Document mq9d6Q1gQ8qrV8NOr96qdgymJ

l PLAINTIFF'S EXHIBIT ) 1 PATRICK J. HAGAN, ESQ. (State Bar #68264) S. JANE WELLS, ESQ. (State Bar #112178) 2 DILLINGHAM & MURPHY 225 Bush Street, Sixth Floor 3 San Francisco, CA 94104-4207 4, (415) 397-2700 5 Attorneys for Defendant KAISER GYPSUM COMPANY, INC. 6 7 SUPERIOR COURT FOR THE STATE OF CALIFORNIA 8 FOR THE COUNTY OF SAN FRANCISCO . ' 9 10 IN RE: SAN FRANCISCO COUNTY 11 COMPLEX ASBESTOS LITIGATION 12 13 14 CASE NO. 828684 - KAISER GYPSUM COMPANY, INC.'S UPDATED RESPONSES TO PLAINTIFFS' STANDARD INTERROGATORIES TO DEFENDANTS 15 PROPOUNDING PARTY : Plaintiffs 16 RESPONDING PARTY : Defendant Kaiser Gypsum Company, Inc. 17 SET : Standard 18 DATE : December 30, 1996 A. 19 COMES NOW defendant Kaiser Gypsum Company, Inc. (hereinafter 20 "Kaiser Gypsum"), and provides the following updated responses to 21 plaintiffs' standard interrogatories propounded pursuant to San 22 Francisco County Complex Asbestos Litigation General Order No. 29: 23 KAISER GYPSUM'S PRELIMINARY STATEMENT AND OBJECTIONS 24 Kaiser'Gypsum was constituted in 1952 and has been J\ 25 headquartered in California since that date. Kaiser Gypsum 26 disposed of its last operating manufacturing plant in August 1978 27 and subsequently has not engaged in manufacturing or product sales 28 anywhere in the United States. Thus, all Kaiser Gypsum product 1 sales occurred between 1952 and 1978. Therefore, Kaiser Gypsum's 2 responses to plaintiffs* standard interrogatories are based almost 3 entirely on its ongoing review of documents presently available to 4 the These updated interrogatory responses reflect Kaiser Gypsum's 5, knowledge at this time and supersede any previous interrogatory 6 answers. Kaiser Gypsum reserves the right to further supplement 7 these responses in the event that more complete or accurate 8 information becomes available. ' 9 Kaiser Gypsum notes that these responses are made without 10 reference to the factual circumstances of any particular case, 11 and, accordingly, Kaiser Gypsum reserves the right to state 12 additional objections or provide supplemental responses that might 13 be appropriate in the specific context of a given plaintiff's 14 claim(s). 15 Kaiser Gypsum objects to requests for information that are 16 unlimited as to geographical scope on the grounds that such ]_7 requests are -unduly burdensome and are not reasonably calculated 18 to lead to the discovery of evidence admissible in cases that are A. 19 subject to General Order No. 29. Accordingly, Kaiser Gypsum's 20 present responses hereto are limited to products sold and 21 operations conducted within the State of California. 22 ,, Kaiser Gypsum objects to these interrogatories to the extent 23. that they call for information protected by the attorney/client 24 privilege"or.*work product doctrine. 25 This Preliminary Statement and the objections contained 26 herein are incorporated into each of the responses set forth 27 below. 28 / / / v ) ..V jj 1 KAISER GYPSUM1S RESPONSES TO INTERROGATORIES 2 RESPONSE TO INTERROGATORY MO. 1: 3 (a) Joseph R. Hobby. 4 (b) 2680 Bishop Drive, Suite 225, San Ramon, 5 . 94583. 6 (c) Vice President. 7 (d) 12/1/95-present: Vice President 8 RESPONSE TO INTERROGATORY NO . 2: 9 Kaiser Gypsum is a corporation. 10 (a) Its full and correct corporate name is Kaiser Gypsum 11 Company, Inc. 12 (b) Kaiser Gypsum is incorporated under the laws of the 13 State of-Washington. > 14 (c) Kaiser Gypsum was organized in 1952 through a somewhat 15 complicated process. Specifically, on June 19, 1952, Permanente 16 Cement Company (now known as Kaiser Cement Corporation) formed a 17 wholly owned `subsidiary named Kaiser Gypsum Company, a California 18 Corporation. On August 1, 1952 Kaiser Gypsum Company purchased 19 from the Henry J. Kaiser Company two gypsum wallboard plants 20 located at Long Beach and Redwood City, California. . 21 On December 1, 1952, Kaiser Gypsum Company wast merged into 22 Pacific Coast Cement Company, another subsidiary of Permanente 23 Cement Company, with Pacific Coast Cement Company, a Washington 24 Corporation,' rwhich at the time of the merger had no assets or 25 operations and which was incorporated on November 28, 1927, being 26 the survivor. The name of the combined company was then changed 27 to Kaiser Gypsum Company, Inc. 28 r 1 (d) Kaiser Gypsum's principal place of business.is located 2 at 3000 3usch Road, Pleasanton, California 94566. 3 (e) Kaiser Gypsum has held a certificate of authority to dp 4 business in California from 1952 to the present. 5 (f) . Kaiser Gypsum's California "registered agent" is CT 6 Corporation, 818 West Seventh Street, Los Angeles, CA 90017. 7 (g) Kaiser Gypsum is a wholly owned subsidiary of Kaiser 8 Cement Corporation, whose principal place of business is located 9 at 3000 Busch Road, Pleasanton, California 94566. 10 RESPONSE TO INTERROGATORY NO. 3: 11 . Yes. See the history of Kaiser Gypsum's formation in 1952 12 that is provided in its answer to Interrogatory 2(c) above. 13 RESPONSE TO INTERROGATORY NO. 4: 14 (a) No. 15 (b) Not applicable. 16 (c) Not applicable. 17 RESPONSE TO INTERROGATORY NO. 5: 18 No. A. 19 RESPONSE TO INTERROGATORY NO. 6: 20 (a) Kaiser Gypsum's corporate records are located at its 21 headquarters, whose address is 3000 Busch Road, Pleasanton, 22 California 94566; at 2680 Bishop Drive, San Ramon, CA 94583; and 23 at a commercial storage site or sites located in the greater San 24 Francisco -area. 25 (b) Joseph R. Hobby, Vice President, 2680 Bishop Drive, San 26 Ramon, California. 27 RESPONSE TO INTERROGATORY NO. 7: 28 (a) through (h): No. I 1 RESPONSE TO INTERROGATORY NO. 8: 2 (a) See response to 8(e) and 8(g). 3 (b) No. 4 (c) See response to 8(e) and 8(g). 5 .(d). See response to 8(e) and 8 (g) 6 (e) Yes. 1953 to 1976. 7 (f) See response to 8(e) and 8(g). 8 (g) Yes. 1953 to 1976. 9 RESPONSE TO INTERROGATORY NO. 9: 10 Not applicable. 11 RESPONSE TO INTERROGATORY NO. 10: 12 I. 13 Kaiser Gyps-urn's Business: Gypsum Plaster, Gypsum Lath, and Gypsum Wallboard - No Asbestos Used 14 Kaiser Gypsum was organized by Henry J;. Kaiser- (1882-1967), 15 the famous industrialist and World War II hero, in 1952 and 16 terminated its United States sales and manufacturing in 1978. 17 Between 1952 and 1978, Kaiser Gypsum's principal business 18 consisted of manufacturing and marketing gypsum plaster, gypsum 19 lath and gypsum wallboard. Tlie word "gypsum" is derived from the 20 Greek word "gypso," meaning chalk. "Gypsum" is hydrous calcium 21 sulfate. Gypsum plaster is sometimes called Plaster of Paris, 22 because gypsum.plaster was widely used in the capital of France 23 during the 19th century. Gypsum occurs in nature in rock form, and is found,in abundance in Baja California, Mexico. 