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ATLANTA GEORGIA BRUSSELS BELGIUM CNABLOTTC CAROLINA mOnG KONG *no*vill. tcnnCSSCE mclEan viRGiNia Lou M. Elliott Hunton & Williams Rivebfhont Plaza. East Toweh eoi East Bybd Street Richmond. Viroinia 23210-4074 Telephone (8041 788-8200 Facsimile 1804) 788-8218 NEW 0K SEN YORK NORTOLK ViRG'NiA RAlC'Gh NO#tn CAROL'NA WARSAW AOUANO WASHINGTON. 0 C Direct Dial: (804) 7M-S639 Bv Overnight Mail July 29, 1996 EL FILE Mr. Oscar Soliz District Clerk Nueces County Courthouse 901 Leopard Street Corpus Christi, Texas 78401 AUG.05.56* 4294] Leona Tiner v. Reynolds Metals Company, et al. No. 94-03884-B Dear Mr. Soliz: Please find enclosed the following documents to be filed in the above-referenced matter: 1. Defendant Reynolds Metals Company's First Supplemental Responses To Plaintiffs First Set Of Interrogatories; and 2. Defendant Reynolds Metals Company's Responses To Plaintiffs Second Set Of Interrogatories. I have enclosed a third copy which I would appreciate your stamping filed and returning to me in the enclosed self-addressed, stamped envelope. By copy of this letter, these documents are being served on plaintiffs' counsel via certified mail, return receipt requested, and on other known defense counsel by U.S. firstclass mail, postage prepaid. Thank you for your assistance with this matter. If you have any questions, please do not hesitate to call. Sincerely yours. Enclosures Lori M. Elliott AUG.05.96* 42942 Cause No. 94-03884-B LEONA TINER, Individually and as 9 Personal Representative of the 9 Heirs and Estate of Robert D. Tiner, Deceased, 9 Plaintiff, 9 9 v. 9 9 REYNOLDS METALS COMPANY and 9 GILMAN INSULATION COMPANY, 9 Defendants. 9 9 IN THE DISTRICT COURT NUECES COUNTY, TEXAS 117th JUDICIAL DISTRICT DEFENDANT REYNOLDS METALS COMPANY'S RESPONSES TO PLA1 ICHMiat F'S SECOND SET OF INTERROGATORIES TO: PLAINTIFF, LEONA TINER, Individually and as Personal Representative of the Hein of Robert D. Tiner, Deceased, by and through their attorney of record, C. Andrew Waters, Baron & Budd, A Professional Corporation, The Centrum, 3102 Oak Lawn Avenue, Suite 1100, Dallas, Texas 75219. Pursuant to the provisions of Rules 167 and 168 of the Texas Rules of Civil Procedure, Defendant, REYNOLDS METALS COMPANY, by counsel, hereby serves the following for its Responses to Plaintiffs Second Set of Interrogatories. Respectfully submitted, CHAVES, GONZALES & HOBUT, L.L.P. State Bar of Texas No. 11863720 HUNTON & WILLIAMS Riverfront Plaza, East Tower 951 East Byrd Street Richmond, Virginia 23219 (804) 788-8200 (804) 788-8218 (facsimile^ toYBoldi Meul Company1! Rewont To Plaintiff! Second Set of Interrogilorwa- Paw I R. Clay Hoblit State Bar No. 09743100 R. Gary Laws State Bar No. 00786045 2000 Frost Bank Plaza 802 N. Carancahua Corpus Christi, Texas 78470 (512) 888-9392 (512) 888-9187 (facsimile) Attorneys for Reynolds Metals Company CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing instrument has been served via certified mail, return receipt requested and by overnight mail, on this the 29th day of July, 1996, on the following counsel of record in this proceeding: Russell W. Budd, Esq. Patrick N. Haines, Esq. BARON & BUDD 3102 Oak Lawn Avenue Suite 1100 Dallas, Texas 75219 William Abemethy, Esq. Clay Coalson, Esq. MEREDITH, DONNEL & ABERNETHY 1500 One Shoreline Post Office Box 2624 Corpus Christi, Texas 78403-2624 Reynold! Mettle Cotnoanv'i Rcwwmc To PteinUfTi Second Set of lnterroglorie- Pate 2 GENERAL OBJECTIONS Reynolds objects to these interrogatories for the reason that they seek to require Reynolds to set out in detail, and at its peril the relevant knowledge of its witnesses, which is properly the subject of deposition. Reynolds objects to this interrogatory as it is impossible in the context of this case to list each and every fact, in narrative form, which supports Reynolds' position. Further, there is no provision in the Texas Rules of Civil Procedure requiring