivery, use or installation or tear-out of asbestos-containing products have been destroyed or discarded and if so, indicate: (a) the date and location of such destruction or discard; (b) the custodian and location of such records prior to their destruction or discard and the identity of each employee, representative, official or agent who ordered, authorized or supervised such destruction or discard. ANSWER: Not to the knowledge of Red Seal. (a)-(b) Not applicable. 48.3 For all documents, other than invoices, work orders and/or purchase orders, which relate to matters relevant to all the preceding interrogatories: (a) Is there any kind of index for the documents? (b) How many pages is the index of documents? (c) How many documents are referred to in the index? (d) Is the index maintained in electronic format (i.e. database, word processing or other computerized format)? (e) What manner of electronic format is used? 45 ANSWER: No. (a)-(e) Not applicable. 48.4 For all invoices, work orders and/or purchase orders, which relate to matters relevant to all the preceding interrogatories: (a) Is there any kind of index for the documents? (b) How many pages is the index of documents? (c) How many documents are referred to in the index? (d) Is the index maintained in electronic format (i.e. database, word processing or other computerized format)? (e) What manner of electronic format is used? ANSWER: (a) No. (b) - (e) Not applicable. 49. Has Defendant obtained statements from any witnesses including the Plaintiffs? If so, please: (a) List each witness who has given a statement and the name, address, and job title of each person having custody of any such statement. ANSWER: Red Seal objects to Plaintiffs' Interrogatory as overbroad in that Red Seal Electric Company has been named as a defendant in numerous asbestos cases. Plaintiffs' Interrogatory is not in any way limited in scope. Furthermore, Red Seal does not know the 46 identity of the "witnesses" to which plaintiffs refer. Without waiver of these objections, Red Seal states that the only statements in its possession are copies of depositions of various plaintiffs and co-workers in the asbestos litigation that are in the possession of its counsel and that are equally available to plaintiffs. 50. Do you contend that the Plaintiff/Decedent improperly used those products listed in response to Interrogatory No. 5? so, please set out in detail in what respect the product was improperly used. If ANSWER: Red Seal objects to Plaintiffs' Interrogatory as overbroad. Without waiver of these objections, it is unknown whether any of the plaintiffs/decedents used any products sold by Red Seal. Discovery and investigation are continuing. 51. As to the sites listed on Exhibit A, and as to each Plaintiff/Decedent, please state whether Defendant contends that there was any substance other than asbestos which contributed or caused Plaintiff/Decedent's injuries. If your answer is yes, please state the following: (a) The facts upon which you rely; (b) The identity of the sources upon which you rely which substantiate these facts. ANSWER: Red Seal objects to Plaintiffs' Interrogatory as overbroad. Plaintiffs have identified in excess of 400 work sites on Exhibit A. Without waiver of these objections, Red Seal states that it 47 has insufficient knowledge concerning plaintiffs'/decedents' work history. Discovery and investigation in this regard are continuing. 