24 A. Gypsum Plaster Products 25 ' 26 During Kaiser Gypsum's first years in business, most houses and many other buildings had interior walls that were made with 27 plaster. The plaster products sold by Kaiser Gypsum were 28 essentially finely-ground gypsum rock packaged in bags. Such gypsum plaster products were mixed with water and an aggregate (most commonly sand) at the construction site to form a paste. The paste was applied by hand and smoothed with a trowel to form a" wall, or ceiling surface. Sometimes several layers of plaster were used, with the underneath layers being brown in color and the surface layer being white. When dried,.the plaster became quite hard. A plaster wall or ceiling typically was' finished by painting the plaster surface or covering- it with wallpaper. Kaiser Gypsum's plaster products designed for the above construction uses included Hardwall Plaster, Fibered Hardwall l; Plaster, Dual Purpose Fibered Hardwall Plaster, Dual Purpose i: Unfibered Hardwall Plaster, Wood Fibered Hardwall Plaster, Slow i< Set Gauging Plaster, and Quick Set Gauging Plaster. They also 1: included plaster products for casting (e.q., making ornaments or ii statues including Casting Plaster and Slow Set Casting Plaster). r Kaiser Gypsum also manufactured Plaster Retarder and Structural ii Gypsum (Pre-Mixed Gypsum Concrete).' Kaiser Gypsum plaster l: products also included Red-E-Mix plaster, a pre-mixed product 2i which combined plaster and aggregate, that was introduced in 1956. 2! Gun Plaster, introduced in 1957, was applied by mixing the sacked 2: product on the job site in special portable mixing machines, and 2 it was then pumped through a large diameter hose to the inside of a building where it was sprayed by plasterers onto walls, with comparative speed and economy. Kaiser Gypsum never used asbestos as a component in any of those products. twriij 1 B. gypsum Lath Products 2 The surface to which gypsum plaster was applied .was called 3| "lath." Lath was sometimes made of wire, but lath also could be 4 made of hard, paper covered sheets of gypsum plaster (called 5 gypsum stucco), sometimes made with holes in them. The lath 6 sheets would be affixed to the interior wall framing, and . 7 plaster would then be applied to the lath. The holes in the lath 8 would help keep the plaster in place while it dried. Kaiser Gypsum 9 made gypsum lath of this type. Kaiser Gypsum lath products - 10 included Plain Lath and Perforated Lath, Foil-Back Insulating 111 Lath, Duralath, Gypsum Veneer Base, and Kaiserwall. Kaiser Gypsum 12 never used asbestos as a component in any of those products. 13 . C. Gypstmt Wallboard Products 14 In years following the Korean War, there were numerous 15 innovations in housing construction, including many changes 3.6j intended to lower housing construction costs. One such change was 17 the substitution of gypsum wallboard, or drywall, for plaster. 18 Gypsum wallboard, like gypsum lath, is basically a hard sheet of !9j gypsum plaster that is affixed to the wall framing. Typically 20 gypsum wallboard would be made in pieces that were 4 feet wide and 21 8 feet long. They typically were 1/2 inch or 5/8 inch thick. 22 During the manufacturing process, the wallboard's core of gypsum 23 plaster was covered by a special paper that could be painted or 24 covered, .with wallpaper. 25 Because more walls, partitions or ceilings could be made 26! using gypsum wallboard in a given period of time than could be 27 made by plastering over lath, constructing houses, apartments and 28 other buildings with wallboard was less expensive. Over time, as ll building codes were amended to permit use of gypsum wallboard, 2 more construction of interior Walls, partitions and ceilings was 3 done using wallboard and less using plaster. Reflecting this 4 trend, Kaiser Gypsum's business focused more on gypsum wallboard 5 as time passed. By 1960 about half of the construction in 6 California used wallboard and half still used plaster. Plaster use 7 continued to decline, and by the early 1970's substantially all of 8 the market demand was for gypsum wallboard. Kaiser Gypsum never 9 used asbestos as a component in any of its gypsum wallboard 10 products. 11 D. Non-Asbestos Products Exceeded 90% Of Total Sales 12 The bulk of Kaiser Gypsum's sales has always consisted of . I 13 products that did not nse asbestos as a component. To illustrate, 14 the following chart shows sales totals in dollars for the years 15! 1969-1975, the last full year prior to the complete cessation of 16 the use of asbestos as a component in Kaiser Gypsum products: 17 Year Non-Asbestos Non-Asbestos Product j ` Products Total Sales Percentage Of Total 18 1969 41,360,000 $43,299,000 96% 19 1970 $37,258,000 $39,457,000 94% ' 20 1971 $48,403,000 $51,671,000 1972 $58,463,000 $63,056,000 21 1973 $65,803,000 $71,382,000 22 1974 $64,996,000 $70,139,000 23 1975 $41,318,000 $43,935,000 94% 93% 92% 93% 94% 24 As these figures illustrate, Kaiser Gypsum's sales of non 25 asbestos-containing products always were substantially more than 26 90% of its business. - 27 28 1 IX. Accessories For Use With Gypsum Wallboard 2 A. Nails, Wall And Door Frames, Comerbead, 3 Paper Products - No Asbestos Osed________ 4 With the expansion of its gypsum wallboard business, Kaiser 5 Gypsum also began selling other products needed to construct 6 interior walls, partitions or ceilings using gypsum wallboard. 7 These included special nails and other devices used to attach . 8 wallboard to the supporting frame. They also included metal wall 9 or partition frames especially, made for installing wallboard, 10 metal "comerbead" used to make partition corners hard, and metal 11 doorframes for use in walls made using gypsum wallboard. Partly 12 to ensure that it could get access to adequate amounts of the 13 special paper used to make wallboard {by covering its gypsum 14 plaster core), Kaiser Gypsum acquired paper plants, where it also 15 manufactured commercial paper products such as cardboard boxes. 16 Kaiser Gypsum.never used asbestos as a component in any of those 17 products. 18 B. Wallboard Joint Compounds Asbestos Used As A Component 19 A When the walls or ceilings of a room are made from gypsum 20 wallboard, large pieces of wallboard are installed side by side, 21 leaving small spaces where two pieces of wallboard meet. These 22 spaces need to be filled so that they cannot be seen after the 23 wall is painted or covered with wallpaper. The products used to 24 perform "that' task are called joint compounds or joint finishing 25 compounds. At the time of use, these joint compounds are thick 26 putty or mud-like substances, which permits them to be pushed into 27 the spaces and smoothed with a putty knife or spatula. Paper or 28 cloth reinforcing tape is pushed into the joint compound to help prevent cracking as the joint compound dries.. The joint compound dries to form a hard rock-like substance. Kaiser Gypsum manufactured and marketed such wallboard joint compounds, and prior to the mid-1970's, these joint compounds contained a small percentage of chrysotile asbestos as a component. The purpose of the chrysotile asbestos component was to prevent cracks from forming as the joint --compound dried. "Asbestos" is the Greek word for! "incombustible," which refers to things that will not burn. Chrysotile is the most common type of asbestos used in products in the United States. Chrysotile is a fibrous rock material derived from the rock "serpentine" which is very common in California, where it is the "state rock." These Kaiser Gypsum products were: :. 1. Joint Cement/Joint Compound 2. Finishing (Topping) Compound 3. 3-Purpose Wallboard Compound ' 4.