a party to state "each and every fact" or anything in detail, and such request is merely an attempt to limit trial testimony. Reynolds objects to these interrogatories for the reason that they exceed the permissible number of interrogatories as provided in Rule 168(5) of the Texas Rules of Civil Procedure. Reynolds objects to these interrogatories as calling for trial strategy and attorney work product which are privileged from discovery pursuant to Rule 166b(3)(a) of the Texas Rules of Civil Procedure. Reynolds further objects to these interrogatories as they attempt to invade the attorney-client privilege. INTERROGATORY NO. 1: For each person identified in response to Plaintiffs Interrogatory No. 22, contained in Plaintiffs First Set of Interrogatories, please describe, with reasonable particularity, the relevant facts to which each person could be expected to testify and each and every fact upon which you intend to rely. Rgyaold Mtttlt Coctmuy'i Rmpowk To PUintifT* Second Set of Interrogtioric*- P 3 ANSWER; Reynolds incorporates its General Objections herein. Reynolds objects that Plaintiffs First Interrogatory No. 22 did not request the names of individuals Reynolds expected to testify at trial. Instead, Plaintiffs First Interrogatory No. 22 requested the name of "each and every person . . . having knowledge of facts relevant to this case." Consequently, Reynolds does not expect that each person listed in response to Plaintiffs First Interrogatory No. 22 will testify at trial. Reynolds specifically states that any response to this interrogatory does not indicate that the individuals listed will, or will not, be called to testify on Reynolds' behalf at trial. Subject to and without waiving any of its prior objections, Reynolds states the following: 1. Dr. Charles D. Dixon - Deceased. 2. Dr. Draper - Deceased. 3. Dr. Harry R. Bratt - Dr. Bratt was the Sherwin Alumina Plant Medical Director from 1971 through 1975. 4. Dr. Robert Dale Gamble - Dr. Gamble was the Sherwin Alumina Plant Medical Director from 1975 through 1989. 5. Dr. John Frandolig - Dr. Frandolig was the Sherwin Alumina Plant Medical Director from 1989 through 1991. 6. Dr. Guy Racette - Dr. Racette was the Sherwin Alumina Plant Medical Director from 1991 through 1993. 7. Dr. Wendell Roberts - Dr. Roberts is the Sherwin Alumina Plant physician and was Mr. Tiner's personal physician. Mcttli Comp--v' Rcwxxac To PUimitT* Second S of Intenowioriet- P 4 8. Dr. James MacMillan - Dr. MacMillan was the Corporate Medical Director for Reynolds from 1956-77. 9. Dr. E. Claiborne Irbv - Dr. Irby was the Associate Medical Director for Reynolds from 1959-77 and the Corporate Medical Director from 1977-92. 10. Dr. David Warren - Dr. Warren was the acting Corporate Medical Director for Reynolds from 1992-93. 11. Dr. Woolson W. Doane - Dr. Doane is the Corporate Medical Director for Reynolds. 12. Homer M. Cole - Mr. Cole is the Corporate Director of Industrial Hygiene and Toxicology for Reynolds. 13. Ronald Benton 14. Linda Maillet - Mr. Benton was a member of the Industrial Hygiene Department at the Corporate Headquarters of Reynolds fron 1974 to 1995, and he is currendy the Director of the Safety Department. Ms. Maillet is a Regional Industrial Hygienist at the Corporate Headquarters of Reynolds who is responsible for the Eastern Region. IS. Laurie Shelby - Ms. Shelby is the Manager of Industrial Hygiene Programs at the Corporate Headquarters of Reynolds. 16. James D. Davidson - Mr. Davidson was a Staff Industrial Hygienist at the Corporate Headquarters of Reynolds. 17. Stacey Hansen < Ms. Hansen was a Staff Industrial Hygienist at the Corporate Headquarters of Reynolds. 18. Deborah R. Hudgins - Ms. Hudgins was a Staff Industrial Hygienist at the Corporate Headquarters of Reynolds. RtvooM* Mttl Compuv't RewKXwe To PUimifT* Second Set of Inlerroglone- Pge 3 19. Edward J. Lareent - Mr. Largent was a member of the Industrial Hygiene Department at the Corporate Headquarters of Reynolds. 