52. Would any respirator, mask or breathing devices prevent inhalation of the asbestos dust and fibers contained in products listed in answer to Interrogatory No. 5? If so, state: (a) When the respirator was sold; (b) A detailed description of such respirator or other breathing devices, including name of manufacturer and model number; (c) The basis of your claim that such respirators or other breathing devices will prevent the inhalation of such dust and fibers; (d) Identify any tests performed regarding the efficaciousness of such respirators and other breathing devices in preventing the inhalation of asbestos dust and fibers including date, title, author and number; (e) List all documents which mention, allude or refer to tests performed on breathing devices which prevented the inhalation of asbestos dust and/or fibers. ANSWER: Red Seal has no knowledge of the specific types of respirators, masks or other breathing devices which would prevent inhalation of asbestos dust. (a)-(e) Not applicable. 53. Does Defendant expect to call expert witnesses at the trial of this case? If so, please state the following: (a) Their identity last known address; 48 (b) The subject matter on which the expert is expected to testify; (c) The expert's specific conclusion and specific opinions and the specific basis therefore; (d) The expert's qualifications to render the opinions set forth above; (e) Whether any person identified in sub-paragraph (a) above has provided a report or other documentation to you, and if so, identify such document or report; (f) Identify all documents that you have provided to each person identified in response to sub-paragraph (a) above; and (g) Describe in detail the education and work history of, and identify any books, treaties, article, published and unpublished reports, studies or other scholarly works authored by any individual identified in response to sub-paragraph (a) above. Alternatively, in lieu of said response, attach a copy of a resume or curriculum vitae and a list of publications to your answer. ANSWER: (a)-(g) Plaintiffs' Interrogatory is overbroad, unduly burdensome and premature as it relates to all the cases filed by Baron & Budd against Red Seal. Defendant Red Seal will identify its expert witnesses in accordance with the Court's Case Management Schedule as these cases are reached for trial and will provide the information required by the Ohio Rules of Civil Procedure. 49 54. Please state the name and last known address of each expert witness who is not retained or employed for that purpose who is an employee of Defendant and will render an opinion within his expertise at the time of trial. ANSWER: See response to Interrogatory 53. 55. Does Defendant admit that service of process was properly had on it in these cases? If not, please state why. ANSWER: Red Seal admits only that service of process in the cases received by Red Seal to date is proper. 55.1 For each and every affirmative defense asserted in Defendant's Answer to Plaintiffs' Complaint, or the cross-claims or counter-claims of any party against Defendant, state: (a) the facts upon which Defendant relies for each and every affirmative defense; (b) each and every document which will be offered to prove each and every affirmative defense; and (c) each and every witness who will testify in support of each and every affirmative defense. (d) the substance and subject matter of the anticipated testimony of each witness identified in the preceding response. ANSWER: (a)-(d) Plaintiffs' Interrogatory is overbroad, unduly burdensome and premature as it relates to all the cases filed by Baron & Budd against Red Seal. The identity of witnesses and exhibits that will be offered at trial will be disclosed in 50 accordance with the Court's Case Management Schedule as these cases are reached for trial. 