--One-Day Joint Compound 5. Pre-ittix Joint Compound 6. Pre-mix Finishing Compound 7. Pre-mix Dual Purpose Joint Compound 8. Pre-mix Topping Compound 9. Laminating Compound . Kaiser Gypsum's separate responses to interrogatory subparts (a)-(f) for each of these-products are as follows: 1. Joint Cement/Joint Compound (a)---The trade name of this product originally was Kaiser Joint Cement; about 1957 it was changed to Kaiser Joint Compound. (b) Kaiser Gypsum marketed Kaiser Joint Cement in 1952, but did not manufacture the product itself. Kaiser Gypsum does not know whether the product marketed in 1952 contained asbestos as a s ) 1 component. Kaiser Gypsum began manufacturing Kaiser Joint Cement 2 in 1953, at which time chrysotile asbestos was,used as a 3 component. 4 (c) Kaiser Gypsum last manufactured Kaiser Joint Compound 5 with chrysotile asbestos as a component in 1975. 6 (d) The Kaiser Gypsum California plants that made this 7 product were located at Redwood City and Antioch. These plants' 8 were in operation at different times. The product was 9 manufactured at Redwood City from 1953 through 1957 and at Antioch 10 from 1957 to 1975. -Because of the heavy weight of the product, 11 low profit margin and high transportation costs, distribution 12 tended to center around the location of the manufacturing plant. 13 The product consisted primarily of minerals including casein or 14 polyvinyl, clay, talc, limestone and mica. The product 15 manufactured in Kaiser Gypsum's California plants included between 16 8% by weight and 16% by weight chrysotile asbestos as a component 17 depending on, the formula in effect at a given date. 18 (e) This product was a white to off-white powder. It was 19 packaged and sold in sacks or 10 to 25 lbs. and in boxes of 5 and 20 18 lbs. Each container was labeled with the name of the 21 manufacturer, Kaiser Gypsum Company, Inc., the name of the product 22 and directions for its use. 23 (f) This product was a dry powder which, when mixed with 24 water, formed a. thick paste. Upon application it dried to a hard, 25 durable surface. It was used to fill gypsum wallboard joints, 26 embed joint reinforcing tape, finish joints and to cover and 27 finish nail heads and metal cornerbead. 28 1; 2. Finishing (Topping) Compound 2 (a) The trade name of this product was Kaiser Gypsum 3 Finishing (topping) Compound. 4 (b) Kaiser Gypsum began manufacturing finishing (topping) 5 compound in 1955, and chrysotile asbestos was used as a component 6 at that time. I 7l (c) Kaiser Gypsum last manufactured finishing (topping) ' 8 compound with chrysotile asbestos as a component in 1975. 9j (d) The Kaiser Gypsum California plants that made this 10' product were located at Redwood City and Antioch. These plants 11 were in operation at different times. The product was 12: manufactured at Redwood City from 1955 to 1957 and at the Antioch 13 plant from 1957 to 1975. Because of the heavy weight of the 14 product, low profit margin and high transportation costs, 15 distribution tended.to center around the location of the 16: manufacturing plant. This product consisted primarily of minerals 17 including casein or polyvinyl, clay, talc, limestone and mica. 18 The product included between 5.3% by weight and 16% by weight 19 chrysotile asbestos as a compcfnent depending on the formula in 20 effect at a given time. 21 (,e) This product was a white to off-white powder. It was 22! packaged and sold in sacks of 25 lbs. Each container was labeled t 23 with the name of the manufacturer, Kaiser Gypsum Company, Inc., 24 the name of the product and instructions for its use, 25 (f) This product was a dry powder which, when mixed with 26 water, formed a thick paste. Upon application it dried to a hard, 27 durable surface. It was used to top and finish gypsum wallboard 28 joints. ' 1 3. 3-Purpose Wallboard Compound 2 (a) The trade name of this product was Kaiser Gypsum 33 Purpose Wallboard Compound. 4 (b) Kaiser Gypsum began manufacturing 3-Purpose Wallboard 5 Compound in 1968, and chrysotile asbestos was used as a component 6 at that time. 7 (c) Kaiser Gypsum last manufactured 3-Purpose Wallboard 8 Compound with chrysotile asbestos as a component in 1976. 9 (d) The Kaiser Gypsum California plant that made this 10 product was located at Antioch. Because of the heavy weight of 11 the product, low profit margin and high transportation costs, 12 distribution tended to center around the location of the ' 13 manufacturing plant. This product consisted primarily of minerals 14 including casein or polyvinyl, clay, talc, limestone and mica. 15 The product included between 5.1% by weight and 14.2% by weight 16 chrysotile asbestos as a component. 17 (e) The product was a white to off-white powder. It was 18 packaged and sold in sacks of 25 lbs. Each sack was labeled with A. ,, 19 the name of the manufacturer, Kais'er Gypsum Company, Inc., the 20 name of the product and directions for its use. 21 (f) This product was a dry powder which, when mixed with 22 water, formed a thick paste. Upon application it dried to a hard, 23 durable surface. It was used to tape, top and finish gypsum 24 wallboard--joints, nailheads and metal cornerbead. 25 4. One-Day Joint. Compound 26 (a) The trade name of this product was Kaiser Gypsum One-Day 27 Joint Compound Powder. 28 1 (b) Kaiser Gypsum began'manufacturing One Day Joint Compound Powder in 1968, and chrysotile `asbestos was used as a component at that time. 4 (c) Kaiser Gypsum last manufactured One Day Joint Compound 5 Powder with chrysotile asbestos as a component in 1975. 6 (d) The Kaiser Gypsum California plants that made this 7 product were located at Santa Ana and Antioch. Because of the ' 8 heavy weight of the product, low profit margin and high 9 transportation costs, distribution tended to center around the 10 location of the manufacturing plant- The product consisted 11 primarily of casein limestone and mica. The product included 12 3.4% by weight chrysotile asbestos as a component. 13 . (e) This product was a white to off-white powder. It was 14 packaged and sold in sacks of 25 lbs. Each sack was labeled with 15 the name of the manufacturer, Kaiser Gypsum Company, Inc., the 16 name of the product and directions for its use. 17 (f) Thi<s product was a dry powder which, when mixed with 18 water, formed a thick paste. Upon application it dried to a hard, 19 durable surface. It was used'to fill gypsum wallboard joints, 20 embed joint reinforcing tape, finish joints and to cover and 21 finish nailhead and metal cornerbead. 22 5. Pre-Mix Joint Compound 23 (a) The trade name of this product was Kaiser Gypsum Pre-Mix 24 Joint Compound. * 25 (b) Kaiser Gypsum began manufacturing Pre-Mix Joint Compound 26 in 1959, and chrysotile asbestos was used as a component at that 27 time. 28 1 (c) Kaiser Gypsum last manufactured Pre-Mix Joint Compound 2 with chrysotile asbestos as a component in 1962. 3 (d) The Kaiser Gypsum California plant that made this 4 product was located at Long Beach. Because of the heavy weight of 5 the.product, low profit margin and high transportation cost, 6 distribution tended to center around the location of the 7 manufacturing plant. This product consisted primarily of minerals 8 including casein or polyvinyl, clay, talc,-limestone and mica. 9 The product included chrysotile asbestos as a component. The 10 percentage presently is unknown. Investigation is continuing. 