20' Mr. Mansur was the Manager of the Industrial Hygiene Department at the Corporate Headquarters of Reynolds. 21. Dale Prokopchak - Mr. Prokopchak was a Staff Industrial Hygienist at the Corporate Headquarters of Reynolds. 22. H.L. Skalskv - Mr. Skalsky was a Medical Advisor, Physician, or member of the Industrial Hygiene Department at the Corporate Headquarters of Reynolds. 23. Karen Kestte - Ms. Kestle is the Senior Insurance Administrator at the Corporate Headquarters of Reynolds. 24. Bobbv J. Sasser - Mr. Sasser was the Corporate Safety Director for Reynolds from 1973 to 1995. 25. C. Alton Boatman - Mr. Boatman is the Health & Safety Manager for Sherwin. He may have knowledge of Reynolds' safety procedures, the use of asbestos, and abatement of asbestos at the Sherwin Plant, as well as other information. He may also have knowledge concerning Mr. Tiner's work habits, assignments, and medical condition. 26. Terry N, Roubittoua - Mr. Roubidoux is the Safety Coordinator for Sherwin. He may have knowledge of Reynolds' safety procedures, the use of asbestos, and abatement of asbestos at the Sherwin Plant, as well as other information. 27. Danis Cheaney - Ms. Cheaney is a Workers' Compensation Clerk at Sherwin. RgTBoMi Mcttto Comptnv'i Rewonic To PUintifTi Second Set of In>errog>toric- Pik 6 28. William E. Hamblin - Mr. Hamblin is the Senior Maintenance Engineer at Sherwin. He may have knowledge of Reynolds' safety procedures, the use of asbestos, and abatement of asbestos at the Sherwin Plant, as well as other information. 29. Delons Ulke - Ms. Ulke is the Head Nurse at Sherwin. Ms. Ulke's deposition transcript. 30. Tim Woods - Mr. Woods is the Plant Controller at Sherwin. He may have knowledge of Reynolds' safety procedures, the use of asbestos, and abatement of asbestos at the Sherwin Plant, as well as other information. 31. C.R. Marsh - Mr. Marsh is a Purchasing Agent at Sherwin. He may have knowledge of Reynolds' safety procedures, the use of asbestos, and abatement of asbestos at the Sherwin Plant, as well as other information. 32. Dorothy Withers * Ms. Withers is the Secretary to the Purchasing Manager for Sherwin. 33. Frank Strickland - Mr. Strickland is the Purchasing Manager for Sherwin. 34. D.'L.Greewn - Mr. Greeson is a Purchasing Agent for Sherwin. He may have knowledge of Reynolds' safety procedures, the use of asbestos, and abatement of asbestos at the Sherwin Plant, as well as other information. 33. limJlffiuy- Mr. Tiffany was the Plant Engineer at Sherwin from approximately 1973-1976 and was a general Engineer, Maintenance Superintendent, and Senior Engineer for various periods from 1964-73 and 1983 to the present. Sfifi Mr. Tiffany's deposition transcript. RctpoM Mcttli Compuv'i Rmpomb To PUimifTi Second Set of Interrogilontt- Pgt 7 36. Jack C. Oates Mr. Oates was the Plant Engineer at Sherwin from 1980-84 and was a Maintenance Engineer, Project Engineer, and Project Manager for various periods from 1967-74 and 1977-91. He may have knowledge of Reynolds' safety procedures, the use of asbestos, and abatement of asbestos at the Sherwin Plant, as well as other information. 37. Howard T e* firote - Mr. Grote is the Maintenance Engineer at Sherwin. He may have knowledge of Reynolds' safety procedures, the use of asbestos, and abatement of asbestos at the Sherwin Plant, as well as other information. 38. Jesse Castillo - Mr. Castillo is a Draftsman in the Engineering Department of Sherwin. He may have knowledge of Reynolds' safety procedures, the use of asbestos, and abatement of asbestos at the Sherwin Plant, as well as other information. 39. Edward S. Peterson. Jr. - Mr. Peterson is a Senior Project Engineer at Sherwin. He may have knowledge of Reynolds* safety procedures, the use of asbestos, and abatement of asbestos at the Sherwin Plant, as well as other information. 