56. Does Defendant have policies of insurance that might cover the claims that have been made by the Plaintiffs herein? ANSWER: (a) If so, please list the name of each insurance carrier who may have coverage, the amount of such coverage, and the dates of each such policy. Yes. (a) St. Paul Fire & Marine Insurance Company. The exact amount of coverage is unknown at this time. 56.1 Has Defendant ever been involved in any litigation concerning potential insurance coverage for asbestos products liability matters? If so, please state: (a) the case caption, court and date of filing of each case in which you have been involved; (b) whether you were Plaintiff or Defendant; (c) a brief statement of the issues; (d) identify by date, author and recipient(s), (including recipients of carbon copies) all documents listed as exhibits by either party in this litigation; (e) identify by deponent and date all individuals who were deposed in these cases; (f) identify by date, author and recipient(s) all documents that have been placed on a protective order in such litigation; (g) identify all expert witnesses retained for use at trial in any of the above litigation by name, address and telephone number. 51 ANSWER: No. (a)-(g) Not applicable. 57. Please state the name and address of each person who has knowledge of relevant facts regarding claims and defenses of this lawsuit. ANSWER: Plaintiffs' Interrogatory is overbroad, unduly burdensome and premature as it relates to all the cases filed by Baron & Budd against Red Seal. Red Seal will disclose its witnesses in accordance with the Court's Case Management Schedule as these cases are reached for trial. 58. State the last date that Defendant sold, distributed, manufactured, installed, and/or otherwise placed asbestoscontaining products into the stream of commerce. ANSWER: Red Seal never manufactured or installed products containing asbestos. Red Seal last sold asbestos-containing products in 1986. 52 KELLEY JASONS McGUIRE & SPINELLI, L.L.P. Robert N. Spinel li' Catherine N. Jasons PA Bar ID Nos. 28051/30105 Centre Square West, Suite 1500 1500 Market Street Philadelphia, PA 19102 Tel. (215) 854-0658 and John A. Kristan OH Bar ID No. 0073463 629 Euclid Avenue, Suite 1037 Cleveland, OH 44114 Tel. (216) 902-4444 Attorneys for Defendant Red Seal Electric Company 53 STATE OF OHIO COUNTY OF CUYAHOGA VERIFICATION ) ) SS. ) I, S. James Stryffeler, state that I am President of Defendant Red Seal Electric Company and am authorized to take this Verification on its behalf; and I have read the foregoing Responses of Defendant Red Seal Electric Company to Plaintiffs' Master Set of Interrogatories and find them true and correct to the best of my knowledge, information and belief. Sworn to and subscribed, before me, a Notary Public, in and for said County and State on this 0\U day of January, 2003. JUDITH ANN STRYFFELER Notary Public, State of Ohio, Cuy. Cty. My Commission Expires Feb. 2, 200? CERTIFICATE OF SERVICE A copy of the foregoing Responses of Defendant Red Seal Electric Company to Plaintiffs' Master Set of Interrogatories was served by First Class Mail on plaintiffs' counsel Ladd R. Gibke, Esquire, Baron & Budd, P.C., 3102 Oak Lawn Avenue, Suite 1100, Dallas, TX 75219 and by notice to all defense counsel via CLAD, this 21st day of January, 2003. Catherine N. Jasons EXHIBIT A BARON & BUDD SITE LIST Adams Eng., Cleveland, OH Adco Chemical & Supply Co., Columbus, OH Aeronca Aircraft Corp., Middletown, OH Akron Reserve Lumber, Ajkron, OH Allegeny Power System, New Martinsville, WV Alliance Machine Co., Alliance, OH Alliance Ware, Alliance, OH Alliance Yard, Alliance, OH Aluminum Corp., Cleveland, OH Aluminum Smelter, Hamilton, OH American Bakeries Plant, Cincinnati, OH American Firebrick Co., Cleveland, OH American International Aluminum Corp., Warren, MI American Shipbuilding Co. American Steel & Wire, Cleveland, OH American Steel Foundry, Alliance, OH American Zinc & Chemical Co., Langeloth, PA American Roller Co., Cincinnati, OH American Packaging Corp. - a/k/a Interstate Folding Box, Middletown, OH Anchor Hocking Glass, Plant One, Lancaster, OH Anchor Hocking Glass, Plant Two, Lancaster, OH Anchor Hocking Glass, Lancaster, OH