11 (e) This product was a white to off-white colored paste. Ic 12 was packaged and sold in cans of 4 or 5 gallons and in cartons of 13 5 gallons. Each container was labeled with the name of the 14 manufacturer, Kaiser Gypsum Company, Inc.,:the name of the produce 15 and directions for its use. 16 (f) This product was a thick paste like material which upon 17 application .dried to a hard, durable surface. It was used to fill 13 gypsum wallbcard joints, embed joint reinforcing tape, finish Jr. 19 joints and to cover and finish nailheads and cornerbead. 20 6. Pre-Mix Finishing Compound .. 21 (a) The trade name of this product was Kaiser Gypsum Pre-Mix 22 Finishing Compound. 23 {b) Kaiser Gypsum began manufacturing Pre-Mix Finishing 24 Compound-inr 195-9, and chrysotile asbestos was used as a component 25 at that time. 26 (c) Kaiser Gypsum last manufactured Pre-Mix Finishing 27 Compound with chrysotile asbestos as a component in 1962. 28 II (d) The Kaiser Gypsum California plant that made this 2 product was located at Long Beach. Because .of the heavy weight' of 3 the product, low profit margin and high transportation cost, 4 distribution tended to center around the location of the 5 manufacturing plant. This product consisted primarily of minerals 6 including casein or polyvinyl, clay, talc, limestone and mica. 7 The product included chrysotile asbestos as a component. The ' 8 percentage presently is unknown. InvestigattSh is continuing. 9 (e) This product was a white to off-white colored paste. It 10 was packaged and sold in cans of 4 or 5 gallons and in cartons of 11 5 gallons. Each container was labeled with the name of the 12 manufacturer, Kaiser Gypsum Company, Inc., the name of the product 13 and directions for its use. 14 (f) This product was a thick paste like material which upon ' 15 application dried to a hard, durable surface. It was used to 16 finish gypsum wallboard joints and to cover and finish nailheads 17 and cornerbead. 18 7. Pre-Mia: Dual Purpose Joint Compound 19 (a) The trade name of "`this product was Kaiser Gypsum Pre-Mix 20 Dual Purpose Joint Compound. 21 (b) Kaiser Gypsum began manufacturing Pre-Mix Dual Purpose 22 Joint Compound in 1960, and chrysotile asbestos was used as a 23 component at that time. 24 (c) _ Kaiser Gypsum last manufactured Pre-Mix Dual Purpose 25 Joint Compound with chrysotile asbestos as a component in 1975. 26 ' (d) The Kaiser Gypsum California plants that made this 27 product were located at Long Beach, Antioch and Santa Ana. 28 Because of the heavy weight of the product, low profit margin and 1 high transportation costs, distribution tended to center around 2 the location of the manufacturing plant. This product consisted 3 primarily of minerals including polyvinyl, clay, talc, limestone 4 and mica. The product included between 1.5% by weight and 6% by 5 weight chrysotile asbestos as a component depending on the formula 6 in effect at a given date. 7 (e) This product was a white to off-white or light buff ' 8 colored paste. It was packaged and sold in 5 gallon metal cans or 9 plastic pails, and 4 or 5 gallon cartons. Beginning in 1966 small 10 amounts were sold in 5 quart plastic buckets as an accommodation 11 product for lumber dealers under the name 3-purpose premix 12 compound. Each container was labeled with the name of the 13 manufacturer, Kaiser Gypsum Company, Inc., the name of the product 14 and directions for its use. 15 (f) This product was a thick paste like material which upon 16 application dried to a hard, durable surface. It was used to 17 finish gypsum wallboard joints, embed joint reinforcing tape, 19 finish joints and to cover and finish nailheads and metal 19 cornerbead. * 20j 8. Pre-Mix Topping Compound 2l! / (a) The trade name of this product was Kaiser Gypsum Pre-Mix 22 Topping Compound. 23 (b) Kaiser Gypsum began manufacturing Pre-Mix Topping 24 Compound in 1968, and chrysotile asbestos was used as a component 25 at that time'. 26 (c) Kaiser Gypsum last manufactured Pre-Mix Topping Compound 27 with chrysotile asbestos- as a component in 1976. 28 (d) The Kaiser Gypsum California plants that made this product were located at Santa Aha and Antioch. Because of the heavy weight of the product, low profit margin and high transportation costs, distribution tended to center around the location of the manufacturing plant. This product consisted primarily of minerals including casein or polyvinyl, clay, talc, limestone and mica. The product included between 0.9% by weight and 2% by weight chrysotile asbestos as a component depending on the formula in effect at a- given date. (e) This product was a white to off-white or light buff colored paste. It was packaged and sold in metal and plastic buckets of 4 or 5 gallons and in cartons of 4 gallons*.* Each container was labeled with the name of the manufacturer, Kaiser Gypsum Company, Inc., the name of the product and directions for its use. (f) This product was a thick paste like material which upon application dried to a hard, durable surface. It was used to top and finish gypsum wallboara joints. 9. Laminating CompourieL (a) The trade name of this product was Kaiser Gypsum Laminating Compound. (b) Kaiser Gypsum began manufacturing Laminating Compound in 1961, at which time chrysotile asbestos was used as a component. (c) ...Kaiser Gypsum last manufactured Kaiser Gypsum Laminating Compound with chrysotile asbestos as a component in 1972, at which time the product was discontinued. (d) The Kaiser Gypsum California plants that made this product were located at Antioch and Santa Ana. These plants were in operation at different times. The product was manufactured at Antioch from 1961 through 1970 and at Santa Ana in 1971 and 1972. Because of the heavy weight of the product, low profit margin and high transportation costs, distribution tended to center around the location of the manufacturing plant. The product consisted primarily of soya, flour and limestone. The product included between 6.5% by weight and 10% by weight chrysotile asbestos as a component depending upon the formula in effect at a given date. (e) This product was a white to off-white powder. It was packaged and sold in sacks of 25 lbs. Each container was labeled with the name of the manufacturer, Kaiser Gypsum Company, Inc., the name of the product and directions for its use. (f) This product was a dry powder, which when mixed with water formed a thick paste. It was used 'as an adhesive to ' laminate one piece of gypsum wallboard to another, which was occasionally done to create gypsum drywall partitions having thicker wallboard than could be created by a single sheet. For example, gypsum wallboard typically came in sheets 1/2 inch and 5/8 inch thick. If one wanted a gypsum wallboard that was 1 inch thick, this would be created by laminating together two pieces of gypsum wallboard that were each 1/2 inch thick. Laminating compound was used for this purpose. Additionally, it was used to laminate gypsum wallboard to sound deadening board, which would increase the wall's capacity to prevent transmission of sound from one room to another. * fc ie 1 Kaiser Gypsum's responses to interrogatory subparts (g)-(j) 2 applicable to all of the eight Wallboard joint compound products 3 discussed above are as follows: 4 (g) Kaiser Gypsum is unsure as to the intended meaning of 5 "The U.S. Government's 'Qualified Products List'," but has no 6 knowledge that any of its wallboard joint compound products ever 7 appeared on such a list. ' 8 (h) Kaiser Gypsum is aware of the following suppliers of 9 chrysoti'le asbestos: 10 11 12 13 14 15 16 John K. 3ice ' Harrison & Crosfield Carmonia Chemical Co. Western Chemical Co. Philip Carey Corp. (Carey Canadian Asbestos) Johns-Manville Union Carbide Corp. .. E. S. Browning Loomis Chemical Co. Benson Chemical Paul W. Wood (Johns-Manville) . 