Document knG7yEJ44DgZenXBrpwyBGxq

FILE NAME Paccar PAC DATE 2023 Jan 23 DOC PAC011 DOCUMENT DESCRIPTION Legal - Paccar's Objections & Responses to Plaintiffs Interrogatories Dickinson v Paacar Ex H EXHIBIT H LAVIN CEDRONE GRAVER BOYD & DISIPIO BY John J. Bateman Esquire No. 49447 Suite 500 190 North Independence Mall West 6th & Race Streets Philadelphia PA 19106 215 627-0303 Counsel for Defendant PACCAR Inc CHARLES W. DICKINSON AND MICHELLE A. DICKINSON V. PACCAR INC and its unincorporated divisions Kenworth Truck Company and Peterbilt Motors Co. ET AL PHILADELPHIA COUNTY COURT OF COMMON PLEAS FEBRUARY TERM 2022 NO 0935 ASBESTOS CASE DEFENDANT PACCAR INC'S OBJECTIONS AND RESPONSES TO PLAINTIFFS INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS DIRECTED TO DEFENDANT PACCAR INC TO Jenna Kristal Egner Esquire Maune Raichle Hartley French 230 S. Broad Street Suite 1010 Philadelphia PA 19102 & Mudd LLC COMES NOW Defendant PACCAR Inc PACCAR and serves its Objections and Responses to Plaintiffs Interrogatories and Requests for Production of Documents to PACCAR the Requests and states as follows The discovery responses that follow are based on the knowledge and information possessed by PACCAR's attorneys and their agents and staff unless otherwise privileged as well as knowledge and information known to PACCAR PACCAR may not have any knowledge or information concerning a particular Request Verification by PACCAR is not an indication that PACCAR has any knowledge personal or otherwise concerning any particular Response which has been provided Moreover the language and word usage in the answers to these Requests include that of PACCAR's attorneys As a result some or all of these answers may not be in the words or language which PACCAR itself might use PRELIMINARY STATEMENT These discovery responses are provided only for those products identified by Plaintiffs and to which Plaintiffs allege exposure These discovery responses are based on an ongoing review of PACCAR's documents and information obtained from ongoing discussions with various PACCAR personnel Much of the information requested dates back many years and is difficult or impossible to reconstruct or retrieve These discovery responses are made pursuant to a reasonable and diligent investigation and search for the information requested PACCAR reserves the right to amend these discovery responses if new or additional information becomes available to it PACCAR prepared these discovery responses with the assistance of counsel No single employee officer or agent of PACCAR has hand knowledge regarding each and every response The person signing these responses does so to satisfy whatever requirement may exist under the applicable rules regarding verification That person is informed and believes that the information known as of the date of his signature supports the discovery responses below DEFINITIONS AND INSTRUCTIONS Plaintiffs definitions and instructions are not repeated herein for the sake of brevity PACCAR objects to Plaintiffs definitions and instructions to the extent they are overbroad unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence PACCAR further objects to Plaintiffs definitions and instructions to the extent they include meanings and characterizations inconsistent with PACCAR's interpretation of the defined terms and phrases GENERAL OBJECTIONS a PACCAR objects to Plaintiffs Requests to the extent that they seek corporate knowledge as it is impossible for PACCAR to set forth the collective knowledge of all of its past or present employees PACCAR reserves the right to revise correct supplement and amend its discovery responses to provide information discovered subsequent to the responses contained herein PACCAR asserts the following objections and incorporates each by reference into each and every Response to Plaintiffs Requests set forth herein b PACCAR asserts the right to object on the grounds of competency privilege relevancy materiality or any other proper ground to the use of any said discovery response for any purpose in whole or in part in any subsequent step or proceeding in this litigation c PACCAR asserts the right to object on any other ground to other requests or other discovery procedures involving or relating to the subject matter of the Requests answered herein d PACCAR asserts the right to revise correct supplement or clarify any of its discovery responses set forth herein at any time and PACCAR reserves the right to object to the use of these discovery responses at trial or any other proceeding as deemed necessary and appropriate by PACCAR e PACCAR objects to the extent Plaintiffs seek documents no longer in PACCAR's possession PACCAR's document retention policy is 7 years save for documents that fall under specific categories As such PACCAR may no longer possess documents responsive to certain Requests f PACCAR objects to Plaintiffs Requests to the extent that they involve matters outside of the geographical area at issue in this litigation and limits its discovery responses to said area g Furthermore these Requests ask PACCAR to disclose information of which may no longer exist or may not be readily available is unrelated to the products at issue in this case Such information is also unrelated to the locations at which Plaintiffs may have used any PACCAR product the conditions under which Plaintiffs may have used any PACCAR product the time period during which Plaintiffs may have used any PACCAR product or the time period during which Plaintiffs allege exposure to any PACCAR product Thus Plaintiffs Requests seek information which is neither material nor relevant to the issues in this litigation are overbroad in time scope and location and are otherwise not reasonably calculated to lead to the discovery of admissible evidence h Plaintiffs Requests are oppressive burdensome and would require PACCAR to undertake a massive and extraordinary document search the results of which would have little to no demonstrable bearing on this litigation in light of the alleged exposure Moreover many of these Requests are not susceptible to a response because they request information which dates back many years and is now virtually impossible for PACCAR to reconstruct or retrieve in its entirety PACCAR objects to Plaintiffs Requests because they were propounded to harass and coerce a settlement despite the lack or complete absence of verifiable product identification and the lack of evidence of injury as a result of alleged exposure to or use of any product which PACCAR may or may not have manufactured q@) PACCAR objects to these Plaintiffs Requests because they are propounded for an additional improper purpose namely as a fishing expedition for the purposes of obtaining information that may be taken out of context by Plaintiffs counsel to create allegations against PACCAR where none may legitimately exist k PACCAR objects to Plaintiffs Requests as overbroad in that they seek information from entities other than itself or its predecessors PACCAR over the course of its long history has owned several businesses which are not involved in the instant litigation Therefore all references in Plaintiffs Requests to DEFENDANT YOU or YOUR and the like are assumed to refer only to PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company 1 PACCAR objects to each and every Request that seeks production of any information constituting a trade secret confidential financial data or other confidential research development or commercial information m PACCAR objects to each and every Request that seeks production of any information constituting a trade secret confidential financial data or other confidential research development or commercial information n PACCAR objects to Plaintiffs Requests as argumentative because they assume that a health hazard is created by the PACCAR products that may have incorporated asbestos- containing component parts which PACCAR denies o PACCAR objects to Plaintiffs Requests on the basis that they are vague and ambiguous Requests relating to certain diseases fail to provide facts relating to the amount of exposure duration of exposure fiber type in exposure and latency period p PACCAR objects to Plaintiffs Requests in that they tend to group together all of Defendants in this litigation and are therefore overbroad unduly burdensome harassing and not calculated to lead to the discovery of relevant and material evidence q PACCAR objects to each and every Request that calls for either pure speculation or legal conclusions on the part of PACCAR r PACCAR objects to each and every Request that calls for a medical conclusion beyond the scope of PACCAR's knowledge and capability s PACCAR objects to each and every Request that purports to impose any obligations on it that are not set forth in the Pennsylvania Code of Civil Procedure or the Pennsylvania Supreme Court Rules t PACCAR objects to each and every Request that seeks information protected by the attorney privilege or attorney work product doctrine u PACCAR objects to each and every Request that seeks disclosure of information generated by persons other than PACCAR that has come into the possession of PACCAR's counsel during the course of discovery and trial preparation in asbestos litigation v PACCAR objects to each and every Request that seeks information for any time period unrelated to Plaintiffs alleged exposure w PACCAR objects to each and every Request that seeks information that is not under PACCAR's custody or control or which is within the public domain or otherwise equally available to Plaintiffs or their counsel Subject to and without waiving any of the foregoing objections PACCAR states as follows OBJECTIONS AND RESPONSES TO PLAINTIFFS INTERROGATORIES INTERROGATORY NO 1 With respect to the individual verifying these answers on your behalf state the following a their name b their present business address C. their present job title d their date of employment with you each job title they held while they were employed ANSWER PACCAR incorporates its Preliminary Statement and General Objections PACCAR also objects to the extent this Interrogatory seeks private information of individuals that are not parties to this litigation Subject to and without waiving the foregoing objections PACCAR prepared its Answers to Plaintiffs Interrogatories and Requests for Production with the assistance of counsel No single employee officer or agent of PACCAR has firsthand knowledge regarding each and every response The following responses were prepared based upon the review of various documents and discussions with various individuals over the course of many years Because many of the subjects of inquiry occurred in some instances more than several decades ago it is extremely difficult to pinpoint with any degree of accuracy when certain information was obtained or the identities of the individuals who may have located the information Rod Curbo PACCAR's corporate representative has verified these answers and has supplied responsive information Mr. Curbo's knowledge is based on his experience with the company and his conversations over the years with various Peterbilt and Kenworth personnel INTERROGATORY NO 2 State whether you are a corporation If so state a Your full corporate name b the state of incorporation C. the date of incorporation d the address of your principal place of business ANSWER PACCAR incorporates its Preliminary Statement and General Objections Furthermore PACCAR objects to the extent that this Request seeks information that is within the public domain or otherwise equally available to Plaintiffs or their counsel Subject to and without waiving the foregoing objections this Defendant's name is PACCAR Inc no punctuation PACCAR is incorporated in Delaware with its principal place of business at 777 106th Avenue Bellevue Washington 98004 INTERROGATORY NO 3 Has this Defendant ever been identified known or done business under any other name If so please state such name or names and the time period during which this Defendant was so known or identified ANSWER PACCAR incorporates its Preliminary Statement and General Objections PACCAR also objects to this Interrogatory as overbroad in scope and time as the only fact witness testimony concerning alleged exposure to any truck allegedly assembled and sold by PACCAR concerns Mr. Dickinson's testimony that he performed brake work 6 times and body work 24 times on Peterbilt trucks and that he performed brake work 6 times body work and engine work 6 times on Kenworth trucks between the years 1979 and 1990. See Discovery Deposition of Charles Dickinson Vol I 4/19/2022 8-16 24-153 23-206 Discovery Deposition of Charles Dickinson Vol II 4/8/2021 23-434 Mr. Dickinson had never worked on PACCAR trucks prior to owning & Collision Services Incorporated in 1979. Id PACCAR further objects that this Interrogatory seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence in that it is not limited to the products circumstances or time period at issue PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company Subject to and without waiving the foregoing objections PACCAR's predecessor Pacific Car & Foundry was first incorporated in 1905 as the Seattle Car Manufacturing Company a manufacturer of railroad cars for the logging industry In 1911 Seattle Car changed its name to Seattle Car & Foundry which in turn was renamed Pacific Car & Foundry in 1917. Pacific Car & Foundry acquired Kenworth in 1945 and Peterbilt in 1958. PACCAR was originally incorporated in 1971 as a subsidiary of Pacific Car & Foundry Co. In January of 1972 Pacific Car & Foundry Co. was merged into PACCAR INTERROGATORY NO 4 Does this Defendant currently have or has this Defendant had a department division subdivision branch or group responsible for the design development manufacture testing and use of asbestos- containing product If so state a the name of each present or former corporate division subdivision branch or group b the identity of the person most knowledgeable about such department division subdivision branch or group ANSWER PACCAR incorporates its Preliminary Statement and General Objections PACCAR also objects to this Interrogatory as overbroad in scope and time as the only fact witness testimony concerning alleged exposure to any truck allegedly assembled and sold by PACCAR concerns Mr. Dickinson's testimony that he performed brake work 6 times and body work 24 times on Peterbilt trucks and that he performed brake work 6 times body work and engine work 6 times on Kenworth trucks between the years 1979 and 1990. See Discovery Deposition of Charles Dickinson Vol I 4/19/2022 8-16 24-153 23-206 Discovery Deposition of Charles Dickinson Vol II 4/8/2021 23-434 Mr. Dickinson had never worked on PACCAR trucks prior to owning & Collision Services Incorporated in 1979. Id PACCAR further objects that this Interrogatory seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence in that it is not limited to the products circumstances or time period at issue PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of asbestoscontaining products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks PACCAR also objects to the extent that this Interrogatory implies that PACCAR had a duty to conduct or contribute to the conducting of any sampling analyses studies or testing of any product which allegedly contained asbestos and was manufactured by another company PACCAR also objects to the extent this Interrogatory seeks private information of individuals that are not parties to this litigation PACCAR further objects that this Interrogatory is confusing as drafted given that it does not refer to any particular product Subject to and without waiving the foregoing objections PACCAR states that David J. Bissonnette was the Manager of Industrial Hygiene and Safety from 1975-2000 PACCAR is aware of sampling testing conducted between 1976 and 1987 by David Bissonette CIH PACCAR's knowledge concerning the details of these tests are limited however PACCAR is aware that Mr. Bissonette had a three process that he enumerated in a 1976 presentation 1 identify a POSSIBLE hazard 2 evaluate the POSSIBLE hazard 3 if the evaluation shows that there is a hazard put controls in place Mr. Bissonette's testing revealed there were no hazards to mechanics performing automotive work INTERROGATORY NO 5 Has this Defendant engaged in the manufacturing marketing or sale of vehicles under the brand names Kenworth and Peterbilt including trucks tractors trailers and engines or replacement parts for these vehicles including gaskets brakes and clutches If so please State a the date this Defendant first manufactured marketed or sold this type of product b the date this Defendant ceased the manufacturing marketing or selling of this type of product C. a generic description of the chemical composition of each type of product including PP the nature of each type of product PP a description of any coloring wording marking and logo on each type of product +60 the recommended use of each type of product including temperature limits +60 the name of the purchaser of this type of product h. the identity of the person most knowledgeable concerning the manufacture of this type of product ANSWER PACCAR incorporates its Preliminary Statement and General Objections PACCAR also objects to this Interrogatory as overbroad in scope and time as the only fact witness testimony concerning alleged exposure to any truck allegedly assembled and sold by PACCAR concerns Mr. Dickinson's testimony that he performed brake work 6 times and body work 24 times on Peterbilt trucks and that he performed brake work 6 times body work and engine work 6 times on Kenworth trucks between the years 1979 and 1990. See Discovery Deposition of Charles Dickinson Vol I 4/19/2022 8-16 24-153 23-206 Discovery Deposition of Charles Dickinson Vol II 4/8/2021 23-434 Mr. Dickinson had never worked on PACCAR trucks prior to owning & Collision Services Incorporated in 1979. Id PACCAR further objects that this Interrogatory seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence in that it is not