Anchor Hocking Glass, Bremen, OH Anchor Hocking Glass, Clarksburg, WV Anchor blocking Glass, Winchester, OH Anchor Hocking Glass, Monaca, PA Apex Powder Corp., Canton, OH Apex Smelting Co., Cleveland, OH A.P. Green, North Lawrence, OH Armco Steel, Hamilton, OH Armco Steel, Washington Courthouse, OH Aimco Steel, Muskingham County, OH Armco Steel, Middletown, OH Armco Steel, Houston, TX Armco Steel, Ambridge, PA Armco Steel, Mt. Coal, WV Armco Steel, Ashland, KY Armco Steel, New Miami, OH Armco Steel, Piqua, OH Armco Steel, Butler, PA PLAINTIFFS' MASTER SET OF INTERROGATORIES PROPOUNDED TO RED SEAL ELECTRIC - PAGE 49 Ni OHIO CUYAHOGA DISCOVER all redseal rog wpd Armco Steel, Marion, OH Armco Steel, Pittsburgh, PA Ashland Oil, Middletown, OH Ashtabula Yard, Ashtabula, OH Associated Paper Products, Germantown, OH Atlantic Foundry, Wadsworth, OH B. F. Goodrich, Akron, OH Babcock & Wilcox, Barberton, OH Babcock & Wilcox, Canton, OH Beaver Powerhouse, Beaver, PA Beck Jord Power Plant, Cincinnati, OH Bedford Yard, Bedford, OH Bellville Mining Co., Wheelersburg, OH Bethlehem Steel Co., Johnstown, PA Black Clawson Co., Hamilton, OH Black Clawson Co., Middletown, OH Blaw-Knox Co., Martins Ferry, OH Blaw-Knox Corp., Wheeling, WV Boeing North America Inc., Columbus, OH Bolling Oven & Machine, Cleveland, OH Borden's Chemical, Cincinnati, OH Borg-Warner, Louisville, OH Branch Candy Co., Chicago, IL Bremco Industries, Bremen, OH Brookhaven National Labs, New York, NY Brush Beryllium, Cleveland, OH Buckeye Steel, Hannibal, OH Buckeye Steel, Columbus, OH Buffalo Yard, Buffalo, NY Canton Provision Co., Canton, OH Canton Iron & Metal Co., Canton, OH Canton Drop Forge Corp., Canton, OH Canton Yard, Canton, OH Carborundum Grinding Wheel Co., Logan, OH Cardinal PS/Brilliant PS/Tidd PS, Brilliant, OH Carling Brewing Co., Cleveland, OH C. C. Dunlap Lumber Co., Delaware, OH Central Brass Foundry, Cleveland, OH Central Foundry - General Motors, Defiance, OH Central Motor, Dayton, OH Centre Foundry, Wheeling, WV Champion Paper, Hamilton, OH Champion Paper Co., Hamilton, OH PLAINTIFFS' MASTER SET OF INTERROGATORIES PROPOUNDED TO RED SEAL ELECTRIC - PAGE 50 N. OHIO CUYAHOGA DISCOVER oil reJseji rog wpd Chase Brass, Cleveland, OH Chelsea Machine Service, Dayton, OH Chrysler Yard, Twinsburg, OH Cincinnati Cordage & Paper Co., Cincinnati, OH Cincinnati Gas & Electric Co., Cincinnati, OH Circle Floor Co., New York, NY Clark Oil & Refining Corp., Middletown, OH Clark Oil, Canton, OH Cleveland Cliffs Iron Co. Cleveland Foundry, Cleveland, OH Clevite Research, Cleveland, OH Club Aluminum, Cleveland, OH Coca-Cola Factory, Columbus, OH Coffman Stair Co., Washington Courthouse, OH Collins Mining Co., Hanging Rock, OH Collinwood Yard, Collinwood, OH Colonial Foundry, Louisville, OH Columbus Yard, Columbus, OH Combustion Engineering, Huntly Station, OH Continental Can Co., Middletown, OH Contours, Inc., Orrville, OH Conway Yard, Freedom, PA Cooper & Jackson, Dayton, OH Cooper Weld Steel Co., Warren, OH Cooper Tire, Findley, OH Copperweld Steel, Newton Falls, OH Copperweld Steel, Warren, OH Crown Steel, Orville, OH Crucible Steel Co., Midland, PA Crystal Tissue Co., Middletown, OH Curtiss Wright Corp., Columbus, OH Custer City Chemical Co., Custer City, PA Cuyahoga Foundry, Cleveland, OH D&A Plumbing, Canton, OH D&S Floors, Akron, OH Dayton Walther, Portsmouth, OH Dayton Rubber Co., Dayton, OH Dayton Press, Dayton, OH Dayton-Walther Corp., Dayton, OH Delco Products, Dayton, OH Detroit Diesel Allison, Detroit, MI Diamond Ntl. Paper Mill, Middletown, OH Diebold, Canton, OH PLAINTIFFS' MASTER SET OF INTERROGATORIES PROPOUNDED TO RED SEAL ELECTRIC - PAGE 51 N: OHIO CUYAHOGA DISCOVER'jlI.redseal rog.v.