17 Current 'addresses, if any, are nor known to Kaiser Gypsum. 18 Most of the specific time periods during which these firms 19 supplied asbestos are unknown. ' 20 (i) (i through iii) Kaiser Gypsum is- not aware of ever selli 21 such products to shipyards, power companies or refineries. Kaiser 22 Gypsum sold such products to non-governmental customers in Norther 23 California from approximately 1952 to 1976. These customers consis 24 largely of building contractors or building materials dealers. 25 Kaiser Gypsum has some retained sales orders and sales 26 invoices for some years which identify the purchasers of Kaiser 27 Gypsum products, the dates of sale, the amount of each product 28 sold and, in some cases, the sites to which the products were to 1 be delivered. These documents do not distinguish between sales of 2 asbestos-containing products and other products. 3 (j) Sales orders and sales invoices. See also Response to 4 Interrogatory 6(b). 5 C. Decorative Texture Finishes For Interior Walls 6 ' or Ceilings - Asbestos Used As A Component 7 Drywall partitions or walls made from gypsum wallboard are- 8 sometimes decorated with wall covering or wallpaper that is fixed 9 to the wall by an adhesive or glue. On other occasions such walls 10 are finished by painting them. There are many varieties of paint, 11 including some that are intended to create a textured surface (rather than a smooth surface). Kaiser Gypsum manufactured and 12 marketed several texture paint products that during certain years 13 used chrysotile asbestos as one of numerous components. Drywall 14 ceilings are sometimes finished with decorative products, as are 15 the cement slab ceilings found in some high-rise buildings. 16 Kaiser Gypsum also manufactured and marketed decorative texture 17 products for use on such interior ceilings that, during certain 18 years, used chrysotile asbestos as one of numerous components. 19 The Kaiser Gypsum decorative wall and ceiling texture products 20 were: 21 1. Cover-Tex texture paint 22 2. Spray-Tex or Spray Cover-Tex texture paint 23 3. Kaiser-Tex texture paint 4. Covertex (TSS) wall texture 24 5; K-Spray ceiling texture 25 Kaiser Gypsum's responses to interrogatory subparts (a)-(f) 26 for each of these products are as follows: 27 28 1 1. Cover-Tea: Texture Paint 2 (a) The trade name of this product was Cover-Tex texture 3 paint. 4 (b) Kaiser Gypsum marketed Cover-Tex texture paint in 1952, 5 but it did not manufacture the product itself. Kaiser Gypsum does 6 not know whether the product marketed in 1952 contained asbestos. 7 Kaiser Gypsum began manufacturing this product in 1953, at which 8 time chrysot'ile asbestos was used as a component. 9 (c) Kaiser Gypsum last manufactured Cover-Tex texture paint 10 with chrysotile. asbestos as a component in 1967, when the product 11 was discontinued. 12 (d) The Kaiser Gypsum California plants that made this 13 product were located in Redwood City and Antioch. These plants 14 were in operation at different times. The product was 15 manufactured at Redwood City from 1953 through 1957 and at the 16 Antioch plant from 1957 through 1967. Because of the heavy weight 17 of rhe product, low profit margin and high transportation costs, distribution tended to center around the location of. the manufacturing plant. The prSduct consisted primarily of casein, limestone" and mica. The product included between 4.4% by weight and 8.6% by weight chrysotile asbestos as a component depending upon the formula in effect at a given date. (e) This product was a white to off-white powder. It was packaged and sold in sacks of 25 lbs. and sacks of- 50 lbs. Each container was. labeled with the name of the manufacturer, Kaiser Gypsum Company, Inc., the name of the product and directions for its use. 1 (f) This product was a dry powder which, when mixed with 2 water formed a texture paint. -It was used to produce texture 3 effects over gypsum wallboard surfaces. 4 2. Spray-Tex Or Spray Cover-Tex Texture Paint 5 (a) The trade name of this product was Spray-Tex. Later it 6 was changed to Spray Cover-Tex texture paint. ' 7 (b) Kaiser Gypsum began manufacturing this product in 1956, 8 at which time chrysotile asbestos was used as a component.- 9 (c) Kaiser Gypsum last manufactured Spray Cover-Tex texture 10 paint with chrysotile asbestos as a component in 1967, when the 11 product was discontinued. 12 . (d) The Kaiser Gypsum California planrs that made this 13 product were located in Redwood City and Antioch. These plants 14 were in operation at different times. The product was 15 manufactured at Redwood City from 1956 through 1957 and at the IS Antioch plant from 1957 through 1967. Because of the heavy weight 17 of the product, low profit margin and high transportation costs, distribution tended to center around the location of the manufacturing plant. The product consisted primarily of casein, limestone and mica. The product included between 6.6% by weight and 36.6% by weight chrysotile asbestos as a component depending upon the formula in effect at a given date. (e) This product was a white to off-white powder. However, some colored versions of the product were offered. It was packaged and sold in sacks of 25 lbs. and sacks of 50 lbs. Each container was labeled with the name of the manufacturer, Kaiser Gypsum Company, Inc. The name of the manufacturer, Kaiser Gypsum Company, Inc., the name of the product and directions for its use. \ i l1l (f) This product was a dry powder which, when mixed with 2 water formed a texture paint that was used to produce texture i effects over gypsum wallboard surfaces. 4 3. Kaiser-Tea: Texture Paint 5 (a) The trade name of this product was Kaiser-Tex texture 6] paint. 7 (b) Kaiser Gypsum marketed Kaiser-Tex texture paint in 1952, 8 but it did hot manufacture the product itself. Kaiser Gypsum does 91 not know whether the product manufactured in 1952 contained 10 asbestos. -Kaiser Gypsum began manufacturing this product in 1953, llj at which time chrysotile asbestos was used as a component. 12 (c) Kaiser Gypsum last manufactured Kaiser-Tex texture . 13 paint with chrysotile asbestos as a component in 1967, when the 14 product was discontinued. ' 15l (d) The Kaiser Gypsum California plants that made this 16 product were located in Redwood City and Antioch. These plants 17 were in operation at different times. The product was 18 manufactured at Redwood City from 1953 through 1957 and at the 19! Antioch plant from 1957 through 1967. Because of the heavy weight 20 of the product, low profit margin and high transportation costs, 2l| distribution tended to center around the location of the 22 manufacturing plant. The product consisted primarily of casein, 23 limestone and mica. The product included between 4.0% by weight 24 and 8.0% by weight chrysotile asbestos as a component depending 25 upon the formula in effect at a given date. 26j (e) This product was a white to off-white powder; however, 27 some colored paints were sold. It was packaged and sold in sacks 28 of 10 lbs. and sacks of 25 lbs. Each container was labeled with 1 the name of the manufacturer, Kaiser Gypsum Company, Inc., the 2 name of the product and directions for its use. 3 (f) This product was a dry powder which, when mixed with 4 water formed a texture paint. It was used to produce texture 5 effects over gypsum wallboard surfaces. 