40. T.J. Mueller. Jr. - Mr. Mueller is a Senior Electrical Engineer at Sherwin. He may have knowledge of Reynolds' safety procedures, the use of asbestos, and abatement of asbestos at the Sherwin Plant, as well as other information. 41. Paul Matula - Mr. Matula is a Designer in the Engineering Department of Sherwin. He may have knowledge of Reynolds' safety procedures, the use of asbestos, and abatement of asbestos at the Sherwin Plant, as well as other information. 42. George D. DeAlcala - Mr. DeAlcala is an Electrical Engineer at Sherwin. He may have knowledge of Reynolds' safety procedures, the use of asbestos, and abatement of asbestos at the Sherwin Plant, as well as other information. '* RewQBK To PUintifTi Second Set of toterroHorw- PM 43. Charles IL Taylor - Mr. Taylor is the Corrosion Control Supervisor at Sherwin. He may have knowledge of Reynolds' safety procedures, the use of asbestos, and the abatement of asbestos at the Sherwin Plant, as well as other information. 44. Audelia T. Rodriguez - Ms. Rodriquez is the secretary to the Plant Engineer at Sherwin. She may have knowledge of Reynolds' safety procedures and the use of asbestos at the Sherwin Plant, as well as other information. 43. Hector De La Garza - Mr. De La Garza has been in the Environmental Department at Sherwin. He may have knowledge of Reynolds' safety procedures, the use of asbestos, and the abatement of asbestos at the Sherwin Plant. 46. Adan J. Villarreal - Mr. Villarreal is the Cost Accountant at Sherwin. 47. Lester Charles Homan - Mr. Homan is a Senior Accountant at Sherwin. 48. Nelda Salinas - Ms. Salinas is the Accounts Payable Clerk at Sherwin. 49. Stan Millsao - Mr. Millsap was the Safety Director at Sherwin. He may have knowledge of Reynolds' safety procedures and the use of asbestos at the Sherwin Plant, as well as other information. He may also have knowledge of Mr. Tiner's work habits and assignments. 30. Joseph Nichols - Mr. Nichols was the Corporate Safety Director for Reynolds from 1945-73. 51. Service Environmental Co. - This company performed insulation and/or asbestos abatement work at the Sherwin plant. 52. Industrial Specialist Inc. - This company performed insulation and/or asbestos abatement work at the Sherwin plant. RfTWMt MfMl* Company'* Rewont To PUimifTi Second Set of IrntfroMtorie*- Pige 9 &S3. Estes Refractory Insulation - This company performed insulation and/or asbestos abatement work at the Sherwin plant. 54. TGI Stephens - This company performed insulation and/or asbestos abatement work at the Sherwin plant. 55. Thermo Tech Inc. - This company performed insulation and/or asbestos abatement work at the Sherwin plant. 56. Gilman Insulation Co. - This company performed insulation and/or asbestos abatement work at the Sherwin plant. 57. Falcon Associates - This company performed insulation and/or asbestos abatement work at the Sherwin plant. 58. Brand Remediation Services. Inc. - This company performed insulation and/or asbestos abatement work at the Sherwin plant. 59. Northwinds Abatement. Inc. - This company performed insulation and/or asbestos abatement work at the Sherwin plant. 60. dasanova Industrial Insulation - This company performed insulation and/or asbestos abatement work at the Sherwin plant. INTERROGATORY NQ. 2: Do you contend that Plaintiffs Decedent's injuries and damages, as alleged in this law suit, were the result of Decedent's own actions and/or alleged negligence? If the answer is anything other than "no", identify each and every fact which supports this contention. Reynold* McUli Company'* Kewom* To PUiatifT* Second Set of Interrognorie*- Pire 10 ANSWER; Reynolds incorporates its General Objections herein. Discovery is ongoing. Subject to and without waiving any of its prior objections, Reynolds states that is continuing its investigation of this matter. Reynolds states further that Mr. Tiner's supervisors at Sherwin specifically warned him, and others, about the hazards associated with, and the safety procedures required when, working with asbestos. Answering further, Reynolds refers