-pd Diggle Machine & Tools, Muscle Shoals, AL Dumas Steel, Pittsburgh, PA Dunbar & Sullivan, Cleveland, OH Dunlap Tire & Rubber, Massillon, OH DuQuesne Steel, DuQuesne, PA E. I. Dupont, Spalter, WV Ebco Manufacturing Co., Columbus, OH Engle Stone, Co., Pedro, OH Erie Yard, Erie, PA Exselo, Middletown, OH Femald Atomic Plant, Cincinnati, OH Ferro Corp., Cleveland, OH Firestone Tire & Rubber Co., Middletown, OH Firestone Tire & Rubber Co., Akron, OH Fisher Body, Cleveland, OH Fisher Favio, Cleveland, OH Fleet Aerospace (a/k/a Aeronca), Middletown, OH Ford Motor Foundry, Brookpark, OH Ford Motor Co., Canton, OH Ford Motor Co., Hamilton, OH Ford Motor Co., Brookpark, OH Ford Motor Co., Cleveland, OH Ford Motor Co., Sharonville, OH Ford Motor Co., Batavia, OH Ford Motor Co., Fairfax, OH Ford Yard, Walton Hills, OH Frigidaire Co., W. Carrollton, OH Frigidaire Co., Dayton, OH Frigidaire Co., Moraine City, OH Ft. Hamilton-Hughes Hospital, Hamilton, OH Gardner Board & Carton Co., Middletown, OH Gateway Yard, Youngstown, OH Gear Co. ofAmerica, Cleveland, OH General Electric, Canonsburg General Electric, Cincinnati, OH General Electric, Cleveland, OH General Electric, Evendale, OH General Mills, Lancaster, OH General Motors, Brookpark, OH General Motors, Cleveland, OH General Motors, Columbus, OH General Motors, Dayton, OH General Motors, Hamilton, OH PLAINTIFFS' MASTER SET OF INTERROGATORIES PROPOUNDED TO RED SEAL ELECTRIC - PAGE 52 N OmO'CUYAHOGA'\DISCOVHR\all redseal rog.wpd General Motors, Lordstown, OH General Motors, Moraine, OH General Motors, Norwood, OH General Motors, Vandela, OH Girard Yard, Girard, OH Goodrich, Akron, OH Goodyear Aerospace, Akron, OH Goodyear Atomic, Dayton, OH Goodyear Tire & Rubber Co., Middletown, OH Granite City Steel, Granite City, IL Greater Cleveland Regional Transit Authority, Cleveland, OH Greer Steel, Dover, OH Gregory Galvanizing Co., Canton, OH Gulf Refinery, Philadelphia, PA Hamilton Foundry, Hamilton, OH Hamlin Metal, Akron, OH Hardesty Chemical Co., Dover, OH Harding Jones Paper Co., Middletown, OH Harrison PS, Shinnston, WV Hercules Motor Corp., Canton, OH Hercules Power Co., Dublin, VA Hermann Manufacturing Corp., Lancaster, OH Hilshire Clark Electric, Canton, OH Hoover Vacuum, Canton, OH Hoskins Brothers Drywall, Cincinnati, OH Howard Paper Mills (a/k/a Champion Int. & St. Regis), Franklin, OH ICS Construction Co., Monroe, MI Ideal Foundry, Newton Falls, OH Ideal Foundry, Newton Falls, OH Illinois Light & Power, Venice, IL Industrial Firebrick Co., Cleveland, OH Ingersole Rand Plant, Athens, PA Inland Container Corp., Middletown, OH International Paper, Florence, KY Isley a.k.a. Superior Diary, Canton, OH J & L Specialty Steel, Canton, OH Jefferson Smurfit, Hamilton, OH Jefferson Smurfit, Middletown, OH Jones & Laughlin Steel, Louisville, OH Jones & Laughlin Steel, Cleveland, OH Jones & Laughlin Steel, Youngstown, OH Jones & Laughlin Steel, Pittsburgh, PA Jones & Laughlin Steel, Aliquippa, PA PLAINTIFFS' MASTER SET OF INTERROGATORIES PROPOUNDED TO RED SEAL ELECTRIC - PAGE 53 NaOHIO'CUYAHOGA'DISCOVER all,redseal.rog.v>pd Kaiser Aluminum, Ravenswood, WV Kauffman Plumbing & Heating Ken Lea Craft, Cambridge, VA Kent State University, Kent, OH Kent State University, Canton, OH Kimberly Clark Corp., Miamisburg, OH King Powder Co., King Mills, OH Kinsman Street Yard, Cleveland, OH Lancaster Glass Corp., Lancaster, OH Lavino Chemical Co., Philadelphia, PA Levinson Steel Co., Pittsburgh, PA Leyman Corp., Cincinnati, OH Liberty Paper Board Co., Steubenville, OH Loblaw Warehouse, Youngstown, OH Lorillard, Inc., Lima, OH LTV Steel, Cleveland, OH LTV Steel Briar Hill Works, Youngstown, OH LTV Steel, Campbell Road, Cleveland, OH LTV Steel, Massillon, OH LTV Steel, East 45th Street, Cleveland, OH LTV Steel, Wanen, OH LTV Steel, West third Street, Cleveland, OH LTV Steel (f/k/a Republic Steel), Niles, OH LTV Steel Campbell Works, Youngstown, OH LTV, Newton