6 4. Cover-Tea: (Tss) Wall Texture 1 (a) The trade name of this product was Kaiser Gypsum Cover 8 Tex (TSS) wall texture paint. . 9 (b) Kaiser Gypsum began manufacturing Cover-Tex Wall Texture 10 in 1968, at which time chrysotile asbestos was used as a 11 component. 12 (c) Kaiser Gypsum last manufactured Cover-Tex Wall Texture 13 with chrysotile asbestos as a component in 1975. 14 (d) The Kaiser Gypsum California plants that manufactured 15 this product were Santa Ana and Antioch. These plants were in 16 operation at different times. The product was manufactured at 17 Santa Ana from 1968 through 1975 and at the Antioch plant from 13 1963 through 1975.- Because of the heavy weight of the product, 19 low profit margin and high transportation costs, distribution 20 tended to center around the location of the manufacturing plant. 21 The product consisted primarily of casein, limestone and mica. 22 The product included between 4.2% by weight and 8.7% by weight 4 23 chrysotile asbestos as a component depending upon the formula in 24 effect at a given date. 25 (e) The product was a white to off-white powder. It was 26 packaged and sold in 50 lb. sacks. Each container was labeled 27 with the name of the manufacturer, Kaiser Gypsum Company, Inc., 28 the name of the product and directions for its use. <) II (f) This was a dry powder which when mixed with water formed 2 a paint-like product designed for hand or spray, application. When 3 dry, it produced a hard, durable surface. It was used to produce 4 texture effects over gypsum wallboard surfaces. 5 - 5- K-Spray Ceiling Texture 6 (a) The trade name of this product was Kaiser Gypsum KvSpray 7 Ceiling Texture. 8 (b) Kaiser Gypsum began manufacturing K-Spray Ceiling 9 Texture with chrysotile asbestos as a component in'1961. 10 (c) Kaiser Gypsum last manufactured K-Spray Ceiling Texture 11* with chrysotile asbestos as a component in 1975. 12 (d) The Kaiser Gypsum California plants that manufactured 13 this product were Santa Ana and Antioch. These plants were in ' 14 operation at different times. The product was manufactured at 15 Santa Ana from 1973 through 1975 and at the Antioch plant from 16 1961 through 1971. Because of the heavy weight of the product, 17 low profit margin and high transportation costs, distribution 18 tended to center around the location of the manufacturing plant. A 19 The product consisted primarily of casein, limestone and mica. 20 The product included between 1.3% by weight and 9.9% by weight 21 chrysotile asbestos as a component depending upon the formula in 22 effect at a given date. 23 (e) The product was a white powder with polystyrene 24 aggregate-.- rlt was packaged and sold in 32 lb. sacks. Each 'i 25 container was labeled with the name of the manufacturer, Kaiser 26 Gypsum Company, Inc., the name of the product and directions for 27 its use. 1 (f) This was a dry powder which when mixed with water formed 2 a paint-like product designed for spray application. When dry, it 3 produced a hard, durable surface. It was used to produce texture 4 effects over gypsum wallboard or interior concrete ceilings. 5 k -k 1e 6 Kaiser Gypsum's responses to interrogatory subparts (g)-(j) 7 applicable to all of the five decorative texture products 8 discussed above are as follows: 9 (g) Kaiser Gypsum is unsure as to the intended meaning of 10 "The U.S. Government's 'Qualified Products List'," but has no 11 knowledge that any of its decorative texture products ever 12 appeared on such a list. 13 _ (h) Kaiser Gypsum is aware of the following suppliers of 14 chrysotile asbestos: 15 John K. Bice 16 Harrison & Crcsfield Carmonia Chemical Co. 17 Western Chemical Co. Philip Carey Corp. {Carey Canadian Asbestos) 18 Johns-Manville .' 19 Union Carbide Corp."` E. S. Browning 20 Loomis Chemical Co. Benson Chemical 21 Paul W. Wood (Johns-Manville) 22 ., Current addresses, if any, are not known to Kaiser Gypsum. 23 Most of the specific time periods during which these firms 24 supplied'asbestos are unknown. 25 (i) (i through iii) Kaiser Gypsum is not aware of ever 26 selling such products to shipyards, power companies or refineries. 27 Kaiser Gypsum sold such products to non-governmental customers in 28 Northern California from approximately 1952 to 1975. These *-- 1 customers consisted largely of building contractors or building 2 materials dealers. - 3 Kaiser Gypsum, has some retained sales orders and sales 4 invoices for some years which identify the purchasers of Kaiser 5 Gypsum products, the dates of sale, the amount of each product 6' sold, and, in some cases, the sites to which the products were to 7 be delivered. These documents do not distinguish between sales of 8 asbestos-containing products and other products. 9 (j) Sales orders and sales invoices. See also Response to 10 Interrogatory 6(b). 11 D. Electric Radiant Heat System Finishing 12 Products - Asbestos Used As A Component 13 In areas where electricity was expected to be particularly 14 inexpensive, some houses and apartments were constructed with 15 electric radiant heating systems. In some such radiant heating 16 systems, grooves were cut in gypsum wallboard ceilings and 17 electrical hearing cables secured in the grooves. The groove18 cracks were then filled and the ceiling covered with a decorative 19 finish. In other systems, electric heating wires were stapled to 20 the surface of wallboard. Then the ceiling was covered with a 21 thick decorative finish that would conceal the heating wires. 22 Kaiser Gypsum made several products for finishing such systems, 23 and these products used chrysotile asbestos as one of numerous 24 components. These Kaiser Gypsum products were: 25 1. Filler Compound 2. Radiant Heat Compound 26 3. Radiant Heat Scrimless Surfacing Compound 27 Kaiser Gypsum's responses to interrogatory subparts (a)-(f) 28 for each of these products are as follows: 1 1. Filler Compound 2 (a) The trade name of this product was Kaiser Gypsum Filler 3 Compound. 4 (b) Kaiser Gypsum began manufacturing Filler Compound in 5 1961, at which time chrysotile asbestos was used as a component. 6 (c) Kaiser Gypsum last manufactured Filler Compound with 7 chrysotile asbestos as a component in 1972, when the product was- 8 discontinued. 9 (d) The Kaiser Gypsum California plant that made this 10 product was located at Antioch. It manufactured Filler Compound 11 from 1961 to 1970. Because of the heavy weight of the product, 12 the low profit margin and high transportation costs, distribution 13 tended to center around the location of the manufacturing plant. 14 The product consisted primarily of minerals including limestone- 15 and mica. The product used chrysotile asbestos as a component in 16 irs formula but the amount of asbestos called for in the formula 17 used to manufacture the product at the Antioch plant is uncertain. 