plaintiff to the depositions taken in this case. INTERROGATORY NO. 3: Do you contend that Plaintiffs Decedent's injuries and damages, as alleged in this law suit, were solely the result of the actions of other entities, over whom Defendant had no right of control? If the answer is anything other than "no", identify each and every fact which supports this contention. ANSWER; Reynolds incorporates its General Objections herein. Discovery is ongoing. Subject to and without waiving any of its prior objections, Reynolds states that is continuing its investigation of this matter. Reynolds states further that Mr. Tiner was not exposed to harmful levels of asbestos while employed by Reynolds. INTERROGATORY NO. 4: Do you contend that Defendant specifically warned Robert Tiner about the hazards of asbestos and asbestos-containing products prior to 1972? If the answer is anything other than "no", identify each and every fact which supports this contention. CotnPMV't Rmpohm To PUiifT Second Set of toterrogrtorict- Pige 11 ANSWER: Reynolds incorporates its General Objections herein. Discovery is ongoing. Subject to and without waiving any of its prior objections, Reynolds states that Mr. Tiner's supervisors at Sherwin specifically warned him, and others, about the hazards associated with, and the safety procedures required when, working with asbestos both before and after 1972. Answering further, Reynolds refers plaintiff to the depositions taken and the documents produced by Reynolds in this case. INTERROGATORY NO. 5: Do you contend that Defendant specifically warned Robert Tiner about the hazards of asbestos and asbestos-containing products prior to 1984? If the answer is anything other than "no", identify each and every fact which supports this contention. ANSWER: See Answer to Interrogatory No. 4. INTERROGATORY NO. 6: Do you contend that Defendant specifically warned Robert Tiner about the hazards of asbestos and asbestos-containing products prior to 1993? If the answer is anything other than "no", identify each and every fact which supports this contention. ANSWER: Sfifi Answer to Interrogatory No. 4. ' Rmpobm To PUimifTi Second Set of lnterroMtori**- Pmc 12 INTERROGATORY NO. 7: Do you contend that Robert Tiner was not exposed to asbestos while employed by Defendant? If the answer is anything other than "no", identify each and every fact which supports this contention. ANSWER: Reynolds incorporates its General Objections herein. Reynolds objects to this interrogatory for the reason that the term "exposed" in the context of this litigation is vague, and without further explanation, cannot be meaningfully answered. Moreover, discovery is ongoing. Subject to and without waiving any of its prior objections, Reynolds states that Mr. Tiner was not exposed to harmful levels of asbestos while employed by Reynolds. INTERROGATORY NO. 8: Do you contend that Robert Tiner's injuries and damages, as alleged in this law suit, were the result of exposure to asbestos at jobsites and/or locations other than Defendant's Sherwin facility? If the answer is anything other than "no", identify each and every fact which supports this contention. ANSWER! See Answer to Interrogatory No. 7. In addition, Robert Tiner has claimed that he was exposed to asbestos at Southwest Refinery in Corpus Christi, Texas, including Combustion Engineering and Riley Stokes boilers, and that the exposure to asbestos products at that site caused his mesothelioma. Rwomc To PUintiff. Wond Set of Intcrrowtorict- Pra 13 INTERROGATORY NO. 9: Do you contend that Defendant performed measurements and/or studies prior to 1970 to determine the quantity of asbestos fibers in the air at the Sherwin facility? If the answer is anything other than "no", identify each and every fact which supports this contention. ANSWER: Reynolds incorporates its General Objections herein. Discovery is ongoing. Subject to and without waiving any of its prior objections, Reynolds states that