limited to the products circumstances or time period at issue PACCAR further objects on the basis that its Kenworth and Peterbilt divisions have assembled hundreds of thousands of trucks during their histories that those trucks were custom at the direction request and specification of the purchaser that certain information regarding those trucks is maintained by Vehicle Identification Number that Plaintiffs have not identified the Vehicle Identification Number of any Kenworth or Peterbilt truck and therefore the location and identification of information responsive to this Interrogatory is unduly burdensome and oppressive and obtainable through less expensive and burdensome means Subject to and without waiving the foregoing objections PACCAR states that Build Sheets for trucks assembled prior to 1988 are on microfiche and microfilm For those microfiche and microfilm in PACCAR's possession PACCAR stores the aforementioned microfiche related to Kenworth trucks in Washington and microfiche related to Peterbilt trucks in Texas PACCAR also possesses Peterbilt Build Sheets on microfilm for trucks assembled prior to 1972. These files are indexed by chassis number so with that information documents specific to a particular truck can be identified PACCAR can make these microfiche and microfilm available for physical review and copying at a mutually convenient time at Plaintiffs expense Build Sheets previously kept on microfiche and converted to electronic format for Kenworth and Peterbilt trucks assembled prior to 1988 are stored as TIFF tagged image file format files For Kenworth vehicles these digitized Build Sheets are for trucks assembled from the late 1960's to 1987. For Peterbilt vehicles these digitized Build Sheets are for trucks assembled from the early 1970's to 1987. PACCAR can make all TIFF files available to Plaintiffs at Plaintiffs expense upon reasonable notice These files are indexed by chassis number so with that information documents specific to a particular truck can be identified Additionally Build Sheets for trucks assembled from 1988 to the present are available electronically in vertical bar delimited text files PACCAR can make these vertical bar delimited text files available to Plaintiffs at Plaintiffs expense upon reasonable notice Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer INTERROGATORY NO 6 Has this Defendant sold or otherwise distributed containing vehicles under the brand names Kenworth and Peterbilt including trucks tractors trailers and engines or replacement parts for these vehicles including gaskets brakes and clutches to any of Plaintiff's employers and worksites as identified in Plaintiff's Complaint Responses to Interrogatories and deposition testimony i.e. Beacon Container & Collison Services in Elverson PA and Pottstown PA Dotter Auto Body in Pottstown PA Mrs. Smith's Pie Company in Pottstown PA and Reading Crane & Hoist If so state 10 a the date of sale or purchase of said products b the intended use of such products C. the identity of the custodian or records of such purchase or acquisition ANSWER PACCAR incorporates its Preliminary Statement and General Objections PACCAR also objects to this Interrogatory as overbroad in scope and time as the only fact witness testimony concerning alleged exposure to any truck allegedly assembled and sold by PACCAR concerns Mr. Dickinson's testimony that he performed brake work 6 times and body work 24 times on Peterbilt trucks and that he performed brake work 6 times body work and engine work 6 times on Kenworth trucks between the years 1979 and 1990. See Discovery Deposition of Charles Dickinson Vol I 4/19/2022 8-16 24-153 23-206 Discovery Deposition of Charles Dickinson Vol II 4/8/2021 23-434 Mr. Dickinson had never worked on PACCAR trucks prior to owning & Collision Services Incorporated in 1979. Id PACCAR further objects that this Interrogatory seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence in that it is not limited to the products circumstances or time period at issue PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of asbestoscontaining products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks PACCAR further objects on the basis that its Kenworth and Peterbilt divisions have assembled hundreds of thousands of trucks during their histories that those trucks were custombuilt at the direction request and specification of the purchaser that certain information regarding those trucks is maintained by Vehicle Identification Number that Plaintiffs have not identified the Vehicle Identification Number of any Kenworth or Peterbilt truck and therefore the location and identification of information responsive to this Interrogatory is unduly burdensome and oppressive and obtainable through less expensive and burdensome means Subject to and without waiving the foregoing objections PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks These vehicles included among other components axles transmissions and engines that were manufactured by various component suppliers PACCAR is informed and believes that some of these assembled component parts may have at various points in time incorporated brakes clutches and gaskets that contained some form of encapsulated chrysotile These products were at all times manufactured by and obtained from various component part suppliers that are unrelated to PACCAR PACCAR did not specify the use of asbestos in these brakes clutches and engine gaskets and did not know the exact formulation or chemical composition of the components manufactured by unrelated entities If those products contained asbestos at some point in time it was because the component manufacturers independently determined that asbestos was a necessary part of the formulation to achieve mandated performance specifications Those other entities would be considered the manufacturers and distributors of containing automotive friction products As such this Interrogatory should be directed to those entities 11 PACCAR is unable to accurately state when component part manufacturers first started using asbestos in component parts PACCAR is informed and believes that for those cam brakes used on Kenworth and Peterbilt trucks that historically contained asbestos the brake lining manufacturers completed their transition to asbestos in 1987. PACCAR is informed and believes that for wedge brakes used on Kenworth and Peterbilt heavy duty trucks that historically contained asbestos the brake lining manufacturers completed their transition in 1990. These wedge brakes were typically used on a small subsection of heavy duty trucks either specifying light weight components or used in off highway applications With respect to clutches that historically contained asbestos PACCAR is informed and believes that PACCAR's primary clutch supplier completed its transition to asbestos in 1982. Discovery responses produced in asbestos litigation also confirm that at least one of PACCAR's primary engine suppliers transitioned away from using asbestos gaskets in the 1980s PACCAR's heavy duty trucks are custom These are extremely complicated machines that vary in form and function based on customer specification and commercial or vocational purpose The possible variations of these custom trucks number in the tens of thousands at least Accordingly the types of component parts that could safely perform on a given vehicle vary from truck to truck The component manufacturers transition to asbestos materials was a process that began in the late 1970s to early 1980s timeframe and took several years to complete Early versions of asbestos brakes and clutches could safely be used on certain trucks for certain applications Thus certain Kenworth and Peterbilt trucks contained asbestos components prior to the date when manufacturers completely stopped using asbestos in their products Answering further PACCAR's primary suppliers of axles and brake assemblies during the relevant time period were Eaton and Rockwell Upon information and belief Eaton and Rockwell brake assemblies typically contained linings manufactured by Abex and Carlisle Abex and Carlisle did not supply brakes directly to PACCAR rather they supplied PACCAR's brake suppliers with brakes Further PACCAR has no way of knowing if these brakes linings contained asbestos since that information is proprietary to those brake lining manufacturers PACCAR's primary suppliers of engines during the relevant time period were Cummins Caterpillar and Detroit Diesel PACCAR's primary supplier of clutches during the relevant time period was Spicer Answering further PACCAR's heavy duty trucks were stamped or otherwise identified with the company name and logo that is Kenworth KW or Peterbilt Answering further PACCAR's Kenworth and Peterbilt heavy trucks were assembled in various locations These locations include but are not limited to the following Kansas City Missouri 19641986 Chillicothe Ohio opened in 1973 Denton Texas opened in 1980 Nashville Tennessee opened in 1969 stopped assembling trucks in 2008 and closed in 2009 Renton Washington plant opened in 1993 Newark California plant closed in 1986 Oakland California plant closed in 1960 Mexicali Mexico St. Therese Montreal and Seattle Washington from 1945 the time PACCAR purchased Kenworth until the facility closed in 2001 12 Finally PACCAR's Kenworth Truck Company and Peterbilt Motors Company divisions sold their trucks to independently authorized dealerships not users To the best of PACCAR's knowledge no witness in this case has identified any of Plaintiff's employers and worksites as a truck dealership PACCAR reserves the right to amend these responses if new or additional information becomes available to it Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer INTERROGATORY NO 7 Has this Defendant applied for and received any patent for any Kenworth and Peterbilt trucks tractors trailers engines gaskets brakes and clutches containing asbestos If so for each product please state b the product for which each patent was applied and issued the date of application the date or issuance of the patent if granted d the date of renewal if any the patent number ANSWER PACCAR incorporates its Preliminary Statement and General Objections PACCAR also objects to this Interrogatory as overbroad in scope and time as the only fact witness testimony concerning alleged exposure to any truck allegedly assembled and sold by PACCAR concerns Mr. Dickinson's testimony that he performed brake work 6 times and body work 24 times on Peterbilt trucks and that he performed brake work 6 times body work and engine work 6 times on Kenworth trucks between the years 1979 and 1990. See Discovery Deposition of Charles Dickinson Vol I 4/19/2022 8-16 24-153 23-206 Discovery Deposition of Charles Dickinson Vol II 4/8/2021 23-434 Mr. Dickinson had never worked on PACCAR trucks prior to owning & Collision Services Incorporated in 1979. Id PACCAR further objects that this Interrogatory seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence in that it is not limited to the products circumstances or time period at issue PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of asbestoscontaining products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products Subject to and without waiving objection to the best of PACCAR's knowledge no but investigation is going and PACCAR reserves the right to supplement and amend if further information is discovered INTERROGATORY NO 8 Has this Defendant ever provided testimony in a deposition or at trial in any asbestos litigation lawsuit involving Kenworth and Peterbilt If so then state a The name of the case b The state and county of filing and associated case number 13 C. The date of deposition or trial testimony d The name and address of plaintiffs counsel of records e The name and address of the court reporter ANSWER PACCAR incorporates its Preliminary Statement and General Objections PACCAR also objects to this Interrogatory as overbroad in scope and time as the only fact witness testimony concerning alleged exposure to any truck allegedly assembled and sold by PACCAR concerns Mr. Dickinson's testimony that he performed brake work 6 times and body work 24 times on Peterbilt trucks and that he performed brake work 6 times body work and engine work 6 times on Kenworth trucks between the years 1979 and 1990. See Discovery Deposition of Charles Dickinson Vol I 4/19/2022 8-16 24-153 23-206 Discovery Deposition of Charles Dickinson Vol II 4/8/2021 23-434 Mr. Dickinson had never worked on PACCAR trucks prior to owning & Collision Services Incorporated in 1979. Id Additionally PACCAR objects to the extent that this Interrogatory is not relevant to the Plaintiffs products facilities locations and circumstances at issue in this litigation and to the extent it seeks information not reasonably calculated to lead to the discovery of admissible evidence Furthermore PACCAR objects to the extent that this Request seeks information that is within the public domain or otherwise equally available to Plaintiffs or their counsel PACCAR further objects that this Interrogatory is confusing as drafted given that it does not refer to any particular product Subject to and without waiving objection yes a Malvin Rivenbark & Mary Ann Rivenbark v Fireboard Corp et al b Alameda County CA Case No. 711462-9 c August 26 1993 d Kazan McClain Edises & Simon 171 12th Street 3rd Floor Oakland CA 94607 e Aiken & Welch Inc. 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Spence as Surviving Children v The Ford Motor Company et al (b) New Castle County DE Case No. 07-160 ASB c May , 2018 d Cappolino Dodd Krebs LLP 312 S Houston Ave. Cameron TX 76520 e Infinity Reporting Group LLC 1502 Park Harbor Estates Dr. Houston TX 77084 39000 Charles French and Victoria French v ArvinMeritor Inc. et al 39000 McLean County IL Case No. 00067 39000 July 25 2018 39000 Wylder Corwin & Kelly 207 E. Washington St. Suite 102 Bloomington IL 61701 39000 Anchor Reporting Inc. P.O. Box 25471 Decatur IL 62525 a Pearl Tart Crystal Booker Cynthia Wilson Wesley Wilson as individuals and legal heirs at law of John Tart v Warner Corporation by its successor in interest BorgWarner Morse Tec Inc. et al b Los Angeles County CA Case No. JCCP4674 c October 18 2018 d Robins Cloud LLP 808 Wilshire Blvd. Suite 450 Santa Monica CA 90401 e HG Litigation Services 2501 Oak Lawn Ave. Suite 600 Dallas TX 75219 a Steven Donovan and Brenda Donovan Lyle Staley and Susan Staley v ArvinMeritor Inc. et al eee McLean County IL Case No. 64 eee February 26 2019 eee Wylder Corwin Kelly LLP 207 East Washington St. Suite 102 Bloomington IL 61701 e Anchor Reporting Inc. P.O. Box 25471 Decatur IL 62525 a Jeffrey Richard Henry Individually and as Trustee for the next for Richard Henry Deceased v Ford Motor Company et al b Ramsey County MN Court File No 15-7775 16 c July 31 2019 d Dean Omar Branham Shirley 302 North Market St. Suite 300 Dallas TX 75202 e U.S. Legal Support 5910 North Central Expressway Suite 100 Dallas TX 75206 a Robert Skelton Individually and as Successor in Interest to Wanda Skelton Deceased and Gary Skelton an Individual Jerry Skelton an Individually v Allied Fluid Products Corp. et al b Alameda County CA Case No. 17868697 c October 3 2019 d Weitz & Luxenburg PC 1880 Century Park East Suite 700 Los Angeles CA 90067 e Priority Court Reporting Services Inc. 290 West Mt. Pleasant Ave. Suite 3200 Livingston NJ 07039 a Donald Dysart and Nancy Dysart v ArvinMeritor Inc. et al 18-130 Roger Soverns and Veronica Soverns v ArvinMeritor Inc. et al 19CV38303 and Gilbert John Puffinberger and Francis Puffinberger v 3M Company et al 9600 b Cumberland County ME Multnomah County OR and Kanawha WV respectively c Maune Raichle Hartley French & Mudd LLC 1015 Locust Street Suite 1200 St. Louis MO 63101 de January 28 2020 de Veritext Legal Solutions Atlantic Region 1801 Market Street Suite 1800 Philadelphia PA 19103 a William Clark and Stephanie Clark v Arrow Machinery Inc. et al 19-2- 26061-1 SEA b King County WA c Bergman Draper Oslund Udo 821 2nd Ave. Suite 2100 Seattle WA 98104 d June 30 2020 e Rebecca Graziano of Graziano Reporting Services LLC a Gary Finn v American Honda Motor Co. Inc. et al 11-107 b New Castle County DE (c) Weitz4 & Luzenberg 700 Broadway New York NY 10003 d August 7 2020 e Cheryl Nicholas HG Litigation Services 2777 N. Stemmons Freeway Suite 1025 Dallas TX 75207 a Regina Pawlik Individually and as the Special Administrator to the Estate of Adam Pawlik Deceased v 3M Company et al 19 L 008784 b Cook County IL c Vogelzang Law 401 N. Michigan Ave. Suite 350 Chicago IL 60611 17 d August 11 2020 e Roselind C. Pisano a Laura Walls Individually and as Executor of the Estate of Robie Walls v Ford Motor Company et al 00098 b North Carolina US District Court Middle District c Dean Omar Branham Shirley LLP 302 N. Market Street Suite 300 Dallas TX 75202 / Wallace & Graham P.A. 525 North Main Street Salisbury NC 28144 dea October 30 2020 dea Deborah Renee Quarles 8144 Walnut Hill Lane Suite 350 Dallas TX 75231 dea David Settlemyer and Jan Settlemyer v Warner Morse Tec LLC successor to Warner Corporation et al 00344 WCM b North Carolina US District Court Western District c Wallace & Graham P.A. 525 North Main Street Salisbury NC 28144 / Simmons Hanly Conroy One Court Street Alton IL 62002 d November 4 2020 e Kevin J. Weichman Paszkiewicz Records Retrieval 26 Ginger Creek Parkway Glen Carbon IL 62034 39000 Wayne K. Maust and Lisa L. Maust v ArvinMeritor Inc. et al 20-2-05906-0 39000 Pierce County WA 39000 Maune Raichle Hartley French & Mudd LLC 1015 Locust St. Suite 1200 St. Louis MO 63101 39000 February 10 2021 February 24,2021 March 2 2021 39000 Pohlman Court Reporting 39000 Carole Colvin et al v Autozone Inc. et al 24X12000713 24X12000713 39000 Baltimore County MD 39000 Napoli Shkolnik 919 N Market Street Suite 1801 Wilmington DE 19801 39000 March 30 2021 39000 Magna Legal Services 1635 Market St. Philadelphia PA 19103 @ Gaynor Austin Individually and as Personal Representative of the Estate of Allen Austin Deceased v BNSF Railway Company et al 18-2-15054-0 SEA 0 King County