Falls, OH LTV Steel, Jennings Road, Cleveland, OH LTV Steel, Youngstown, OH Lucans Steel, Massillon, OH Magnode Corp., Trenton, OH Malibu Steel, Sharon, PA Mansfield Sanitary Inc., Perrysville, OH Mansfield Yard, Mansfield, OH Marathon Station, Sharonville, OH Martin Pilot, Massillon, OH Martin Marietta, Woodville, OH Massillon Rubber Co., Massillon, OH Massillon Steel Casting Co., Massillon, OH Maxwell Paper Co., Franklin, OH McComber Steel, Canton, OH Meade Paper, Chilicothe, OH Merritt, Chapman & Scott, Cleveland, OH Miami Carey, Middletown, OH Mid America Spec. Dist., Youngstown, OH PLAINTIFFS' MASTER SET OF INTERROGATORIES PROPOUNDED TO RED SEAL ELECTRIC - PAGE 54 N; OHIO CUYAHOGA DISCOVER all.redseal rog wpd r,.;;/:;..c^eel, Cleveland, OH Mingo Junction Yard, Mingo Junction, OH Mohawk Foundry, Cleveland, OH Mohawk Foundry, Garfield, OH Mold Rite Plastics, Inc., Cambridge, OH Monark Tire & Rubber Co., Hartville, OH Monoglass Fibers, Breeman, OH Monsanto, Dayton, OH Monsanto, Miamisburg, OH Monsanto, Cincinnati, OH Mound Chemical Plant, Miamisburg, OH MRI, Akron, OH Murray Oil Manufacturing Co., Cleveland, OH Muscle Shoals Industries, Florence, AL National Iron & Metal Co., Canton, OH National Rubber Machinery Co., Akron, OH National Screen & Manufacturing, Cleveland, OH National Screen & Manufacturing, Mentor, OH National Steel, Wierton, WV National Cash Register, Dayton, OH Nickel Plate Railroad, Lima, OH Niles Junction Yard, Niles, OH Norfolk & Western Railroad, Massillon, OH Norfolk & Western Railroad, Zanesville, OH Norfolk & Western Railroad, Canton, OH Northstar Steel, Youngstown, OH Oglebay Norton Coal Mines, Mullins, WV Ohio Brass Co., Barberton, OH Ohio Box Board Co., Rittman, OH Ohio Edison, Akron, OH Ohio Edison, Youngstown, OH Ohio Foundry, Cleveland, OH Ohio Foundry & Manufacturing Co., Steubenville, OH Ormet Corp., Potman, OH Owens Coming, Toledo, OH Owens-Illinois (a/k/a Tech Glass, a/k/a 01 Neg.), Columbus, OH Pascola Coal Mine, Salem, OH Pepsi Cola Bottling Co., Portsmouth, OH Pepsi Cola Bottling Co., Hamilton, OH Perkins Diesel, Canton, OH Permanent Mold and Die, Florence, AL Philip Carey Corp., Monroe, OH Philip Carey Corp., Middletown, OH PLAINTIFFS' MASTER SET OF INTERROGATORIES PROPOUNDED TO RED SEAL ELECTRIC - PAGE 55 N. OHIO CUYAHOGA DISCOVERall.redseal.rog.wpd Philip Carey, Cincinnati, OH Picker International, Inc., New York, NY Pillsbury Co., Hamilton, OH Pittsburgh and Lake Erie Railroad Company, Newell, PA Pittsburgh Foundry Corp., Pittsburgh, PA Pollock Paper Co., Middletown, OH Poly Clinic Hospital and Medical School, New York, NY Power Press Steel, Hubbard, OH PPG Industries, Middletown, OH PPG Industries, Barberton, OH Precision Rubber Products, Dayton, OH Precision Castings Co., Cleveland, OH Premier Industries, Cleveland, OH Princess Susan Coal Co., WV Pure Oil Refinery, Lima, OH Quality Castings Co., Orville, OH Queen City Steel, Cincinnati, OH Ralston Purina, Cincinnati, OH Rayon Co., Cleveland, OH Reeves Steel & Manufacturing Co., Dover, OH Reynolds Metals Co., Richmond, VA Reo Industries, Massillon, OH Republic Rubber, Youngstown, OH Republic Steel, Massillon, OH Republic Steel, Niles, OH Republic Steel, Plant B, Canton, OH Republic Steel, Newton Falls, OH Republic Steel, Berger Plant, Canton, OH Republic Steel, South Division, Massillon, OH Republic Steel, Union Drawn Steel, Massillon, OH Republic Steel, Cleveland, OH Republic Steel, Plant A, Canton, OH Republic Steel, 3 Shop, Canton, OH Republic Steel, Warren, OH Republic Steel, 4 Shop, Canton, OH Republic Engineered Steel Inc. (RESI), Canton, OH Republic Steel, Canton, OH Republic Steel, Eighth Street Plant, Canton, OH Republic Steel, Youngstown, OH Republic Steel, Stark Division, Canton, OH Republic Steel, Culvert Division, Canton, OH Residential Homes (home repairman). Canton, OH