18 Investigation is continuing. , 19 (e) This product was a -white to off-white powder. It was packaged and sold in sacks of 50 lbs. Each container was labeled with contained the name of the manufacturer, Kaiser Gypsum Company, Inc., the name of the product and directions for its use. (f) This product was a dry powder, which when mixed with water formed a thick paste. Upon application it dried to a hard, durable surface. It was used to cover radiant heating system ceiling surfaces. 2. Radiant Heat Compoond (a) The trade name of this product was .Kaiser Gypsum Radiant Heat Compound. (b) Kaiser Gypsum began manufacturing this product in 1968, at which time chrysotile asbestos was used as a component. (c) Kaiser Gypsum last manufactured Radiant Heat Compound with chrysotile asbestos as a component in 1974, when the product was discontinued. = (d) The Kaiser Gypsum California plant that made this product was located in Santa'Ana, where it was manufactured from 1968 through 1974. Because of the heavy weight of the product, the low profit margin and high transportation costs, distribution tended to center around the location of the manufacturing plant. The product consisted primarily of sand and; white portland cement. The product included between 3.3% by weight and 3.6 by weight chrysotile asbestos as a component. . (e) This product was a white to off-white powder. It was packaged and sold in sacks of 60 lbs. Each container was labeled with the name of the manufacturer, Kaiser Gypsum Company, Inc., the name of the product and directions for its use. (f) This product was a dry powder, which when mixed with water formed a thick paste that was used to cover radiant heating cables stapled to ceiling surfaces. 3. ,...Radiant Heat Scrimless Surfacing Compound (a) The trade name of this product was Kaiser Gypsum Radiant Heat Scrimless Surfacing Compound. 1 (b) Kaiser Gypsum began manufacturing this product in 2 California in 1972, at which time chrysotile asbestos was used as 3 a component. . 4 (c) Kaiser Gypsum last manufactured Radiant Heat Scrimless 5 Surfacing Compound with chrysotile asbestos as a component in 6 1974, when the product was discontinued. 7 (d) The Kaiser Gypsum California plant that made this ' 8 product was located in Santa Ana, where it was'manufactured from 9 1972. Because of the heavy weight of the product,- the low profit 10 margin and high transportation costs, distribution tended to 11 center around the location of the manufacturing plant. The 12 product consisted primarily of sand, silica flour and mica. The 13 product included 5% by weight chrysotile asbestos as a component. 14 (e) This product was a greenish powder. It was packaged and 15 sold in sacks of 25 lbs. and in sacks of 50 lbs. Each container 16 was labeled with the name of the manufacturer, Kaiser Gypsum 17 Company, Inc.., the name of the product and directions for its use. 18 (f) This product was a dry powder, which when mixed with 19 water formed a thick paste tfiat was used to cover radiant heating 20 cables embedded in ceiling surfaces. 21 * * * 22 Kaiser Gypsum's responses to interrogatory subparts (g)-(j) 23 applicable to all of the three radiant heating system surfacing 24 products discussed above are as follows: 25 (g) Kaiser Gypsum is unsure as to the intended meaning of 26 "The U.S. Government's 'Qualified Products List'," but has no 27 knowledge that any of its radiant heating system surfacing 28 products ever appeared on such a list. V 1 (h) Kaiser Gypsum is aware of the following suppliers of 2 asbestos: 3 John K. Bice Harrison & Crosfield 4 Carmonia Chemical Co. Western Chemical Co. 5 . Philip Carey Corp. (Carey Canadian Asbestos) 6 Johns-Manville Onion Carbide Corp. 7 E. S. Browning Loomis Chemical Co. 8 Benson Chemical 9 Paul W. Wood (Johns-Manville) ' 10 Current addresses, if any, are not known to Kaiser Gypsum. 11 Most of the specific time periods during which these firms 12 supplied asbestos are unknown. 13 (i) (i through iii) Kaiser Gypsum is not aware of ever 14 selling such products to shipyards, power companies or refineries. 15 Kaiser Gypsum sold such products to non-governmental customers in 16 Northern California from approximately 1952 to 1976. These 17 customers consisted largely of building contractors or building 18 materials dealers. . Kaiser Gypsum has some retained sales orders and sales 19 invoices for some years which identify the purchasers of Kaiser 20 Gypsum products, the dates of sale, the amount of each product 21 sold, and, in some cases, the sites to which the products were to 22 be 'delivered. These documents do not distinguish between sales of 23 asbestos-containing products and other products. 24 (j) Sales orders and sales invoices. See also Response 25 26 Interrogatory 6(b). 27 E. Gypsum Wallboard Accessories For 28 Exterior Pse - Asbestos Used As A Component 1 Kaiser Gypsum experimented with gypsum wallboard products for 2 use on the exrerior surfaces of' buildings, but those products 3 proved unsuccessful. Kaiser Gypsum never discovered a way for 4 them to be manufactured that would allow them to effectively 5 withstand the wide variety of weather and temperature conditions 6 that exterior products confront. Those exterior gypsum products 7 were marketed in several test areas and, as in the case of ' 8 interior gypsum drywall products, required the use of materials 9 to fill the spaces between pieces of gypsum wallboard and to 10 provide a decorative finish. Kaiser Gypsum offered products for 11 those purposes whose components included small percentages of 12 chrysotile asbestos. These products were: 13 . 14 1. X-Terior Premix Prefill Compound 2. X-Terior Premix Wall Texture Compound 15 Kaiser Gypsum's responses to interrogatory subparts (a)-(f) 16 for each of these products are as follows: 17! 1. X-Terior Premia: grefill Compound 181 (a) The trade name of this product was Kaiser Gypsum X- 19 Terior Premix Prafill Compound. 20 (b) & (c) Kaiser Gypsum began and ceased marketing this 21 product during 1975. Chrysotile asbestos was used as a component 22 for the brief period during which this product was manufactured. 23 (d) The Kaiser Gypsum California plant that made this 24 product was located at Antioch. The product was marketed in a 25 limited market area where exterior gypsum wallboard was being sold 26 on a test basis. Kaiser Gypsum X-Terior Premix Prefill Compound 27 was made primarily of raw gypsum, PVA emulsion and mica. The 28 1 product included 1.5% by weight chrysotile asbestos as a 2 component. ' 3 (e) This product was a white to off-white paste. It was 4 packaged and sold in metal cans and plastic buckets of 60 lbs., 5 and in cartons of 48 and 60 lbs. Each container was labeled with 6 the name of the manufacturer, Kaiser Gypsum Company, Inc., the 7 name of the product and directions for its use. 8i (f) This product was a paste that was used to pre-fill 9 joints in gypsum wallboard installed on building exteriors. 10 2. X-Terior Premise Wall Texture Compound 11 \ (a) The trade name of this product was Kaiser Gypsum X- 12 Terior Premix Wall Texture Compound. 13 <b) & (c) Kaiser Gypsum began and ceased marketing this 14 product during 197 5. Chrysotile asbestos-was used as a component 15 for the brief period during which this product was manufactured. 