WA 0 Waters & Kraus Iola Galerston LLP 3838 Oak Lawn Ave Suite 840 Dallas TX 75219 0 June 22 2021 & June 23 2021 0 Advances One Legal 2777 N Stemmons Freeway Suite 1025 Dallas TX 75207 18 a Case Name Randall Bose and Etta Bose his wife v 84 Lumber Company et al 1759 - Rodney Curbo b Madison County IL c SWMW Law LLC 701 Market St Unit 1000 St. Louis MO 63101 d September 9 2021 e Paszkiewicz Litigation Services 26 Ginger Creek Parkway Glen Carbon Illinois 62034 a Rita Chapman & Gary Chapman v Avon Products Inc. et al b Los Angeles County CA Case No. 22STCV05968 c August 5 2022 d Dean Omar Branham Shirley LLP 302 N. Market Street Suite 300 Dallas TX 75202 e Adam D. Miller Asbestos Reporters GPS partner INTERROGATORY NO 9 When and how did Defendant first learn that inhalation of asbestos fibers can lead to the development of each of the following asbestos diseases a asbestosis b pleural plaques d lung cancer kidney cancer f laryngeal cancer esophageal cancer stomach cancer g colon cancer and mesothelioma ANSWER PACCAR incorporates its Preliminary Statement and General Objections PACCAR also objects to this Interrogatory as overbroad in scope and time as the only fact witness testimony concerning alleged exposure to any truck allegedly assembled and sold by PACCAR concerns Mr. Dickinson's testimony that he performed brake work 6 times and body work 24 times on Peterbilt trucks and that he performed brake work 6 times body work and engine work 6 times on Kenworth trucks between the years 1979 and 1990. See Discovery Deposition of Charles Dickinson Vol I 4/19/2022 8-16 24-153 23-206 Discovery Deposition of Charles Dickinson Vol II 4/8/2021 23-434 Mr. Dickinson had never worked on PACCAR trucks prior to owning & Collision Services Incorporated in 1979. Id PACCAR further objects that this Interrogatory seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence in that it is not limited to the products circumstances or time period at issue PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of asbestoscontaining products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks PACCAR further objects on the basis that as a corporation it is extremely difficult to pinpoint a date when a corporate entity first learned about something PACCAR further 19 objects that this Interrogatory represents an improper attempt to shift the burden of proof PACCAR also objects to this Interrogatory as argumentative because it inappropriately assumes that exposures to all containing products are equal and hazardous despite the abundance of epidemiological studies which demonstrate that mechanics are not at an increased risk of developing an asbestos disease Accordingly without more specificity regarding the type of product type of asbestos fiber amount of exposure duration of exposure and latency period PACCAR cannot fully answer this Interrogatory Subject to and without waiving the foregoing objections PACCAR does not currently know when it first received information about the potential dangers from breathing some forms of asbestos fibers PACCAR generally received information on regulations promulgated by federal OSHA on topics of workplace safety Responding further in 1976 certain PACCAR employees attended a seminar on workplace health and safety This seminar consisted of over a dozen presentations including one regarding industrial hygiene That industrial hygiene presentation included a limited discussion on the development of OSHA regulations pertaining to permissible exposure limits To demonstrate how some of those standards were developed the presenter discussed certain epidemiological studies on asbestos disease among insulation workers Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 10 Please list all trade organizations trade associations and any other groups to which Defendant belonged in which information relating to the hazards of asbestos or nuisance dust in general was discussed disseminated or in any way published before 2013. This list should include but is not limited to any membership in the American Hygiene Foundation Industrial Hygiene Foundation Chemical Manufacturer's Association or its predecessor the MCA American Chemical Council American Petroleum Institute Texas Chemical Council National Safety Council American National Standards Institute ANSI Asbestos Information Association Industrial Medical Association American Society of Mechanical Engineers American Society for Testing and Materials Chlorine Institute American Industrial Hygiene Association National Insulation Manufacturers Association Asbestos Textile Institute Society of Automotive Engineers Society of Petroleum Engineers ACGIH American Occupational Medicine Association American Public Health Association Friction Materials Standards Institute Brake Lining Manufacturer's Association American Medical Association NIOSH and any state safety organizations As to each listed group please state a the time period when Defendant was a member b the identity of Defendant's employees former employees or representatives who attended any of the meetings held by each listed group as well as the dates and locations of the meetings they attended C. the identity of Defendant's employees former employees or representatives who served on any committees or subcommittees of any listed group e.g. a medical advisory committee or legal committee and d the name of the committee or subcommittee on which such person served and the position occupied on the committee if applicable 20 ANSWER PACCAR incorporates its Preliminary Statement and General Objections PACCAR also objects to this Interrogatory as overbroad in scope and time as the only fact witness testimony concerning alleged exposure to any truck allegedly assembled and sold by PACCAR concerns Mr. Dickinson's testimony that he performed brake work 6 times and body work 24 times on Peterbilt trucks and that he performed brake work 6 times body work and engine work 6 times on Kenworth trucks between the years 1979 and 1990. See Discovery Deposition of Charles Dickinson Vol I 4/19/2022 8-16 24-153 23-206 Discovery Deposition of Charles Dickinson Vol II 4/8/2021 23-434 Mr. Dickinson had never worked on PACCAR trucks prior to owning & Collision Services Incorporated in 1979. Id PACCAR further objects that this Interrogatory seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence in that it is not limited to the products circumstances or time period at issue Furthermore this Interrogatory seeks information regarding nuisance dust To the best of PACCAR's knowledge Plaintiffs are alleging exposure in relation to asbestos not nuisance dust PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks Subject to and without waiving the foregoing objections to the best of PACCAR'S knowledge PACCAR has been a member of the Truck Manufacturers Association TMA and the Engine Manufacturers Association EMA Memberships to both the TMA and EMA would have commenced sometime in the middle 1990s Responding further PACCAR does not maintain information regarding trade associations and other professional organizations to which its employees may have had individual memberships over the years Discovery is ongoing and PACCAR reserves the right to supplement or amend its Response to this Interrogatory if new or additional information is obtained INTERROGATORY NO 11 Please identify each of Defendant's employees former employees or representatives who attended any proceeding symposium or conference of a scientific medical or technical nature before 1990 during which information relating to the hazards of asbestos or nuisance dust in general was discussed disseminated or in any way published e.g. the effects of human or nonhuman exposure to asbestos populations at risk etc. A response to this Interrogatory should include any attendance at meetings of any organization listed in Defendant's response to Interrogatory No. 10. For each person identified in the response to this Interrogatory please also list the proceeding symposium or conference the person attended provide the date and location of the proceeding symposium or conference provide the identity of the person within Defendant's organization who received or was designated to receive the attending person's report of the information gathered at such proceeding symposium or conference and describe the manner in which such reports were made 21 ANSWER PACCAR incorporates its Preliminary Statement and General Objections PACCAR also objects to this Interrogatory as overbroad in scope and time as the only fact witness testimony concerning alleged exposure to any truck allegedly assembled and sold by PACCAR concerns Mr. Dickinson's testimony that he performed brake work 6 times and body work 24 times on Peterbilt trucks and that he performed brake work 6 times body work and engine work 6 times on Kenworth trucks between the years 1979 and 1990. See Discovery Deposition of Charles Dickinson Vol I 4/19/2022 8-16 24-153 23-206 Discovery Deposition of Charles Dickinson Vol II 4/8/2021 23-434 Mr. Dickinson had never worked on PACCAR trucks prior to owning & Collision Services Incorporated in 1979. Id PACCAR further objects that this Interrogatory seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence in that it is not limited to the products circumstances or time period at issue Furthermore this Interrogatory seeks information regarding nuisance dust To the best of PACCAR's knowledge Plaintiffs are alleging exposure in relation to asbestos not nuisance dust PACCAR further objects on the basis that this Interrogatory is unduly burdensome and appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks Subject to and without waiving the foregoing objections PACCAR directs Plaintiffs to its Objections to Interrogatory Nos 9 and 10 incorporated herein Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 12 Please describe Defendant's medical safety and industrial hygiene programs from the Defendant's inception through the current time Specifically please state when Defendant first established each of its medical departments safety departments and industrial hygiene departments Please also provide the name or designation of each department For each department identified in the response to this Interrogatory please identify each person associated with the department including but not limited to the director manager physician nurse medical personnel safety engineer industrial hygienist safety personnel and other employees in such department who were employed by Defendant or contracted with Defendant at any time ANSWER PACCAR incorporates its Preliminary Statement and General Objections PACCAR also objects to this Interrogatory as overbroad in scope and time as the only fact witness testimony concerning alleged exposure to any truck allegedly assembled and sold by PACCAR concerns Mr. Dickinson's testimony that he performed brake work 6 times and body work 24 times on Peterbilt trucks and that he performed brake work 6 times body work and engine work 6 times on Kenworth trucks between the years 1979 and 1990. See Discovery Deposition of Charles Dickinson Vol I 4/19/2022 8-16 24-153 23-206 Discovery Deposition of Charles Dickinson Vol II 4/8/2021 23-434 Mr. Dickinson had never worked on PACCAR trucks prior to owning & Collision Services Incorporated in 1979. Id PACCAR further objects that this Interrogatory seeks information that is neither 22 relevant nor reasonably calculated to lead to the discovery of admissible evidence in that it is not limited to the products circumstances or time period at issue Subject to and without waiving the foregoing objections PACCAR states that it did not have a Medical Department and as a general matter did not ascribe such nomenclature to its operations Further answering and in the spirit of cooperation the precise history of any such program or department is not entirely known and not within the knowledge of any one person or document or otherwise readily retrievable however based on a review of available documents David J. Bissonnette was the Manager of Industrial Hygiene and Safety from 1975- 2000. As for medical directors PACCAR is informed and believes that it employed Dr. J.F. Johanson as a medical director in the 1970s Dr. J.M. Hughes as a medical director in 1984 and Dr. Francis VonFeldt as a medical director from 1985 to 2000. Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer should new or additional information be obtained Finally PACCAR directs Plaintiffs to its Objections to Interrogatory No. 4 incorporated herein INTERROGATORY NO 13 Has Defendant ever been investigated or cited by OSHA or any other local state or federal governmental agency for any matter related to asbestos or asbestos exposure If so please provide the dates of such investigations the results that were communicated to Defendant and the remedial measures if any which were undertaken by Defendant ANSWER PACCAR incorporates its Preliminary Statement and General Objections PACCAR also objects to this Interrogatory as overbroad in scope and time as the only fact witness testimony concerning alleged exposure to any truck allegedly assembled and sold by PACCAR concerns Mr. Dickinson's testimony that he performed brake work 6 times and body work 24 times on Peterbilt trucks and that he performed brake work 6 times body work and engine work 6 times on Kenworth trucks between the years 1979 and 1990. See Discovery Deposition of Charles Dickinson Vol I 4/19/2022 8-16 24-153 23-206 Discovery Deposition of Charles Dickinson Vol II 4/8/2021 23-434 Mr. Dickinson had never worked on PACCAR trucks prior to owning & Collision Services Incorporated in 1979. Id PACCAR further objects that this Interrogatory seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence in that it is not limited to the products circumstances or time period at issue PACCAR further objects on the basis that this Interrogatory is unduly burdensome and appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks Subject to and without waiving the foregoing objections not to the best of PACCAR'S current knowledge Discovery is ongoing and PACCAR reserves the right to supplement or amend its Response to this Request if new or additional information is obtained 23 INTERROGATORY NO 14 Please provide Defendant's complete corporate history including its ownership sale acquisition or divestiture and any mergers acquisitions consolidations or other similar events involving Defendant at any time during its history ANSWER PACCAR incorporates its Preliminary Statement and General Objections PACCAR also objects to this Interrogatory as overbroad in scope and time as the only fact witness testimony concerning alleged exposure to any truck allegedly assembled and sold by PACCAR concerns Mr. Dickinson's testimony that he performed brake work 6 times and body work 24 times on Peterbilt trucks and that he performed brake work 6 times body work and engine work 6 times on Kenworth trucks between the years 1979 and 1990. See Discovery Deposition of Charles Dickinson Vol I 4/19/2022 8-16 24-153 23-206 Discovery Deposition of Charles Dickinson Vol II 4/8/2021 23-434 Mr. Dickinson had never worked on PACCAR trucks prior to owning & Collision Services Incorporated in 1979. Id PACCAR further objects that this Interrogatory seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence in that it is not limited to the products circumstances or time period at issue PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company Furthermore PACCAR objects to the extent that this Request seeks information that is within the public domain or otherwise equally available to Plaintiffs or their counsel Subject to and without waiving the foregoing objections PACCAR's predecessor Pacific Car & Foundry was first incorporated in 1905 as the Seattle Car Manufacturing Company a manufacturer of railroad cars for the logging industry In 1911 Seattle Car changed its name to Seattle Car & Foundry which in turn was renamed Pacific Car & Foundry in 1917. Pacific Car & Foundry acquired Kenworth in 1945 and Peterbilt in 1958. PACCAR was originally incorporated in 1971 as a subsidiary of Pacific Car & Foundry Co. In January of 1972 Pacific Car & Foundry Co. was merged into PACCAR INTERROGATORY NO 15 Where are Defendant's principal places of business city state and county Defendant's place of business where its highest decision makers work Defendant's three most significant business locations within the United States Please Please identify identify ANSWER PACCAR incorporates its Preliminary Statement and General Objections PACCAR also objects to this Interrogatory as overbroad in scope and time PACCAR further objects that this Interrogatory seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence in that it is not limited to the products circumstances or time period at issue PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects 24 to the extent that this interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR also objects to the undefined terms highest decision makers and significant places of business as vague ambiguous and overbroad Subject to and without waiving the foregoing objections PACCAR directs Plaintiffs to its Objections and Answer to Interrogatory No. 2 incorporated herein INTERROGATORY NO 16 Please identify each person who has supplied any information or assisted in locating any documents or tangible things used in answering or responding to all Asbestos Litigation discovery and provide a year list of all positions or job titles held by each person ANSWER PACCAR incorporates its Preliminary Statement and General Objections PACCAR also objects to this Interrogatory as unduly burdensome and overbroad in scope and time PACCAR further objects to the extent this Interrogatory seeks information protected by third party privacy or any other applicable privilege PACCAR further objects that this Interrogatory seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence in that it is not limited to the products circumstances or time period at issue PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR also objects