Residential Homes (home repairman), Cleveland, OH PLAINTIFFS' MASTER SET OF INTERROGATORIES PROPOUNDED TO REP SEAL ELECTRIC - PAGE 56 N OHIO CUYAHOGA DISCOVER .all redseal rog ivpd Residential Homes (home repairman), Flatwoods, WV Residential Homes (home repairman), Medina, OH Reyerson Steel Co., Cincinnati, OH Rockport Yard, Cleveland, OH Schaefer Valve Co., Orville, OH Sharon Steel, Louisville, OH Sharon Steel, Sharon, PA Shell Oil Co., Hamilton, OH Shell Oil Co., Middletown, OH Shell Station, Sharonville, OH SIA a/k/a Sancap, Alliance, OH Sieple Lithograph Co., Canton, OH Simcraft Tool & Gage, Dayton, OH Sintermet, Brookpark, OH S.K.. Wellman, Bedford, OH S.K. Wellman, Brookpark, OH Sohio Refinery, Cleveland, OH Sorg Paper, Middletown, OH South Central Die Co., Florence, AL Southwestern Ohio Steel Co., Hamilton, OH Sperry Rand Corp., Huntsville, AL St. Joseph Lead Co., Monaca, PA Standard Oil Company, Cleveland, OH Standard Plumbing & Heating Standard Oil Company, Middletown, OH Standard Oil Company, Canton, OH Stark Ceramics, East Canton, OH State Metals & Steel Co., Canton, OH Stone Container Corp. (a/k/a Boxboard Corp.), Franklin, OH Strong Enamel, Sebring, OH Sun Oil Refinery, Toledo, OH Sun Oil Co., Markes Hook, PA Sun Rubber, Barberton, OH Superior Foundry Co., Cleveland, OH Superior Sheet & Steel, Louisville, OH Surface Combustion Co., Mingo Junction, OH Tallo Plant, New Orleans, LA Taylor Steel Inc., Niles, OH Tennessee Eastman Corp. Oak Ridge, TN Texaco Refinery, Toledo, OH The Timken Company, aka Timken Roller Bearing, Navarre Road SW, Canton, OH The Timken Company, aka Timken Roller Bearing, Dueber Avenue, Canton, OH The Timken Company, aka Timken Roller Bearing, Canton, OH PLAINTIFFS' MASTER SET OF INTERROGATORIES PROPOUNDED TO RED SEAL ELECTRIC - PAGE 57 N.OHIO'CUYAHOGA DISCOVER all redseal rog wpd Thompson Ramo Woolridge (TRW), Cleveland, OH Timken Steel, Harrison Plant, Canton, OH Timken Steel, Faircrest Plant, Canton, OH Timken Bearing Division, Gambrinus Plant, Canton, OH Timken Steel, Wooster, OH Timken Steel, Gambrinus Plant, Canton, OH Timken Bearing, Wooster, OH Tyson Bearing Co., Massillon, OH USA Quick Print #2, Canton, OH USA Quick Print #3, Canton, OH USA Quick Print #5, Canton, OH U.S. Steel, Lorain, OH U.S. Steel, Clairton, PA U.S. Steel, Cleveland, OH U.S. Steel, Johnstown, PA U.S. Steel, McDonald, OH U.S. Steel, Ronco, PA U.S. Steel, Allenport, PA U.S. Steel (a/k/a Carnegie Illinois Steel Corporation), Mingo Junction, OH U.S. Steel, McKeesport, PA U.S. Steel, Ohio Works, Youngstown, OH U.S. Steel, Homestead, PA U.S. Steel, McDonald Works, Youngstown, OH U.S. Steel, Clairton, PA U.S. Rubber, Clinton, OH U.S. Steel, Canton, OH U.S.S. Higbee U.S.S. Queen Mary U.S.S. Sipan Unimet Corp., Canton, OH Union Carbide Corp., Marietta, OH Union Metal, Canton, OH Union Carbide Corp., Ashtabula, OH Union Carbide Corp., Long Branch, WV United Welding Co., Middletown, OH Val Decker Packing Co., Piqua, OH Valley Paper Converting Co., Toronto, OH Valley Mold, Hubbard, OH Valley Mold & Iron, Hubbard, OH Vinton Dale Cole Mine, PA Visioneering Co., Chicago, IL Visioneering Co., Cleveland, OH Wade Youmans, Alliance, OH PLAINTIFFS' MASTER SET OF INTERROGATORIES PROPOUNDED TO RED SEAL ELECTRIC - PAGE 58 N. OHIO CUYAHOGA >ISCO\ HR all redseal rog.wpd Wallace Forge Tool & Dye, Canton, OH Warner & Swaser, Cleveland, OH Warner Iron Comp Foundry, TN Washington Steel, Massillon, OH WCI Steel, Warren, OH Weber Dental Manufacturing, Canton, OH Weirton Steel, Weirton, WV West Virginia Steel & Mfg. Co., Huntington, WV Westinghouse Electric Co., Cleveland, OH Westinghouse Electric Co., Columbus, OH Wheeling-Pitt Steel, Beechbottom, WV Wheeling-Pitt Steel, Martins Ferry, OH Wheeling-Pitt Steel, Monessen, PA Wheeling-Pitt Steel, Allenport, PA Wheeling-Pitt Steel, North