it is continuing its investigation of this matter. At this time, Reynolds believes that any asbestos fibers in the air at the Sherwin facility were not harmful because of the nature of the plant, the safety practices and procedures in place for handling asbestos, and the availability of protective equipment. INTERROGATORY NO. 10: Do you contend that Defendant's representatives, insurance carriers and/or agents performed measurements and/or studies prior to 1970 to determine the quantity of asbestos fibers in the air at the Sherwin facility? If the answer is anything other than "no", identify each and every fact which supports this contention. ANSWER; Sec Answer to Interrogatory No. 9. INTERROGATORY NO. 11: Do you contend that Defendant provided dust masks and/or respirators to Robert Tiner, specifically for the purpose of protection from the hazards of asbestos and asbestos-containing products, prior to 1970? If the answer is anything other than "no", identify each and every fact which supports this contention. ' Rewome To PUinUfTt Second Si of IntcrroMtonw- Pibc 14 ANSWER: Reynolds incorporates its General Objections herein. Discovery is ongoing. Subject to and without waiving any of its prior objections, Reynolds states that, prior to 1970, it provided Mr. Tiner with dust masks and/or respirators, and instructions how to use them, for the purpose of protecting Mr. Tiner from asbestos fibers and other dust. Answering further, Reynolds refers plaintiff to the depositions taken and the documents produced by Reynolds in this case. INTERROGATORY NO. 12: Do you contend that Robert Tiner did not suffer from mesothelioma? If the answer is anything other than "no", identify each and every fact which supports this contention. ANSWER: Reynolds incorporates its General Objections herein. Discovery is ongoing. Subject to and without waiving any of its prior objections, Reynolds states that it is continuing its investigation of this matter. INTERROGATORY NO. 13: Do you contend that Robert Tiner's mesothelioma was not caused by exposure to asbestos? If the answer is anything other than "no", identify each and every fact which supports this contention. ANSWER; SfiC Answers to Interrogatory Nos. 7 and 12. tawofcto Mul Company'* Rcx>nt To PtoinUfTi Second So of Intenwiorie*- Pw 15 INTERROGATORY NO. 14: Do you contend that Robert Tiner's mesothelioma was not caused by exposure to asbestos while employed at Reynolds Metals Company? If the answer is anything other than "no", identify each and every fact which supports this contention. ANSWER; See Answers to Interrogatory Nos. 7 and 12. INTERROGATORY NO. 15: Did Defendant enter into any contracts with the Federal Government or any of its agencies between 1960 and 1972, wherein the amount of said contract exceeded $10,000? ANSWER: Yes. INTERROGATORY NO. 16: If the answer to Interrogatory No. 15 is "yes", did any of the materials, supplies, articles or equipment manufactured or furnished under said contracts originate from the Sherwin facility? ANSWER: No. INTERROGATORY NO. 17: For each individual Reynolds Metals employee or former employee listed below, please identify all trade and/or professional organizations to which said individual belonged at any time. Kraoldt Mcttb Compnv, Rmpomb To PUinUtTi Second Set of Imerrogiionen Pc 16 ANSWER: (a) E.C. Iiby, M.D. Certified by American Board of Preventive Medicine In Occupational Medicine Virginia Occupational Medical Association Virginia Medical Society Richmond Academy of Medicine American College of Physicians American College of Preventive Medicine Governor's Advisory Committee for Toxic Substance Information Act Advisory Committee, Virginia Industrial Commission American Aluminum Association Health Committee Steering Committee Health Careers, Virginia Council of Health and Medical Care Advisory Committee NIOSH Educational Resource Center, North Carolina Governor's Advisory Board-Health and Safety Codes American Occupational Medicine