to this Interrogatory to the extent it seeks information and documents protected from disclosure by the attorney privilege the work product doctrine or any other applicable protection INTERROGATORY NO 17 When was the first time Defendant became familiar with the concept of a threshold limit value or TLV for airborne dust and how was Defendant first made aware of this concept ANSWER PACCAR incorporates its Preliminary Statement and General Objections PACCAR also objects to this Interrogatory as overbroad in scope and time as the only fact witness testimony concerning alleged exposure to any truck allegedly assembled and sold by PACCAR concerns Mr. Dickinson's testimony that he performed brake work 6 times and body work 24 times on Peterbilt trucks and that he performed brake work 6 times body work and engine work 6 times on Kenworth trucks between the years 1979 and 1990. See Discovery Deposition of Charles Dickinson Vol I 4/19/2022 8-16 24-153 23-206 Discovery Deposition of Charles Dickinson Vol II 4/8/2021 23-434 Mr. Dickinson had never worked on PACCAR trucks prior to owning & Collision Services Incorporated in 1979. Id PACCAR also objects to this Interrogatory as vague and ambiguous in its use of the undefined term airborne dust PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture asbestos- containing products rather they assembled and sold heavy duty trucks PACCAR further 25 objects on the basis that as a corporation it is extremely difficult to pinpoint a date when a corporate entity was first made aware about something Subject to and without waiving the foregoing objections PACCAR directs Plaintiffs to its Objection and Answer to Interrogatory No. 9 incorporated herein INTERROGATORY NO 18 When and how did Defendant first learn that a household member's inhalation of asbestos fibers from work outside of the home with asbestos can lead to the development of each of the following asbestos related diseases a asbestosis pleural plaques b lung cancer kidney cancer f laryngeal cancer esophageal cancer stomach cancer h colon cancer and mesothelioma ANSWER PACCAR incorporates its Preliminary Statement and General Objections PACCAR also objects to this Interrogatory as overbroad in scope and time as the only fact witness testimony concerning alleged exposure to any truck allegedly assembled and sold by PACCAR concerns Mr. Dickinson's testimony that he performed brake work 6 times and body work 24 times on Peterbilt trucks and that he performed brake work 6 times body work and engine work 6 times on Kenworth trucks between the years 1979 and 1990. See Discovery Deposition of Charles Dickinson Vol I 4/19/2022 8-16 24-153 23-206 Discovery Deposition of Charles Dickinson Vol II 4/8/2021 23-434 Mr. Dickinson had never worked on PACCAR trucks prior to owning & Collision Services Incorporated in 1979. Id PACCAR further objects that this Interrogatory seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence in that it is not limited to the products circumstances or time period at issue PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of asbestoscontaining products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks PACCAR further objects on the basis that as a corporation it is extremely difficult to pinpoint a date when a corporate entity first learned about something PACCAR further objects that this Interrogatory represents an improper attempt to shift the burden of proof PACCAR also objects to this Interrogatory as argumentative because it inappropriately assumes that exposures to all containing products are equal and hazardous despite the abundance of epidemiological studies which demonstrate that mechanics are not at an increased risk of developing an asbestos disease Accordingly without more specificity regarding the type of product type of asbestos fiber amount of exposure duration of exposure and latency period PACCAR cannot fully answer this Interrogatory 26 Subject to and without waiving the foregoing objections PACCAR directs Plaintiffs to its Objection and Answer to Interrogatory No. 9 incorporated herein OBJECTIONS AND RESPONSES TO PLAINTIFFS REQUESTS FOR PRODUCTION REQUEST FOR PRODUCTION NO 1 Please produce all documents and tangible things that indicate the time and manner in which Defendant learned inhalation of asbestos fibers by humans can lead to the development of the following asbestos diseases asbestosis b pleural plaques lung cancer kidney cancer f laryngeal cancer esophageal cancer stomach cancer g colon cancer and mesothelioma ANSWER PACCAR incorporates its Preliminary Statement and General Objections PACCAR also objects to this Request as overbroad in scope and time as the only fact witness testimony concerning alleged exposure to any truck allegedly assembled and sold by PACCAR concerns Mr. Dickinson's testimony that he performed brake work 6 times and body work 24 times on Peterbilt trucks and that he performed brake work 6 times body work and engine work 6 times on Kenworth trucks between the years 1979 and 1990. See Discovery Deposition of Charles Dickinson Vol I 4/19/2022 8-16 24-153 23-206 Discovery Deposition of Charles Dickinson Vol II 4/8/2021 23-434 Mr. Dickinson had never worked on PACCAR trucks prior to owning & Collision Services Incorporated in 1979. Id PACCAR further objects that this Request seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence in that it is not limited to the products circumstances or time period at issue PACCAR further objects on the basis that this Request appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks PACCAR further objects that this Request represents an improper attempt to shift the burden of proof PACCAR also objects to this Request as it is argumentative and inappropriately assumes that exposures to all containing products are equal and hazardous despite the abundance of epidemiological studies which demonstrate that mechanics are not at an increased risk of developing an asbestos disease Accordingly without more specificity regarding the type of product type of asbestos fiber amount of exposure duration of exposure and latency period PACCAR cannot fully answer this Request PACCAR further objects on the basis that 27 as a corporation it is extremely difficult to pinpoint a date when a corporate entity first learned about something PACCAR also objects to the extent this Request seeks information and documents protected from disclosure by the attorney privilege the work product doctrine or any other applicable protection Subject to and without waiving the foregoing objections to the extent responsive documents exist PACCAR directs Plaintiffs to the documents produced bates labeled PACCAR000001 Additionally PACCAR directs Plaintiffs to its Objection and Answer to Interrogatory No. 9 incorporated herein REQUEST FOR PRODUCTION NO 2 Please produce all documents and tangible things containing any information Defendant received before 1990 relating to the hazards of asbestos or nuisance dust in general that was discussed disseminated or in any way published by any organization association or group listed in Defendant's response to the Interrogatory immediately above or by any other trade organization or group ANSWER PACCAR incorporates its Preliminary Statement and General Objections PACCAR also objects to this Request as overbroad in scope and time as the only fact witness testimony concerning alleged exposure to any truck allegedly assembled and sold by PACCAR concerns Mr. Dickinson's testimony that he performed brake work 6 times and body work 24 times on Peterbilt trucks and that he performed brake work 6 times body work and engine work 6 times on Kenworth trucks between the years 1979 and 1990. See Discovery Deposition of Charles Dickinson Vol I 4/19/2022 8-16 24-153 23-206 Discovery Deposition of Charles Dickinson Vol II 4/8/2021 23-434 Mr. Dickinson had never worked on PACCAR trucks prior to owning & Collision Services Incorporated in 1979. Id PACCAR further objects that this Request seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence in that it is not limited to the products circumstances or time period at issue Furthermore this Request seeks information regarding nuisance dust To the best of PACCAR's knowledge Plaintiffs are alleging exposure in relation to asbestos - not nuisance dust PACCAR further objects on the basis that this Request appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks PACCAR further objects that this Request represents an improper attempt to shift the burden of proof PACCAR also objects to this Request as it is argumentative and inappropriately assumes that exposures to all containing products are equal and hazardous despite the abundance of epidemiological studies which demonstrate that mechanics are not at an increased risk of developing an asbestos disease Accordingly without more specificity regarding the type of product type of asbestos fiber amount of exposure duration of exposure and latency period PACCAR cannot fully answer this Request PACCAR also objects to the extent this Request seeks information and documents protected from disclosure by the attorneyclient privilege the work product doctrine or any other applicable protection Finally PACCAR objects that there is no Interrogatory immediately above this Request and PACCAR cannot speculate as to which Interrogatory Plaintiffs are referring 28 REQUEST FOR PRODUCTION NO 3 Please produce all documents and tangible things related to any meeting attended by any of Defendant's employees former employees or representatives that indicate any discussion consideration or information regarding asbestos or nuisance dust in general This Request for Production specifically seeks but is not limited to meeting agendas minutes notes or memoranda from any proceeding symposium or conference listed in Defendant's Response to the preceding Interrogatory as well as from safety committees purchasing committees or other groups within Defendant's organization generated before 1990 ANSWER PACCAR incorporates its Preliminary Statement and General Objections PACCAR also objects to this Request as overbroad in scope and time as the only fact witness testimony concerning alleged exposure to any truck allegedly assembled and sold by PACCAR concerns Mr. Dickinson's testimony that he performed brake work 6 times and body work 24 times on Peterbilt trucks and that he performed brake work 6 times body work and engine work 6 times on Kenworth trucks between the years 1979 and 1990. See Discovery Deposition of Charles Dickinson Vol I 4/19/2022 8-16 24-153 23-206 Discovery Deposition of Charles Dickinson Vol II 4/8/2021 23-434 Mr. Dickinson had never worked on PACCAR trucks prior to owning & Collision Services Incorporated in 1979. Id PACCAR further objects that this Request seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence in that it is not limited to the products circumstances or time period at issue Furthermore this Request seeks information regarding nuisance dust To the best of PACCAR's knowledge Plaintiffs are alleging exposure in relation to asbestos- asbestos- not nuisance dust PACCAR further objects on the basis that this Request is unduly burdensome and appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks PACCAR also objects to the extent this Request seeks information and documents protected from disclosure by the attorney privilege the work product doctrine or any other applicable protection Finally PACCAR objects that there is no Interrogatory preceding this Request and PACCAR cannot speculate as to which Interrogatory Plaintiffs are referring REQUEST FOR PRODUCTION NO 4 Please produce all documents and tangible things relating to Defendant's establishment of the medical safety and industrial hygiene departments noted in Defendant's response to the Interrogatory immediately above This Request for Production specifically seeks but is not limited to any policies procedures or guidelines given to each such department by Defendant's management and any programs testing or other actions taken by each such department regarding the hazards of asbestos or nuisance dust in general ANSWER PACCAR incorporates its Preliminary Statement and General Objections PACCAR also objects to this Request as overbroad in scope and time as the only fact witness testimony concerning alleged exposure to any truck allegedly assembled and sold by PACCAR 29 concerns Mr. Dickinson's testimony that he performed brake work 6 times and body work 24 times on Peterbilt trucks and that he performed brake work 6 times body work and engine work 6 times on Kenworth trucks between the years 1979 and 1990. See Discovery Deposition of Charles Dickinson Vol I 4/19/2022 8-16 24-153 23-206 Discovery Deposition of Charles Dickinson Vol II 4/8/2021 23-434 Mr. Dickinson had never worked on PACCAR trucks prior to owning & Collision Services Incorporated in 1979. Id PACCAR further objects that this Request seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence in that it is not limited to the products circumstances or time period at issue Furthermore this Request seeks information regarding nuisance dust To the best of PACCAR's knowledge Plaintiffs are alleging exposure in relation to asbestos not nuisance dust PACCAR further objects on the basis that this Request appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks PACCAR further objects that this Request represents an improper attempt to shift the burden of proof PACCAR also objects to this Request as it is argumentative and inappropriately assumes that exposures to all containing products are equal and hazardous despite the abundance of epidemiological studies which demonstrate that mechanics are not at an increased risk of developing an asbestos disease Accordingly without more specificity regarding the type of product type of asbestos fiber amount of exposure duration of exposure and latency period PACCAR cannot fully answer this Request PACCAR also objects to the extent this Request seeks information and documents protected from disclosure by the attorneyclient privilege the work product doctrine or any other applicable protection Finally PACCAR objects that there is no Interrogatory immediately above this Request and PACCAR cannot speculate as to which Interrogatory Plaintiffs are referring Subject to and without waiving the foregoing objections to the extent responsive documents exist PACCAR directs Plaintiffs to the documents produced bates labeled PACCAR000102 REQUEST FOR PRODUCTION NO 5 Please produce all documents and tangible things relating to health or safety inspections of Defendant by local state or federal regulatory agencies This Request for Production specifically seeks but is not limited to all documents and tangible things relating to any violations citations or warnings and includes inspections for asbestos and other dust hazards ANSWER PACCAR incorporates its Preliminary Statement and General Objections PACCAR also objects to this Request as overbroad in scope and time as the only fact witness testimony concerning alleged exposure to any truck allegedly assembled and sold by PACCAR concerns Mr. Dickinson's testimony that he performed brake work 6 times and body work 24 times on Peterbilt trucks and that he performed brake work 6 times body work and engine work 6 times on Kenworth trucks between the years 1979 and 1990. See Discovery Deposition of Charles Dickinson Vol I 4/19/2022 8-16 24-153 23-206 Discovery Deposition of Charles Dickinson Vol II 4/8/2021 23-434 Mr. Dickinson had never worked on PACCAR trucks prior to owning & Collision Services Incorporated in 1979. Id PACCAR further objects that this Request seeks information that is neither relevant nor 30 reasonably calculated to lead to the discovery of admissible evidence in that it is not limited to the products circumstances or time period at issue Furthermore this Request seeks information regarding other dust hazards To the best of PACCAR's knowledge Plaintiffs are alleging exposure in relation to asbestos - not other dust hazards PACCAR further objects on the basis that this Request appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks PACCAR further objects that this Request represents an improper attempt to shift the burden of proof PACCAR also objects to the extent this Request seeks information and documents protected from disclosure by the attorney privilege the work product doctrine or any other applicable protection Subject to and without waiving the foregoing objections PACCAR states that it has not located any information or documents related to any asbestos citation of its unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company with regards to the heavy truck assembly and its component parts REQUEST FOR PRODUCTION NO 6 Please produce all the closing binders and final transaction documents related to all transactions in which Defendant acquired any business entity which manufactured mined distributed supplied or sold containing products ANSWER PACCAR incorporates its Preliminary Statement and General Objections PACCAR also objects to this Request as overbroad in scope and time as the only fact witness testimony concerning alleged exposure to any truck allegedly assembled and sold by PACCAR concerns Mr. Dickinson's testimony that he performed brake work 6 times and body work 24 times on Peterbilt trucks and that he performed brake work 6 times body work and engine work 6 times on Kenworth trucks between the years 1979 and 1990. See Discovery Deposition of Charles Dickinson Vol I 4/19/2022 8-16 24-153 23-206 Discovery Deposition of Charles Dickinson Vol II 4/8/2021 23-434 Mr. Dickinson had never worked on PACCAR trucks prior to owning & Collision Services Incorporated in 1979. Id PACCAR further objects that this Request seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence in that it is not limited to the products circumstances or time period at issue PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Request seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects on the basis that this Request appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks PACCAR also objects to the extent this Request seeks information and documents protected from disclosure by the attorney privilege the work product doctrine or any other applicable protection 31 Subject to and without waiving the foregoing objections PACCAR directs Plaintiffs to its Objections and Answer to Interrogatory No. 14 incorporated herein REQUEST FOR PRODUCTION NO 7 Please produce all the closing binders and final transaction documents related to all transactions in which Defendant was acquired by another entity ANSWER PACCAR incorporates its Preliminary Statement and General Objections PACCAR also objects to this Request as overbroad in scope and time as the only fact witness testimony concerning alleged exposure to any truck allegedly assembled and sold by PACCAR concerns Mr. Dickinson's testimony that he performed brake work 6 times and body work 24 times on Peterbilt trucks and that he performed brake work 6 times body work and engine work 6 times on Kenworth trucks between the years 1979 and 1990. See Discovery Deposition of Charles Dickinson Vol I 4/19/2022 8-16 24-153 23-206 Discovery Deposition of Charles Dickinson Vol II 4/8/2021 23-434 Mr. Dickinson had never worked on PACCAR trucks prior to owning & Collision Services Incorporated in 1979. Id PACCAR further objects that this Request seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence in that it is not limited to the products circumstances or time period at issue PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Request seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR also objects to the extent this Request seeks information and documents protected from disclosure by the attorney privilege the work product doctrine or any other applicable protection Subject to and without waiving the foregoing objections PACCAR directs Plaintiffs to its Objections and Answer to Interrogatory No. 14 incorporated herein REQUEST FOR PRODUCTION NO 8 Please produce all the closing binders and final transaction documents related to all transactions in which Defendant agreed to assume tort liabilities of any third party which manufactured mined distributed supplied or sold containing products ANSWER PACCAR incorporates its Preliminary Statement and General Objections PACCAR also objects to this Request as overbroad in scope and time as the only fact witness testimony concerning alleged exposure to any truck allegedly assembled and sold by PACCAR concerns Mr. Dickinson's testimony that he performed brake work 6 times and body work 24 times on Peterbilt trucks and that he performed brake work 6 times body work and engine work 6 times on Kenworth trucks between the years 1979 and 1990. See Discovery Deposition of Charles Dickinson Vol I 4/19/2022 8-16 24-153 23-206 Discovery Deposition of Charles Dickinson Vol II 4/8/2021 23-434 Mr. Dickinson had never worked on PACCAR trucks prior to owning & Collision Services Incorporated in 1979. Id 32 PACCAR further objects that this Request seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence in that it is not limited to the products circumstances or time period at issue PACCAR further objects on the basis that this Request appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Request seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR also objects to the extent this Request seeks information and documents protected from disclosure by the attorney privilege the work product doctrine or any other applicable protection Subject to and without waiving the foregoing objections PACCAR directs Plaintiffs to its Objections and Answer to Interrogatory No. 14 incorporated herein REQUEST FOR PRODUCTION NO 9 Please produce all the closing binders and final transaction documents related to all transactions in which Defendant agreed to indemnify defend or hold harmless the tort liabilities of any third party which manufactured mined distributed supplied or sold asbestoscontaining products ANSWER PACCAR incorporates its Preliminary Statement and General Objections PACCAR also objects to this Request as overbroad in scope and time as the only fact witness testimony concerning alleged exposure to any truck allegedly assembled and sold by PACCAR concerns Mr. Dickinson's testimony that he performed brake work 6 times and body work 24 times on Peterbilt trucks and that he performed brake work 6 times body work and engine work 6 times on Kenworth trucks between the years 1979 and 1990. See Discovery Deposition of Charles Dickinson Vol I 4/19/2022 8-16 24-153 23-206 Discovery Deposition of Charles Dickinson Vol II 4/8/2021 23-434 Mr. Dickinson had never worked on PACCAR trucks prior to owning & Collision Services Incorporated in 1979. Id PACCAR further objects that this Request seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence in that it is not limited to the products circumstances or time period at issue PACCAR further objects on the basis that this Request appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Request seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR also objects to the extent this Request seeks information and documents protected from disclosure by the attorney privilege the work product doctrine or any other applicable protection 33 Subject to and without waiving the foregoing objections PACCAR directs Plaintiffs to its Objections and Answer to Interrogatory No. 14 incorporated herein REQUEST FOR PRODUCTION NO 10 Please produce all the closing binders and final transaction documents related to all transactions in which Defendant changed its name ANSWER PACCAR incorporates its Preliminary Statement and General Objections PACCAR also objects to this Request as overbroad in scope and time as the only fact witness testimony concerning alleged exposure to any truck allegedly assembled and sold by PACCAR concerns Mr. Dickinson's testimony that he performed brake work 6 times and body work 24 times on Peterbilt trucks and that he performed brake work 6 times body work and engine work 6 times on Kenworth trucks between the years 1979 and 1990. See Discovery Deposition of Charles Dickinson Vol I 4/19/2022 8-16 24-153 23-206 Discovery Deposition of Charles Dickinson Vol II 4/8/2021 23-434 Mr. Dickinson had never worked on PACCAR trucks prior to owning & Collision Services Incorporated in 1979. Id PACCAR further objects that this Request seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence in that it is not limited to the products circumstances or time period at issue PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Request seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR also objects to the extent this Request seeks information and documents protected from disclosure by the attorney privilege the work product doctrine or any other applicable protection Subject to and without waiving the foregoing objections PACCAR directs Plaintiffs to its Objections and Answer to Interrogatory No. 14 incorporated herein REQUEST FOR PRODUCTION NO 11 Please produce all documents and tangible things received or obtained by Defendant before 1970 that indicate that inhaled asbestos fibers can be hazardous to human or human health This Request for Production specifically seeks but is not limited to all responsive books articles reports pamphlets and manufacturer's instructions ANSWER PACCAR incorporates its Preliminary Statement and General Objections PACCAR also objects to this Request as overbroad in scope and time as the only fact witness testimony concerning alleged exposure to any truck allegedly assembled and sold by PACCAR concerns Mr. Dickinson's testimony that he performed brake work 6 times and body work 24 times on Peterbilt trucks and that he performed brake work 6 times body work and engine work 6 times on Kenworth trucks between the years 1979 and 1990. See Discovery Deposition of Charles Dickinson Vol I 4/19/2022 8-16 24-153 34 23-206 Discovery Deposition of Charles Dickinson Vol II 4/8/2021 23-434 Mr. Dickinson had never worked on PACCAR trucks prior to owning & Collision Services Incorporated in 1979. Id PACCAR further objects that this Request seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence in that it is not limited to the products circumstances or time period at issue PACCAR further objects on the basis that this Request appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks PACCAR also objects to the extent this Request seeks information and documents protected from disclosure by the attorney privilege the work product doctrine or any other applicable protection PACCAR further objects that this Request represents an improper attempt to shift the burden of proof PACCAR also objects to this Request as argumentative because it inappropriately assumes that exposures to all containing products are equal and hazardous despite the abundance of epidemiological studies which demonstrate that mechanics are not at an increased risk of developing an asbestos disease Accordingly without more specificity regarding the type of product type of asbestos fiber amount of exposure duration of exposure and latency period PACCAR cannot fully answer this Request Subject to and without waiving the foregoing objections PACCAR is aware of no responsive documents REQUEST FOR PRODUCTION NO 12 Please produce all documents and tangible things relating to the inventories of all Defendant's libraries research repositories or other archives that contain magazines journals books publications or other documents related to asbestos pneumoconiosis or any other related disease including but not limited to the effects of exposure to asbestos industrial hygiene measures relating to asbestos dust and medical information or research relating to asbestos or its effects on animals or humans populations at risk etc. This Request for Production specifically seeks but is not limited to all card catalogs indices holding lists databases other record management systems and subscription lists for periodicals such as Journal of the American Medical Association Industrial Medicine Journal of Industrial Hygiene and Toxicology National Safety News Industrial Hygiene Foundation Digest and Public Health Reports of the United States ANSWER PACCAR incorporates its Preliminary Statement and General Objections PACCAR also objects to this Request as overbroad in scope and time as the only fact witness testimony concerning alleged exposure to any truck allegedly assembled and sold by PACCAR concerns Mr. Dickinson's testimony that he performed brake work 6 times and body work 24 times on Peterbilt trucks and that he performed brake work 6 times body work and engine work 6 times on Kenworth trucks between the years 1979 and 1990. See Discovery Deposition of Charles Dickinson Vol I 4/19/2022 8-16 24-153 23-206 Discovery Deposition of Charles Dickinson Vol II 4/8/2021 23-434 Mr. Dickinson had never worked on PACCAR trucks prior to owning & Collision Services Incorporated in 1979. Id PACCAR further objects that this Request seeks information that is neither relevant nor 35 reasonably calculated to lead to the discovery of admissible evidence in that it is not limited to the products circumstances or time period at issue PACCAR also objects to the extent this Request seeks information and documents protected from disclosure by the attorney privilege the work product doctrine or any other applicable protection Furthermore this Request seeks information regarding other related disease To the best of PACCAR'S knowledge Plaintiffs are alleging exposure in relation to asbestos - not other related disease PACCAR further objects on the basis that this Request is unduly burdensome and appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture asbestos- containing products rather they assembled and sold heavy duty trucks Subject to and without waiving the foregoing objections PACCAR did not maintain a library whose purpose was to contain books articles periodicals journals and reference materials regarding asbestos PACCAR has maintained a general reference library since 1974 PACCAR also maintained a Technical Center library from 1986 until February 2018. Discovery is ongoing and PACCAR reserves the right to supplement or amend its Response to this Request if new or additional information is obtained REQUEST FOR PRODUCTION NO 13 Please produce all documents and tangible things containing information concerning the hazards of asbestos or nuisance dust in general that Defendant received at any time ANSWER PACCAR incorporates its Preliminary Statement and General Objections PACCAR also objects to this Request as overbroad in scope and time as the only fact witness testimony concerning alleged exposure to any truck allegedly assembled and sold by PACCAR concerns Mr. Dickinson's testimony that he performed brake work 6 times and body work 24 times on Peterbilt trucks and that he performed brake work 6 times body work and engine work 6 times on Kenworth trucks between the years 1979 and 1990. See Discovery Deposition of Charles Dickinson Vol I 4/19/2022 8-16 24-153 23-206 Discovery Deposition of Charles Dickinson Vol II 4/8/2021 23-434 Mr. Dickinson had never worked on PACCAR trucks prior to owning & Collision Services Incorporated in 1979. Id PACCAR further objects that this Request seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence in that it is not limited to the products circumstances or time period at issue Furthermore this Request seeks information regarding nuisance dust To the best of PACCAR's knowledge Plaintiffs are alleging exposure in relation to asbestos - not nuisance dust PACCAR further objects on the basis that this Request is unduly burdensome and appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks PACCAR also objects to the extent this Request seeks information and documents protected from disclosure by the attorney privilege the work product doctrine or any other applicable protection 36 Subject to and without waiving the foregoing objections and to the extent responsive documents exist PACCAR directs Plaintiffs to the documents produced bates labeled PACCAR000001 REQUEST FOR PRODUCTION NO 14 Please produce all documents and tangible things containing information concerning the hazards of asbestos or nuisance dust in general that Defendant published distributed or disseminated at any time ANSWER PACCAR incorporates its Preliminary Statement and General Objections PACCAR also objects to this Request as overbroad in scope and time as the only fact witness testimony concerning alleged exposure to any truck allegedly assembled and sold by PACCAR concerns Mr. Dickinson's testimony that he performed brake work 6 times and body work 24 times on Peterbilt trucks and that he performed brake work 6 times body work and engine work 6 times on Kenworth trucks between the years 1979 and 1990. See Discovery Deposition of Charles Dickinson Vol I 4/19/2022 8-16 24-153 23-206 Discovery Deposition of Charles Dickinson Vol II 4/8/2021 23-434 Mr. Dickinson had never worked on PACCAR trucks prior to owning & Collision Services Incorporated in 1979. Id PACCAR further objects that this Request seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence in that it is not limited to the products circumstances or time period at issue Furthermore this Request seeks information regarding nuisance dust To the best of PACCAR's knowledge Plaintiffs are alleging exposure in relation to asbestos not nuisance dust PACCAR further objects on the basis that this Request is unduly burdensome and appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks PACCAR also objects to the extent this Request seeks information and documents protected from disclosure by the attorney privilege the work product doctrine or any other applicable protection PACCAR further objects that this Request is confusing as drafted given that it does not refer to any particular product PACCAR further objects on the basis that its Kenworth and Peterbilt divisions have assembled hundreds of thousands of trucks during their histories that those trucks were custom at the direction request and specification of the purchaser that certain information regarding those trucks is maintained by Vehicle Identification Number that Plaintiffs have not identified the Vehicle Identification Number of any Kenworth or Peterbilt truck and therefore the location and identification of information responsive to this Request is unduly burdensome and oppressive and obtainable through less expensive and burdensome means Subject to and without waiving the foregoing objections PACCAR states that upon information and belief Kenworth and Peterbilt provided service literature authored by their component suppliers to dealers and customers Specifically Kenworth and Peterbilt provided their dealers with master shop manuals that were comprised of a series of three binders which included component supplier service manuals Kenworth and Peterbilt also made these master shop manuals available to users for purchase Additionally Kenworth and Peterbilt provided individual component supplier manuals inside the glove compartments or sleeper 37 compartments of their trucks These manuals would correspond to the particular components specified by the user for a given truck Upon information and belief some of these component service manuals would have contained asbestos warnings starting in the 1970s For example PACCAR has located a 1978 Rockwell brake maintenance manual containing such a warning Further to the extent responsive documents exist PACCAR directs Plaintiffs to the documents produced bates labeled PACCAR000674 REQUEST FOR PRODUCTION NO 15 Please produce all documents and tangible things created by any of Defendant's employees former employees or representatives at any time that refer to any documents or tangible things responsive to the Request for Production immediately above ANSWER PACCAR incorporates its Preliminary Statement and General Objections PACCAR also objects to this Request as overbroad in scope and time as the only fact witness testimony concerning alleged exposure to any truck allegedly assembled and sold