Plant (Steubenville) Wheeling-Pitt Steel, Benwood, WV Wheeling-Pitt Steel, Yorkville, OH Wheeling-Pitt Steel, South Plant (Mingo Junction) Wheeling-Pitt Steel, East Plant (Follansbee, WV) Wheeling-Pitt Steel, Warwood, WV Wheeling-Pitt Steel, Wheeling, WV Whiskey Island Yard, Cleveland, OH Wilkoff Steel & Supply Co., Canton, OH Wooster Yard, Wooster, OH Worthington Steel, Monroe, OH Wrerui Paper Co., Middletown, OH Wright Aeronautical, Corp., Evandale, OH Xerox Corp., Columbus, OH Yoder Brothers, Inc., Barberton, OH Youngstown Sheet & Tube/Lykes Steamship, Campbell, OH Youngstown Sheet & Tube, Youngstown, OH Youngstown Waste Water Treatment Plant, Youngstown, OH PLAINTIFFS' MASTER SET OF INTERROGATORIES PROPOUNDED TO RED SEAL ELECTRIC - PAGE 59 N. OHIO CUYAHOGADISCOVER all.redseal rog.u-pd _____________ __ _ A 11 ; r n 9 y_s_A t__L_a w KELLEY JASONS McGUIRE & SPINELLI, L.L.P. lohn Patrick leHey** 'i'r.Ttr L P> Armand 1 Della Porta lr*k Robert N Sptnelli-O Thomas P Hanna **.aj* Michael L Turner* Richard l Walker II* Timothy McGowan* Neal C Glenn*e W Matthew Reber** R Steven Porreca** .Angela M Coll** lohn A Kristan 2: ) Of Counsel foseph W McGuire** Matthew D Blum. M D * * WnM or j P-'rr-s.'Adntd Bdr ^ Member i \<3`a (erse\ Bar \S'*rrr'f j LeL'Adre Bar 7 Mcmivr i Bar\nz<snci S Member *i \ic*a Y *rk Bar J Momber I Washington 0 C Bar Member .>1 Maryland Bar Z Wmt e1* t Ohio Bar ) \Vr{ er rmCm nn<i gar January 21, 2003 / Ladd R. Gibke, Esquire Baron & Budd, P.C. 3102 Oak Lawn Avenue, Suite Dallas, TX 75219 1100 RE: All Baron & Budd Cases in which Red Seal Electric Is Named as Defendant, Court of Common Pleas, Cuyahoga County, Ohio, Asbestos Master Case No. 073958 Dear Mr. Gibke: Enclosed please find the Responses of Defendant Red Seal Electric Company to Plaintiffs' Master Set of Interrogatories and Plaintiffs' Requests for Production of Documents. Very truly yours, KELLEY JASONS McGUIRE & SPINELLI, L.L.P. '-J / Catherine N. .yasons CNJ/ld Enclosures KIM&S Philadelphia ti.irr .v-.r r;K .nc^* a NW2 *21 ^j rV>4- )*>*>>* Fix >2I5 JJ54-8434 \*?.v rrr^c. >5^'- 4 " --csJl'r Hadd 'r*f>e!d M *?o 52J-* >! 74 85<>o22*0 |V6 r` re.uA-irr ~.'=,r ,r Ar.**--'- - f H ' '4 4 L'r- 'J* " . X'j /)52-*85r.O F-i* - ;02 ^2*8405 '-'t-. T-.*r' -e T - "*' 3" _ _ * -j' 3 .44 4 .. 0 "i_-4444 F-j\ * Id > ^02-444 7 IN THE COURT OF COMMON PLEAS CUYAHOGA COUNTY, OHIO IN RE: ALL BARON & BUDD CASES IN WHICH RED SEAL ELECTRIC IS NAMED AS DEFENDANT Plaintiffs, v. A-BEST PRODUCTS COMPANY, et al. Defendants ASBESTOS MASTER CASE NO. 073958 JUDGE HARRY A. HANNA NOTICE OF SERVICE OF RESPONSES OF DEFENDANT RED SEAL ELECTRIC COMPANY TO PLAINTIFFS' MASTER SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS Please take notice that the Responses of Defendant Red Seal Electric Company to Plaintiffs' Master Set of Interrogatories and Requests for Production of Documents were served by First Class Mail upon plaintiffs' counsel, Ladd Gibke, Baron & Budd, P.C., 3102 Oak Lawn Avenue, Suite 1100, Dallas, Texas, 75219, this 21st day of January, 2003. KELLEY JASONS McGUIRE & SPINELLI, L.L.P. /s/ Electronically filed Robert N. Spinelli Catherine N. Jasons PA Bar ID Nos. 28051/30105 Centre Square West, Suite 1500 1500 Market Street Philadelphia, PA 19102 Tel. (215) 854-0658 and John A. Kristan OH Bar ID No. 0073463 629 Euclid Avenue, Suite Cleveland, OH 44114 Tel. (216) 902-4444 1037 Attorneys for Defendant Red Seal Electric Company I hereby certify that the foregoing Notice of Service of Responses of Defendant Red Seal Electric Company to Plaintiffs' Master Set of Interrogatories and Requests for Production of Documents was filed electronically on the CLAD system and deemed served on all parties pursuant to the Cuyahoga County Rules of Court, this 21st day of January, 2003. /s/ Electronically filed Catherine N. Jasons