Association American Academy of Occupational Medicine American College of Occupational Medicine American Medical Association (b) Homer Cole Aluminum Association Health Committee Aluminum Association Task Group on Welding Aluminum Association Task Group on Trace Metals International Primary Aluminum Institute Health Committee MCV Affiliated Associate Professor University of North Carolina School of Public Health American Industrial Hygiene Association Central Virginia Industrial Hygiene Association Academy of Industrial Hygiene American College of Toxicology (c) Edward Largent The New York Academy of Sciences American Industrial Hygiene Association American Conference of Governmental Industrial Hygienists American Chemical Society Reynold! MUli Company' Remnie To PUinifT* Second Set of InUrrog.toric*- Pge 17 (d) Richard Mansur American Industrial Hygiene Association American Conference of Governmental Industrial Hygiene (e) J.M. MacMillan, M.D. American College of Physicians Southern Medical Association American Medical Association Occupational Medical Association (0 B.J. Sasser American Society of Testing and Materials American Society of Safety Engineers National Fire Protection Association Virginia Manufacturing Association Safety Committee Certified Safety Professional (Safety and Health Codes Board, Virginia) Aluminum Association (ad hoc safety committee) (g) Ron Benton American Industrial Hygiene Association National Safety Council American Society of Safety Engineers American Academy of Industrial Hygiene The Society of Sigma Xi American National Standards Institute Certified Industrial Hygienist Certified Safety Professional Registered Occupational Hygienist in Canada INTERROGATORY NO. 18: Does Defendant have a Corporate Safety and Health Committee? If so, please identify all members of said committee and state whether minutes of the meetings of said committee are and/or have been maintained. IUtboMi Metilf Comptnv't Rcwxxat To PUiatifT* Second Set of Imcrrog.iooo- Pire 18 ANSWER: Reynolds incorporates its General Objections herein. Reynolds objects to this interrogatory as overly broad in time, place, and subject matter. The requested information is irrelevant in this lawsuit and not reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving any of its prior objections, Reynolds states that it does not have a "Corporate Safety and Health Committee," but has other committees which address safety and health issues. SSS the documents produced in this litigation. Company' Reaowc To PUirtifTi Second Set of totenogitoric*- Pe 19 REYNOLDS METALS COMPANY By: Arf/rw3oa1ma.* ARLON BOATMAN C Manager, Health and Safety STATE OF TEXAS COUNTY oiGnBasicio S 5 BEFORE ME, the undersigned Notary Public, on this day personally appeared ARLON BOATMAN, Manager, Health and Safety, for REYNOLDS METALS COMPANY, who being by me duly sworn under oath and deposed and said that he is the representative of Defendant REYNOLDS METALS COMPANY in the above entitled and numbered cause; he is charged with collecting information gathered by REYNOLDS METALS COMPANY'S officers, agents and/or employees; has compiled this information as a result of the investigation of REYNOLDS METALS COMPANY'S officers, agents and/or employees; (hat he has read the questions contained in the foregoing instrument and that to the best of his knowledge, information, and belief, formed after reasonable inquiry, the statements contained therein are true and correct and are based upon the information that is available and has been gathered by REYNOLDS METALS COMPANY'S officers, agents and/or employees. Aritnu Rnntmnn ARLON BOATMAN SUBSCRIBED AND SWORN TO BEFORE ME, by the said ARLON BOATMAN on this the2fcfe'd*y of July, 1996, to certify which witness my hand and seal of office. L.C. HOMAN MV COMSSIM EXPIRES Augusta, 1W7 Nfttaxy Public in and for the State of Texas L-Co------------- rrOMfW______ Prim or type name My commission expires: 9Z-2A~*I7 TOTAL P.03