by PACCAR concerns Mr. Dickinson's testimony that he performed brake work 6 times and body work 24 times on Peterbilt trucks and that he performed brake work 6 times body work and engine work 6 times on Kenworth trucks between the years 1979 and 1990. See Discovery Deposition of Charles Dickinson Vol I 4/19/2022 8-16 24-153 23-206 Discovery Deposition of Charles Dickinson Vol II 4/8/2021 23-434 Mr. Dickinson had never worked on PACCAR trucks prior to owning & Collision Services Incorporated in 1979. Id PACCAR further objects that this Request seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence in that it is not limited to the products circumstances or time period at issue PACCAR further objects on the basis that this Request is unduly burdensome and appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks PACCAR also objects to the extent this Request seeks information and documents protected from disclosure by the attorney privilege the work product doctrine or any other applicable protection PACCAR further objects that this Request is confusing as drafted given that it does not refer to any particular product PACCAR further objects on the basis that its Kenworth and Peterbilt divisions have assembled hundreds of thousands of trucks during their histories that those trucks were custom at the direction request and specification of the purchaser that certain information regarding those trucks is maintained by Vehicle Identification Number that Plaintiffs have not identified the Vehicle Identification Number of any Kenworth or Peterbilt truck and therefore the location and identification of information responsive to this Request is unduly burdensome and oppressive and obtainable through less expensive and burdensome means Subject to and without waiving the foregoing objections PACCAR directs Plaintiffs to its Objections and Answer to Request for Production No. 14 incorporated herein REQUEST FOR PRODUCTION NO 16 Please produce all documents and tangible things generated by Defendant before 1970 that discuss or refer to the Fleischer Report 38 ANSWER PACCAR incorporates its Preliminary Statement and General Objections PACCAR also objects to this Request as overbroad in scope and time as the only fact witness testimony concerning alleged exposure to any truck allegedly assembled and sold by PACCAR concerns Mr. Dickinson's testimony that he performed brake work 6 times and body work 24 times on Peterbilt trucks and that he performed brake work 6 times body work and engine work 6 times on Kenworth trucks between the years 1979 and 1990. See Discovery Deposition of Charles Dickinson Vol I 4/19/2022 8-16 24-153 23-206 Discovery Deposition of Charles Dickinson Vol II 4/8/2021 23-434 Mr. Dickinson had never worked on PACCAR trucks prior to owning & Collision Services Incorporated in 1979. Id PACCAR further objects that this Request seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence in that it is not limited to the products circumstances or time period at issue PACCAR further objects on the basis that this Request appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks PACCAR also objects to the extent this Request seeks information and documents protected from disclosure by the attorney privilege the work product doctrine or any other applicable protection Subject to and without waiving the foregoing objections PACCAR has not located documents responsive to this Request Discovery is ongoing and PACCAR reserves the right to supplement or amend its Response should new or additional information be obtained REQUEST FOR PRODUCTION NO 17 Please produce all documents and tangible things generated by Defendant before 1970 that discuss or refer to the Dreessen Report ANSWER PACCAR incorporates its Preliminary Statement and General Objections PACCAR also objects to this Request as overbroad in scope and time as the only fact witness testimony concerning alleged exposure to any truck allegedly assembled and sold by PACCAR concerns Mr. Dickinson's testimony that he performed brake work 6 times and body work 24 times on Peterbilt trucks and that he performed brake work 6 times body work and engine work 6 times on Kenworth trucks between the years 1979 and 1990. See Discovery Deposition of Charles Dickinson Vol I 4/19/2022 8-16 24-153 23-206 Discovery Deposition of Charles Dickinson Vol II 4/8/2021 23-434 Mr. Dickinson had never worked on PACCAR trucks prior to owning & Collision Services Incorporated in 1979. Id PACCAR further objects that this Request seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence in that it is not limited to the products circumstances or time period at issue PACCAR further objects on the basis that this Request appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks PACCAR also objects to the extent this Request seeks information and documents protected from disclosure by the attorney privilege the work product doctrine or any other applicable protection 39 Subject to and without waiving the foregoing objections PACCAR has not located documents responsive to this Request Discovery is ongoing and PACCAR reserves the right to supplement or amend its Response should new or additional information be obtained REQUEST FOR PRODUCTION NO 18 Please produce all documents and tangible things relating to Defendant's document and record retention and destruction policies or procedures including but not limited to a any supplements addenda memoranda operating bulletins revisions or any other superseding instructions that refer to the stoppage suspension or resumption of responsive policies or procedures and b policies or procedures regarding documents or records created maintained or stored by electronic digital optical and magnetic means such as microfilm microfiche imaging scanning or storage on tapes disks CD or based media databases or on any computer hardware backup system download system file dumping or other system of information management whether on site or site ANSWER PACCAR incorporates its Preliminary Statement and General Objections PACCAR further objects to this Request as overbroad in time and scope and to the extent this Request seeks information and documents protected from disclosure by the attorney privilege the work product doctrine or any other applicable protection Subject to and without waiving the foregoing documents exist PACCAR directs Plaintiffs to the PACCAR000960 PACCAR001005 objections documents to the extent responsive produced bates labeled REQUEST FOR PRODUCTION NO 19 Please produce all demonstrative aids that Defendant plans to use at trial in this matter ANSWER PACCAR incorporates its Preliminary PACCAR also objects to this Request as premature Statement and General Objections Subject to and without waiving the foregoing objections PACCAR states it will designate and produce its demonstrative aids in accordance with the Pennsylvania Rules of Civil Procedure and the governing case management order REQUEST FOR PRODUCTION NO 20 Please produce all documents and tangible things relating to communications between Defendant and any of its worker's compensation insurance carriers or any other insurance companies made at any time regarding containing products the hazards of asbestos or nuisance dust in general and any asbestos studies analyses or testing conducted by any insurance carriers 40 ANSWER PACCAR incorporates its Preliminary Statement and General Objections PACCAR also objects to this Request as overbroad in scope and time as the only fact witness testimony concerning alleged exposure to any truck allegedly assembled and sold by PACCAR concerns Mr. Dickinson's testimony that he performed brake work 6 times and body work 24 times on Peterbilt trucks and that he performed brake work 6 times body work and engine work 6 times on Kenworth trucks between the years 1979 and 1990. See Discovery Deposition of Charles Dickinson Vol I 4/19/2022 8-16 24-153 23-206 Discovery Deposition of Charles Dickinson Vol II 4/8/2021 23-434 Mr. Dickinson had never worked on PACCAR trucks prior to owning & Collision Services Incorporated in 1979. Id PACCAR further objects that this Request seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence in that it is not limited to the products circumstances or time period at issue Furthermore this Request seeks information regarding nuisance dust To the best of PACCAR's knowledge Plaintiffs are alleging exposure in relation to asbestos - not nuisance dust PACCAR further objects on the basis that this Request is unduly burdensome and appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks PACCAR also objects to the extent this Request seeks information and documents protected from disclosure by the attorney privilege the work product doctrine or any other applicable protection PACCAR also objects to the extent that this Request implies that PACCAR had a duty to conduct or contribute to the conducting of any sampling analyses studies or testing of any product which allegedly contained asbestos and was manufactured by another company REQUEST FOR PRODUCTION NO 21 Please produce all documents and tangible things that indicate Defendant's net worth and financial position including but not limited to all 10 forms 10 forms and annual reports for the last ten 10 years If Defendant is not a publicly traded entity please produce Defendant's audited balance sheets cash flow worksheets and federal and state tax returns for the last ten 10 years ANSWER PACCAR incorporates its Preliminary Statement and General Objections PACCAR also objects to this Request as overbroad in scope and time as the only fact witness testimony concerning alleged exposure to any truck allegedly assembled and sold by PACCAR concerns Mr. Dickinson's testimony that he performed brake work 6 times and body work 24 times on Peterbilt trucks and that he performed brake work 6 times body work and engine work 6 times on Kenworth trucks between the years 1979 and 1990. See Discovery Deposition of Charles Dickinson Vol I 4/19/2022 8-16 24-153 23-206 Discovery Deposition of Charles Dickinson Vol II 4/8/2021 23-434 Mr. Dickinson had never worked on PACCAR trucks prior to owning & Collision Services Incorporated in 1979. Id PACCAR further objects that this Request seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence in that it is not limited to the products circumstances or time period at issue PACCAR also objects to the extent this Request seeks information and documents protected from disclosure by the attorney privilege the work product doctrine or any other applicable protection PACCAR also objects 41 that the requested information is either already in Plaintiffs counsel's possession and equally available to Plaintiffs as public record REQUEST FOR PRODUCTION NO 22 Please produce copies of all affidavits depositions and trial transcripts of Defendant's employees former employees or representatives taken in any matter involving an alleged injury or claimed property damage incurred at any time due to asbestos This Request for Production includes all affidavits depositions and trial transcripts of all persons listed by Defendant as having knowledge of relevant facts ANSWER PACCAR incorporates its Preliminary Statement and General Objections PACCAR also objects to this Request as overbroad in scope and time as the only fact witness testimony concerning alleged exposure to any truck allegedly assembled and sold by PACCAR concerns Mr. Dickinson's testimony that he performed brake work 6 times and body work 24 times on Peterbilt trucks and that he performed brake work 6 times body work and engine work 6 times on Kenworth trucks between the years 1979 and 1990. See Discovery Deposition of Charles Dickinson Vol I 4/19/2022 8-16 24-153 23-206 Discovery Deposition of Charles Dickinson Vol II 4/8/2021 23-434 Mr. Dickinson had never worked on PACCAR trucks prior to owning & Collision Services Incorporated in 1979. Id PACCAR further objects that this Request seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence in that it is not limited to the products circumstances or time period at issue PACCAR further objects on the basis that this Request is unduly burdensome and appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks PACCAR also objects to the extent this Request seeks information and documents protected from disclosure by the attorney privilege the work product doctrine or any other applicable protection PACCAR also objects to the extent this Request seeks private information of individuals that are not parties to this litigation PACCAR also objects to this Request as argumentative because it inappropriately assumes that exposures to all asbestoscontaining products are equal and hazardous despite the abundance of epidemiological studies which demonstrate that mechanics are not at an increased risk of developing an asbestos disease Accordingly without more specificity regarding the type of product type of asbestos fiber amount of exposure duration of exposure and latency period PACCAR cannot fully answer this Request PACCAR also objects that the requested information is either already in Plaintiffs counsel's possession and equally available to Plaintiffs as public record REQUEST FOR PRODUCTION NO 23 Please produce copies of all affidavits depositions and trial transcripts in the possession of Defendant of all experts Defendant intends to call at trial ANSWER PACCAR incorporates its Preliminary Statement and General Objections PACCAR also objects to this Request as premature PACCAR further objects to the extent the requested information is either already in Plaintiffs counsel's possession and equally 42 available to Plaintiffs as public record PACCAR also objects to this Request as it is overbroad unduly burdensome and not limited in time or scope Further PACCAR objects to the extent that this Request exceeds the scope of the Pennsylvania Rules of Civil Procedure Subject to and without waiving the foregoing objections PACCAR states it will designate its experts and provide corresponding required documents as they pertain to this pending matter in accordance with the Pennsylvania Rules of Civil Procedure and the governing case management order REQUEST FOR PRODUCTION NO 24 Please produce all documents and tangible things related to inventory stock warehousing or other storage of asbestos or containing products at any location owned operated or controlled by Defendant between 1970 and the present day ANSWER PACCAR incorporates its Preliminary Statement and General Objections PACCAR also objects to this Request as overbroad in scope and time as the only fact witness testimony concerning alleged exposure to any truck allegedly assembled and sold by PACCAR concerns Mr. Dickinson's testimony that he performed brake work 6 times and body work 24 times on Peterbilt trucks and that he performed brake work 6 times body work and engine work 6 times on Kenworth trucks between the years 1979 and 1990. See Discovery Deposition of Charles Dickinson Vol I 4/19/2022 8-16 24-153 23-206 Discovery Deposition of Charles Dickinson Vol II 4/8/2021 23-434 Mr. Dickinson had never worked on PACCAR trucks prior to owning & Collision Services Incorporated in 1979. Id PACCAR further objects that this Request seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence in that it is not limited to the products circumstances or time period at issue PACCAR further objects on the basis that this Request is unduly burdensome and appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks PACCAR also objects to the extent this Request seeks information and documents protected from disclosure by the attorney privilege the work product doctrine or any other applicable protection Finally PACCAR notes that to the best of its knowledge Plaintiffs have not alleged that they were employed by PACCAR worked at a PACCAR facility or were otherwise involved in the assembly of its trucks To the extent this Request seeks information about PACCAR facilities and employment practices that are not at issue it has no legitimate purpose other than to harass PACCAR and confuse the issues Responding further PACCAR possesses the following documents that may be responsive to Plaintiffs Request 1. Build Sheets for trucks assembled prior to 1988 are on microfiche and microfilm For those microfiche and microfilm in PACCAR's possession PACCAR stores the aforementioned microfiche related to Kenworth trucks in Washington and microfiche related to Peterbilt trucks in Texas PACCAR also possesses Peterbilt Build Sheets on microfilm for trucks assembled prior to 1972. These files are indexed by chassis number so with that information documents specific to a particular truck can be 43 identified PACCAR can make these microfiche and microfilm available for physical review and copying at a mutually convenient time at Plaintiffs expense 2. Build Sheets previously kept on microfiche and converted to electronic format for Kenworth and Peterbilt trucks assembled prior to 1988 are stored as TIFF tagged image file format files For Kenworth vehicles these digitized Build Sheets are for trucks assembled from the late 1960's to 1987. For Peterbilt vehicles these digitized Build Sheets are for trucks assembled from the early 1970's to 1987. PACCAR can make all TIFF files available to Plaintiffs at Plaintiffs expense upon reasonable notice These files are indexed by chassis number so with that information documents specific to a particular truck can be identified and 3. Build Sheets for trucks assembled from 1988 to the present are available electronically in vertical bar delimited text files PACCAR can make these vertical bar delimited text files available to Plaintiffs at Plaintiffs expense upon reasonable notice Discovery is ongoing and PACCAR reserves the right to supplement or amend its Response to this Request if new or additional information is obtained REQUEST FOR PRODUCTION NO 25 Please produce all documents and tangible things that indicate Defendant's participation in or funding of any research regarding the health effects of asbestos exposure ANSWER PACCAR incorporates its Preliminary Statement and General Objections PACCAR also objects to this Request as overbroad in scope and time as the only fact witness testimony concerning alleged exposure to any truck allegedly assembled and sold by PACCAR concerns Mr. Dickinson's testimony that he performed brake work 6 times and body work 24 times on Peterbilt trucks and that he performed brake work 6 times body work and engine work 6 times on Kenworth trucks between the years 1979 and 1990. See Discovery Deposition of Charles Dickinson Vol I 4/19/2022 8-16 24-153 23-206 Discovery Deposition of Charles Dickinson Vol II 4/8/2021 23-434 Mr. Dickinson had never worked on PACCAR trucks prior to owning & Collision Services Incorporated in 1979. Id PACCAR further objects that this Request seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence in that it is not limited to the products circumstances or time period at issue PACCAR further objects on the basis that this Request is unduly burdensome and appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks PACCAR also objects to the extent this Request seeks information and documents protected from disclosure by the attorney privilege the work product doctrine or any other applicable protection Subject to and without waiving the foregoing objections PACCAR is aware of airsampling testing conducted between 1976 and 1987 by David Bissonette CIH PACCAR's knowledge concerning the details of these tests are limited however PACCAR is aware that Mr. Bissonette had a three process that he enumerated in a 1976 presentation 1 identify a POSSIBLE hazard 2 evaluate the POSSIBLE hazard 3 if the evaluation shows that there is 44 a hazard put controls in place Mr. Bissonette's testing revealed there were no hazards to mechanics performing automotive work Responding further and to the extent responsive documents exist PACCAR directs Plaintiffs to the documents produced bates labeled PACCAR000102 REQUEST FOR PRODUCTION NO 26 Please produce all documents and tangible things indicating any industrial hygiene advice related to the hazards of asbestos that Defendant received from any insurance carrier at any time ANSWER PACCAR incorporates its Preliminary Statement and General Objections PACCAR also objects to this Request as overbroad in scope and time as the only fact witness testimony concerning alleged exposure to any truck allegedly assembled and sold by PACCAR concerns Mr. Dickinson's testimony that he performed brake work 6 times and body work 24 times on Peterbilt trucks and that he performed brake work 6 times body work and engine work 6 times on Kenworth trucks between the years 1979 and 1990. See Discovery Deposition of Charles Dickinson Vol I 4/19/2022 8-16 24-153 23-206 Discovery Deposition of Charles Dickinson Vol II 4/8/2021 23-434 Mr. Dickinson had never worked on PACCAR trucks prior to owning & Collision Services Incorporated in 1979. Id PACCAR further objects that this Request seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence in that it is not limited to the products circumstances or time period at issue PACCAR further objects on the basis that this Request is unduly burdensome and appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks PACCAR also objects to the extent this Request seeks information and documents protected from disclosure by the attorney privilege the work product doctrine or any other applicable protection PACCAR also objects to the extent that this Request implies that PACCAR had a duty to conduct or contribute to the conducting of any sampling analyses studies or testing of any product which allegedly contained asbestos and was manufactured by another company REQUEST FOR PRODUCTION NO 27 Please produce the personnel records of all witnesses listed in the disclosures that Defendant will make in this case ANSWER PACCAR incorporates its Preliminary Statement and General Objections PACCAR also objects to this Request as premature PACCAR further objects to the extent the requested information is either already in Plaintiffs counsel's possession and equally available to Plaintiffs as public record PACCAR also objects to this Request as it is overbroad unduly burdensome and not limited in time or scope Further PACCAR objects to the extent that this Request exceeds the scope of the Pennsylvania Rules of Civil Procedure 55 Subject to and without waiving the foregoing objections PACCAR states it will designate its witnesses in accordance with the applicable rules and case management order REQUEST FOR PRODUCTION NO 28 Please produce all reports writings whether published or unpublished and other documents and tangible things that were written created and edited by any expert Defendant plans to call at trial and that pertain in any way to the hazards of asbestos ANSWER PACCAR incorporates its Preliminary Statement and General Objections PACCAR also objects to this Request as premature PACCAR further objects to the extent the requested information is either already in Plaintiffs counsel's possession and equally available to Plaintiffs as public record PACCAR also objects to this Request as it is overbroad unduly burdensome and not limited in time or scope PACCAR also objects to the extent this Request seeks information and documents protected from disclosure by the attorney privilege the work product doctrine or any other applicable protection Further PACCAR objects to the extent that this Request exceeds the scope of the Pennsylvania Rules of Civil Procedure Subject to and without waiving the foregoing objections PACCAR states it will designate its experts and provide corresponding required documents as they pertain to this pending matter in accordance with the Pennsylvania Rules of Civil Procedure and the governing case management order REQUEST FOR PRODUCTION NO 29 Please produce all documents and tangible things Defendant's counsel provided to any of Defendant's expert or fact witnesses as a result of the filing of this case ANSWER PACCAR incorporates its Preliminary Statement and General Objections PACCAR also objects to this Request as premature and to the extent it seeks information and documents protected from disclosure by the attorney privilege the work product doctrine or any other applicable protection PACCAR further objects to the extent the requested information is either already in Plaintiffs counsel's possession and equally available to Plaintiffs as public record Further PACCAR objects to the extent that this Request exceeds the scope of the Pennsylvania Rules of Civil Procedure Subject to and without waiving the foregoing objections PACCAR states it will designate its experts and fact witnesses and provide corresponding required documents in accordance with the Pennsylvania Rules of Civil Procedure and the governing case management order REQUEST FOR PRODUCTION NO 30 Please produce all responses to written discovery made by Defendant in all previous or pending asbestos lawsuits other than this lawsuit 46 ANSWER PACCAR incorporates its Preliminary Statement and General Objections PACCAR also objects to this Request as overbroad in scope and time as the only fact witness testimony concerning alleged exposure to any truck allegedly assembled and sold by PACCAR concerns Mr. Dickinson's testimony that he performed brake work 6 times and body work 24 times on Peterbilt trucks and that he performed brake work 6 times body work and engine work 6 times on Kenworth trucks between the years 1979 and 1990. See Discovery Deposition of Charles Dickinson Vol I 4/19/2022 8-16 24-153 23-206 Discovery Deposition of Charles Dickinson Vol II 4/8/2021 23-434 Mr. Dickinson had never worked on PACCAR trucks prior to owning & Collision Services Incorporated in 1979. Id PACCAR further objects that this Request seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence in that it is not limited to the products circumstances or time period at issue PACCAR further objects on the basis that this Request is unduly burdensome and appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks PACCAR also objects to the extent the requested information is either already in Plaintiffs counsel's possession and equally available to Plaintiffs as public record Further PACCAR objects to the extent that this Request exceeds the scope of the Pennsylvania Rules of Civil Procedure REQUEST FOR PRODUCTION NO 31 If Defendant contends it has not been sued in the proper capacity as set forth in Plaintiffs latest petition please produce all documents and tangible things that support this contention ANSWER PACCAR incorporates its Preliminary Statement and General Objections PACCAR states its name is PACCAR Inc no punctuation and that it was incorrectly named as PACCAR Inc. PACCAR directs Plaintiffs to its Objections and Answers to Interrogatory No. 2 incorporated herein Discovery is ongoing and PACCAR reserves the right to supplement or amend its Response REQUEST FOR PRODUCTION NO 32 Please produce all agreements between Defendant and any manufacturer of containing products in which Defendant agreed to act on the manufacturer's behalf in representing selling or distributing the manufacturer's products ANSWER PACCAR incorporates its Preliminary Statement and General Objections PACCAR also objects to this Request as overbroad in scope and time as the only fact witness testimony concerning alleged exposure to any truck allegedly assembled and sold by PACCAR concerns Mr. Dickinson's testimony that he performed brake work 6 times and body work 24 times on Peterbilt trucks and that he performed brake work 6 times body work and engine work 6 times on Kenworth trucks between the years 1979 and 1990. See Discovery Deposition of Charles Dickinson Vol I 4/19/2022 8-16 24-153 23-206 Discovery Deposition of Charles Dickinson Vol II 4/8/2021 23-434 Mr. Dickinson had never 47 worked on PACCAR trucks prior to owning & Collision Services Incorporated in 1979. Id PACCAR further objects that this Request seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence in that it is not limited to the products circumstances or time period at issue PACCAR further objects on the basis that this Request is unduly burdensome and appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks REQUEST FOR PRODUCTION NO 33 Any and all documents and tangible items evidencing sales distribution or supply of asbestos- containing product to any locations identified in Plaintiff's deposition ANSWER PACCAR incorporates its Preliminary Statement and General Objections PACCAR also objects to this Request as overbroad in scope and time as the only fact witness testimony concerning alleged exposure to any truck allegedly assembled and sold by PACCAR concerns Mr. Dickinson's testimony that he performed brake work 6 times and body work 24 times on Peterbilt trucks and that he performed brake work 6 times body work and engine work 6 times on Kenworth trucks between the years 1979 and 1990. See Discovery Deposition of Charles Dickinson Vol I 4/19/2022 8-16 24-153 23-206 Discovery Deposition of Charles Dickinson Vol II 4/8/2021 23-434 Mr. Dickinson had never worked on PACCAR trucks prior to owning & Collision Services Incorporated in 1979. Id PACCAR further objects that this Request seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence in that it is not limited to the products circumstances or time period at issue PACCAR further objects on the basis that this Request appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks PACCAR further objects on the basis that its Kenworth and Peterbilt divisions have assembled hundreds of thousands of trucks during their histories that those trucks were custom at the direction request and specification of the purchaser that certain information regarding those trucks is maintained by Vehicle Identification Number that Plaintiffs have not identified the Vehicle Identification Number of any Kenworth or Peterbilt truck and therefore the location and identification of information responsive to this Request is unduly burdensome and oppressive and obtainable through less expensive and burdensome means PACCAR further objects as PACCAR's Kenworth Truck Company and Peterbilt Motors Company divisions sold their trucks to independently authorized dealerships not users PACCAR also objects to the extent this Request seeks information and documents protected from disclosure by the attorney privilege the work product doctrine or any other applicable protection 88 Subject to and without waiving the foregoing objections PACCAR researched the available information in its order processing warranty registration and warranty claims systems for customer names that include the terms Beacon D D & D Dotter Mrs Reading and Crane and did not find documents or information responsive to this Request Responding further PACCAR possesses the following documents that may be responsive to Plaintiffs Request Build Sheets for trucks assembled prior to 1988 are on microfiche and microfilm For those microfiche and microfilm in PACCAR's possession PACCAR stores the aforementioned microfiche related to Kenworth trucks in Washington and microfiche related to Peterbilt trucks in Texas PACCAR also possesses Peterbilt Build Sheets on microfilm for trucks assembled prior to 1972. These files are indexed by chassis number so with that information documents specific to a particular truck can be identified PACCAR can make these microfiche and microfilm available for physical review and copying at a mutually convenient time at Plaintiffs expense Build Sheets previously kept on microfiche and converted to electronic format for Kenworth and Peterbilt trucks assembled prior to 1988 are stored as TIFF tagged image file format files For Kenworth vehicles these digitized Build Sheets are for trucks assembled from the late 1960's to 1987. For Peterbilt vehicles these digitized Build Sheets are for trucks assembled from the early 1970's to 1987. PACCAR can make all TIFF files available to Plaintiffs at Plaintiffs expense upon reasonable notice These files are indexed by chassis number so with that information documents specific to a particular truck can be identified and Build Sheets for trucks assembled from 1988 to the present are available electronically in vertical bar delimited text files PACCAR can make these vertical bar delimited text files available to Plaintiffs at Plaintiffs expense upon reasonable notice Discovery is ongoing and PACCAR reserves the right to supplement or amend its Response to this Request if new or additional information is obtained REQUEST FOR PRODUCTION NO 34 Any and all depositions trial transcripts and sworn statements in any case alleging exposure to asbestos and containing products by any current and former director officer employee and agents of defendant any predecessor and related entity ANSWER PACCAR incorporates its Preliminary Statement and General Objections PACCAR also objects to this Request as overbroad in scope and time as the only fact witness testimony concerning alleged exposure to any truck allegedly assembled and sold by PACCAR concerns Mr. Dickinson's testimony that he performed brake work 6 times and body work 24 49 times on Peterbilt trucks and that he performed brake work 6 times body work and engine work 6 times on Kenworth trucks between the years 1979 and 1990. See Discovery Deposition of Charles Dickinson Vol I 4/19/2022 8-16 24-153 23-206 Discovery Deposition of Charles Dickinson Vol II 4/8/2021 23-434 Mr. Dickinson had never worked on PACCAR trucks prior to owning & Collision Services Incorporated in 1979. Id PACCAR further objects that this Request seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence in that it is not limited to the products circumstances or time period at issue PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Request seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects on the basis that this Request appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks PACCAR also objects to the extent this Request seeks information and documents protected from disclosure by the attorney privilege the work product doctrine or any other applicable protection In addition PACCAR notes that to the best of its knowledge Plaintiffs have not alleged that they were employed by PACCAR worked at a PACCAR facility or were otherwise involved in the assembly of its trucks To the extent this Request seeks information about PACCAR facilities and employment practices that are not at issue it is irrelevant and it has no legitimate purpose other than to harass PACCAR and confuse the issues PACCAR objects to the extent that this Request exceeds the scope of the Pennsylvania Rules of Civil Procedure REQUEST FOR PRODUCTION NO 35 Any and all corporate reports including but not limited to annual reports for each and every year relating to defendant or any predecessor entity ANSWER PACCAR incorporates its Preliminary Statement and General Objections PACCAR also objects to this Request as overbroad in scope and time as the only fact witness testimony concerning alleged exposure to any truck allegedly assembled and sold by PACCAR concerns Mr. Dickinson's testimony that he performed brake work 6 times and body work 24 times on Peterbilt trucks and that he performed brake work 6 times body work and engine work 6 times on Kenworth trucks between the years 1979 and 1990. See Discovery Deposition of Charles Dickinson Vol I 4/19/2022 8-16 24-153 23-206 Discovery Deposition of Charles Dickinson Vol II 4/8/2021 23-434 Mr. Dickinson had never worked on PACCAR trucks prior to owning & Collision Services Incorporated in 1979. Id PACCAR further objects that this Request seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence in that it is not limited to the products circumstances or time period at issue PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Request seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors 50 Company PACCAR also objects to the extent this Request seeks information and documents protected from disclosure by the attorney privilege the work product doctrine or any other applicable protection PACCAR also objects that the requested information is either already in Plaintiffs counsel's possession and equally available to Plaintiffs as public record REQUEST FOR PRODUCTION NO 36 Any and all annual reports for each and every year relating to defendant or any predecessor entity ANSWER PACCAR incorporates its Preliminary Statement and General Objections PACCAR also objects to this Request as overbroad in scope and time as the only fact witness testimony concerning alleged exposure to any truck allegedly assembled and sold by PACCAR concerns Mr. Dickinson's testimony that he performed brake work 6 times and body work 24 times on Peterbilt trucks and that he performed brake work 6 times body work and engine work 6 times on Kenworth trucks between the years 1979 and 1990. See Discovery Deposition of Charles Dickinson Vol I 4/19/2022 8-16 24-153 23-206 Discovery Deposition of Charles Dickinson Vol II 4/8/2021 23-434 Mr. Dickinson had never worked on PACCAR trucks prior to owning & Collision Services Incorporated in 1979. Id PACCAR further objects that this Request seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence in that it is not limited to the products circumstances or time period at issue PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Request seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR also objects to the extent this Request seeks information and documents protected from disclosure by the attorney privilege the work product doctrine or any other applicable protection PACCAR also objects that the requested information is either already in Plaintiffs counsel's possession and equally available to Plaintiffs as public record Finally PACCAR objects that this Request is duplicative of Request No. 35 above REQUEST FOR PRODUCTION NO 37 Any and all advertising documents promotional materials photographs of products and corporate organizational charts product books catalogues ANSWER PACCAR incorporates its Preliminary Statement and General Objections PACCAR also objects to this Request as overbroad in scope and time as the only fact witness testimony concerning alleged exposure to any truck allegedly assembled and sold by PACCAR concerns Mr. Dickinson's testimony that he performed brake work 6 times and body work 24 times on Peterbilt trucks and that he performed brake work 6 times body work and engine work 6 times on Kenworth trucks between the years 1979 and 1990. See Discovery Deposition of Charles Dickinson Vol I 4/19/2022 8-16 24-153 23-206 Discovery Deposition of Charles Dickinson Vol II 4/8/2021 23-434 Mr. Dickinson had never worked on PACCAR trucks prior to owning & Collision Services Incorporated in 1979. Id 51 PACCAR further objects that this Request seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence in that it is not limited to the products circumstances or time period at issue PACCAR further objects on the basis that its Kenworth and Peterbilt divisions have assembled hundreds of thousands of trucks during their histories that those trucks were custom at the direction request and specification of the purchaser that certain information regarding those trucks is maintained by Vehicle Identification Number that Plaintiffs have not identified the Vehicle Identification Number of any Kenworth or Peterbilt truck and therefore the location and identification of information responsive to this Request is unduly burdensome and oppressive and obtainable through less expensive and burdensome means Subject to and without waiving the foregoing objections and to the extent responsive documents exist PACCAR directs Plaintiffs to the documents produced bates labeled PACCAR000674 Responding further PACCAR possesses the following documents that may be responsive to Plaintiffs Request 1. Build Sheets for trucks assembled prior to 1988 are on microfiche and microfilm For those microfiche and microfilm in PACCAR's possession PACCAR stores the aforementioned microfiche related to Kenworth trucks in Washington and microfiche related to Peterbilt trucks in Texas PACCAR also possesses Peterbilt Build Sheets on microfilm for trucks assembled prior to 1972. These files are indexed by chassis number so with that information documents specific to a particular truck can be identified PACCAR can make these microfiche and microfilm available for physical review and copying at a mutually convenient time at Plaintiffs expense 2. Build Sheets previously kept on microfiche and converted to electronic format for Kenworth and Peterbilt trucks assembled prior to 1988 are stored as TIFF tagged image file format files For Kenworth vehicles these digitized Build Sheets are for trucks assembled from the late 1960's to 1987. For Peterbilt vehicles these digitized Build Sheets are for trucks assembled from the early 1970's to 1987. PACCAR can make all TIFF files available to Plaintiffs at Plaintiffs expense upon reasonable notice These files are indexed by chassis number so with that information documents specific to a particular truck can be identified and 3. Build Sheets for trucks assembled from 1988 to the present are available electronically in vertical bar delimited text files PACCAR can make these vertical bar delimited text files available to Plaintiffs at Plaintiffs expense upon reasonable notice Answering further PACCAR can make these additional documents available upon request at a mutually agreeable time and place Discovery is ongoing and PACCAR reserves the right to supplement or amend its Response to this Request if new or additional information is obtained 52 REQUEST FOR PRODUCTION NO 38 Any and all writings or documents including but not limited to invoices contracts purchase orders inventory records engineering standards sales books which concern the sale delivery or transfer any asbestos containing products ANSWER PACCAR incorporates its Preliminary Statement and General Objections PACCAR also objects to this Request as overbroad in scope and time as the only fact witness testimony concerning alleged exposure to any truck allegedly assembled and sold by PACCAR concerns Mr. Dickinson's testimony that he performed brake work 6 times and body work 24 times on Peterbilt trucks and that he performed brake work 6 times body work and engine work 6 times on Kenworth trucks between the years 1979 and 1990. See Discovery Deposition of Charles Dickinson Vol I 4/19/2022 8-16 24-153 23-206 Discovery Deposition of Charles Dickinson Vol II 4/8/2021 23-434 Mr. Dickinson had never worked on PACCAR trucks prior to owning & Collision Services Incorporated in 1979. Id PACCAR further objects that this Request seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence in that it is not limited to the products circumstances or time period at issue PACCAR further objects on the basis that this Request appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks PACCAR further objects on the basis that its Kenworth and Peterbilt divisions have assembled hundreds of thousands of trucks during their histories that those trucks were custom at the direction request and specification of the purchaser that certain information regarding those trucks is maintained by Vehicle Identification Number that Plaintiffs have not identified the Vehicle Identification Number of any Kenworth or Peterbilt truck and therefore the location and identification of information responsive to this Request is unduly burdensome and oppressive and obtainable through less expensive and burdensome means PACCAR also objects to the extent this Request seeks information and documents protected from disclosure by the attorney privilege the work product doctrine or any other applicable protection Responding further PACCAR possesses the following documents that may be responsive to Plaintiffs Request 1. Build Sheets for trucks assembled prior to 1988 are on microfiche and microfilm For those microfiche and microfilm in PACCAR's possession PACCAR stores the aforementioned microfiche related to Kenworth trucks in Washington and microfiche related to Peterbilt trucks in Texas PACCAR also possesses Peterbilt Build Sheets on microfilm for trucks assembled prior to 1972. These files are indexed by chassis number so with that information documents specific to a particular truck can be identified PACCAR can make these microfiche and microfilm available for physical review and copying at a mutually convenient time at Plaintiffs expense 2. Build Sheets previously kept on microfiche and converted to electronic format for Kenworth and Peterbilt trucks assembled prior to 1988 are stored as TIFF tagged image file format files For Kenworth vehicles these digitized Build Sheets are for trucks assembled from the late 1960's to 1987. For Peterbilt vehicles these digitized Build 53 Sheets are for trucks assembled from the early 1970's to 1987. PACCAR can make all TIFF files available to Plaintiffs at Plaintiffs expense upon reasonable notice These files are indexed by chassis number so with that information documents specific to a particular truck can be identified and 3. Build Sheets for trucks assembled from 1988 to the present are available electronically in vertical bar delimited text files PACCAR can make these vertical bar delimited text files available to Plaintiffs at Plaintiffs expense upon reasonable notice Answering further PACCAR can make these additional documents available upon request at a mutually agreeable time and place Discovery is ongoing and PACCAR reserves the right to supplement or amend its Response to this Request if new or additional information is obtained REQUEST FOR PRODUCTION NO 39 Please produce all documents and tangible things relating to the cessation of asbestoscontaining product use in any of Defendant's plants ANSWER PACCAR incorporates its Preliminary Statement and General Objections PACCAR also objects to this Request as overbroad in scope and time as the only fact witness testimony concerning alleged exposure to any truck allegedly assembled and sold by PACCAR concerns Mr. Dickinson's testimony that he performed brake work 6 times and body work 24 times on Peterbilt trucks and that he performed brake work 6 times body work and engine work 6 times on Kenworth trucks between the years 1979 and 1990. See Discovery Deposition of Charles Dickinson Vol I 4/19/2022 8-16 24-153 23-206 Discovery Deposition of Charles Dickinson Vol II 4/8/2021 23-434 Mr. Dickinson had never worked on PACCAR trucks prior to owning & Collision Services Incorporated in 1979. Id PACCAR further objects that this Request seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence in that it is not limited to the products circumstances or time period at issue PACCAR further objects on the basis that this Request appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks PACCAR also objects to the extent this Request seeks information and documents protected from disclosure by the attorney privilege the work product doctrine or any other applicable protection PACCAR also objects to this Request to the extent that there is no allegation of work for PACCAR or at any PACCAR facility and therefore any information regarding PACCAR facilities is irrelevant and has no legitimate purpose other than to harass PACCAR and confuse the issues PACCAR objects to the extent that this Request exceeds the scope of the Pennsylvania Rules of Civil Procedure REQUEST FOR PRODUCTION NO 40 Please produce all documents and tangible things relating to Defendant's consideration of alternatives to the use of containing products before 1990 54 ANSWER PACCAR incorporates its Preliminary Statement and General Objections PACCAR also objects to this Request as overbroad in scope and time as the only fact witness testimony concerning alleged exposure to any truck allegedly assembled and sold by PACCAR concerns Mr. Dickinson's testimony that he performed brake work 6 times and body work 24 times on Peterbilt trucks and that he performed brake work 6 times body work and engine work 6 times on Kenworth trucks between the years 1979 and 1990. See Discovery Deposition of Charles Dickinson Vol I 4/19/2022 8-16 24-153 23-206 Discovery Deposition of Charles Dickinson Vol II 4/8/2021 23-434 Mr. Dickinson had never worked on PACCAR trucks prior to owning & Collision Services Incorporated in 1979. Id PACCAR further objects that this Request seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence in that it is not limited to the products circumstances or time period at issue PACCAR further objects on the basis that this Request appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture asbestos- containing products rather they assembled and sold heavy duty trucks PACCAR also objects to this Request to the extent it seeks information and documents protected from disclosure by the attorney privilege the work product doctrine or any other applicable protection Subject to and without waiving the foregoing objections and to the extent responsive documents exist PACCAR directs Plaintiffs to the documents produced bates labeled PACCAR000103 REQUEST FOR PRODUCTION NO 41 Please produce all health surveys and epidemiological studies regarding asbestos exposure conducted between 1990 and Present at Defendant's request or involving any of Defendant's employees ANSWER PACCAR incorporates its Preliminary Statement and General Objections PACCAR also objects to this Request as overbroad in scope and time as the only fact witness testimony concerning alleged exposure to any truck allegedly assembled and sold by PACCAR concerns Mr. Dickinson's testimony that he performed brake work 6 times and body work 24 times on Peterbilt trucks and that he performed brake work 6 times body work and engine work 6 times on Kenworth trucks between the years 1979 and 1990. See Discovery Deposition of Charles Dickinson Vol I 4/19/2022 8-16 24-153 23-206 Discovery Deposition of Charles Dickinson Vol II 4/8/2021 23-434 Mr. Dickinson had never worked on PACCAR trucks prior to owning & Collision Services Incorporated in 1979. Id PACCAR further objects that this Request seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence in that it is not limited to the products circumstances or time period at issue PACCAR further objects on the basis that this Request appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture asbestos- containing products rather they assembled and sold heavy duty trucks PACCAR also objects to this Request to the extent it seeks information and documents protected from disclosure by the attorney privilege the work product doctrine or any other applicable protection 55 PACCAR also objects to the extent that this Request implies that PACCAR had a duty to conduct or contribute to the conducting of any sampling analyses studies or testing of any product which allegedly contained asbestos and was manufactured by another company Subject to and without waiving the foregoing objections PACCAR is aware of airsampling testing conducted between 1976 and 1987 by David Bissonette CIH PACCAR'S knowledge concerning the details of these tests are limited however PACCAR is aware that Mr. Bissonette had a three process that he enumerated in a 1976 presentation 1 identify a POSSIBLE hazard 2 evaluate the POSSIBLE hazard 3 if the evaluation shows that there is a hazard put controls in place Mr. Bissonette's testing revealed there were no hazards to mechanics performing automotive work Responding further and to the extent responsive documents exist PACCAR directs Plaintiffs to the documents produced bates labeled PACCAR000102 Date January 26 2023 LAVIN CEDRONE GRAVER BOYD & DISIPIO BY John J. Bateman John J. Bateman Esquire Counsel for Defendant PACCAR Inc and its unincorporated divisions Peterbilt Motors Co. and Kenworth Truck Company JBateman@Lavin-Law.com 56 VERIFICATION Rod Curbo being first duly sworn deposes and states as follows That he is the Corporate Representative for Peterbilt Motors Company a division of PACCAR Inc which is a defendant in the above entitled action that he has read the foregoing Answers to Plaintiff's Interrogatories and knows the contents thereof that said Answers were prepared with the assistance and advice of counsel and the assistance of employees and representatives of PACCAR Inc upon which he relied that the Answers subject to inadvertent or undiscovered errors are based on and therefore necessarily limited by the records and information still in existence presented or recollected and thus far discovered in the course of the preparation of the Answers that consequently defendant reserves the right to make any changes in the Answers if it appears at any time that omissions or errors have been made therein or that more accurate information is available that subject to the limitations set forth herein said Answers are true to the best of his knowledge information and belief Custo SWORN TO AND SUBSCRIBED BEFORE ME THIS 12TH DAY OF JANUARY 2023 DANA LEE Notary ID 7780038 My Commission Expires July 8 2023 57 VERIFICATION Rod Curbo being first duly sworn deposes and states as follows That he is the Corporate Representative for Peterbilt Motors Company a division of PACCAR Inc which is a defendant in the above entitled action that he has read the foregoing Answers to Plaintiffs Requests for Production and knows the contents thereof that said Answers were prepared with the assistance and advice of counsel and the assistance of employees and representatives of PACCAR Inc upon which he relied that the Answers subject to inadvertent or undiscovered errors are based on and therefore necessarily limited by the records and information still in existence presented or recollected and thus far discovered in the course of the preparation of the Answers that consequently defendant reserves the right to make any changes in the Answers if it appears at any time that omissions or errors have been made therein or that more accurate information is available that subject to the limitations set forth herein said Answers are true to the best of his knowledge information and belief SWORN TO AND SUBSCRIBED BEFORE ME THIS 12TH DAY OF JANUARY 2023 DANA LEE Notary ID 7780038 My Commission Expires July 8 2023 58