16 (d) The Kaiser Gypsum California plant that made this 17 product was located at Antioch. The product consisted primarily 19 of limestone, acrylic emulsion and mica. The product included IS 1.5% by weight chrysotile asbdstos as a component. (e) The product was a white to off-white paste. It was packaged and sold in 58-lb. metal cans, plastic buckets and cartons. Each container was labeled with the name of the manufacturer, Kaiser Gypsum Company, Inc., the name of the produc and directions for its use. (f) This product was a white to off-white paste that was used to provide surface texture to gypsum wallboard installed on building exteriors. * * * t 1 sold, and, in some cases, the sites to which the products were to be delivered. These documents do not distinguish between sales of asbestos-containing products and other products. (j) Sales orders and sales invoices. See also Response to Interrogatory 6(b). IXX. Products Made At Kaiser Gypsum's Oregon Plant From 1956 to 1978 Kaiser Gypsum owned and operated a plant located at St. Helens, Oregon whose basic capability was to make building construction products by compressing wood fibers 10 extracted from wood chips to make various types of sheets and 11 boards. 12 A. Firteac Products - Wo Asbestos Used . 13 The overwhelming majority of the products Kaiser Gypsum made 14 at its Oregon plant were sold with the trademark "Firtex." No 15 product' sold under this trade name ever used asbestos as a 16 component. Firtex products included various types of materials 17 intended to provide insulation against outside temperatures or to 18 dampen noise. Such products included sheathing that was nailed to 19 walls before outer layers of 'bricks or siding were installed. They 20 also included sheet products for insulating roofs. They also 21 included sound deadening board that was used in partitions to 22 reduce the noise that could be heard from adjacent rooms. 23 Firtex products also included materials intended for use on 24 ceilings. One type was tiles that could be glued or tacked to 25 ceilings to reduce noise. Another group o: such products was used 26 in suspended ceilings. Suspended ceilings are made by hanging a 27 wood or metal frame from the structural members of a ceiling and 28 then laying square or rectangular decorative and insulating pieces 1 into the frame. Those pieces were termed "lay-in boards." Such 2 suspended ceilings used a significant amount of the room's 3 vertical space and because that vertical space cost money to 4 build, suspended ceilings were most commonly found in commercial' 5 buildings or office buildings, which typically had higher ceilings 6 than houses during the 1956-1978 period when Kaiser Gypsum made 7 the products. The Firtex line of products was quite successful, 8 and Kaiser Gypsum sold them in great volume, r:: 9 B. Mineral Fiber Products :- 10 n. 1. Kaiser Gypsum Ordinary And 1-Hour Fire Rated Mineral Fiberboard Products - Mo Asbestos Used 12 As high-rise buildings became more common in California 13 during the 1960's, building code authorities became increasingly 14 concerned about the risks of fires in those buildings and 15 encouraged the development and use of products that were less 16 likely to burn. Since its Firtex wood-chip products would burn, 17 Kaiser Gypsum sought to develop other ceiling tile and lay-in 18 board products that would be more resistant to fire. Kaiser 19 Gypsum found that the manufacturing machinery at its St. Helens, 20 Oregon plant could be used to make ceiling tiles and lay-in boards 21 for suspended ceilings with various types of mineral wool as the 22 principal component (instead of wood chips). Mineral wool is the 23 name given to products made by heating various types of rock to 24 extremely high temperature (where they melt), spinning them into 25 threads, and then letting them cool. Mineral wool looks something 26 like steel wool that is used for rubbing rust off of metal or used 27 in certain kitchen scouring pads. Mineral wool does resist fire 28 and Kaiser Gypsum was successful in developing ceiling tiles and W.' w 1 Mineral Fibreboard - U.L. Fire Rated (Underwriters1 Laboratories., Inc. Design) (a) The trade name of this product, a mineral fiber product, was'Kaiser Mineral Fibreboard - U.L. Fire Rated (Underwriters' 5 Laboratories, Inc. Design). The same product'was cut into ceiling 6 tiles and lay-in boards for use in suspended ceilings., It was 7 used for acoustical ceiling tile and suspended lay-in board in 8 circumstances where a 2-hour fire resistance classification was 9 specified. Both the ceiling, tiles and the lay-in boards were sold under the trade name "Kaiser Mineral Fibreboard-UL Fire Rated 10 (Underwriters' Laboratories, Inc. design)." 11 (b) Kaiser Gypsum began manufacturing Mineral Fibreboard12 U.L. Fire Rated with chrysotile asbestos as a component in 1963. 13 (c) Kaiser Gypsum last manufactured Mineral Fibreboard-U.L. 14 Fire Rated with chrysotile asbestos as a component in 1974, when 15 the 2-hour fire-rated product was discontinued. 16 (d) The plant that made this product was located at St. 17 Helens, Oregon. This product included 1.6% by weight chrysotile 18 asbestos as a component. 19 a (e) This product consisted of ceiling tiles and lay-in 20 boards 21 with face side white or colored and wich perforated or fissured design for acoustical treatment. The tiles were 1/2" or 22 5/8`' by 12" by 12" and. the lay-in boards came in two sizes: 1/2" 23 or 5/8" by 24" by 24" and 1/2" or 5/8" by 24" by 48." They were 24 packaged'and sold in boxes of various quantities. The boxes 25 contained the name of the manufacturer, Kaiser Gypsum Company, 26 Inc., the name of the product and other printed material. Kaiser 27 Gypsum's 2-hour fire-rated ceiling tiles and suspended ceiling 28 1 lay-in board products (in which chrysotile asbestos was used as a 2 component) were required to be specially marked because they 3 looked similar to other Kaiser Gypsum mineral fiberboard ceiling 4 tiles and lay-in boards (that did not.contain asbestos as a c component) and building inspectors wanted to be able to check to 6 make sure that products with a 2-hour fire resistance . 1 classification actually were being used by the building contractor S when those had been specified. It is believed that 2-hour fire c rated ceiling tile and suspended ceiling lay-in board was stamped 1( on the back with either the initial "KG" or the word "Kaiser 1] Gypsum." It is believed that this marking was employed during the i: entire period that the 2-hour fire-rated products were i: manufactured by Kaiser Gypsum. i` (g) Kaiser Gypsum is unsure as to the intended meaning of 1! "The U.S. Government's 'Qualified Products List'," but has no ll knowledge that any of its 2-hour fire-rated mineral fiberboard v products everappeared on such a list. 1! (h) Kaiser Gypsum is aware of the following suppliers of . l: asbestos: <*. . ` 2i John K. Bice 2 Harrison & Crosfield Carmonia Chemical Co. 2: Western Chemical Co. Philip Carey Corp. (Carey Canadian Asbestos) 2: Johns-Manville ..Union Carbide Corp. E- S. Browning Loomis Chemical Co. Benson Chemical Paul' W. Wood (Johns-Manville) T' 1 Current addresses, if any, are not known to Kaiser Gypsum. 2 Most of the specific time periods during which these firms 3 supplied asbestos are unknown. 4 (i) (i through iii) Kaiser Gypsum is not aware of ever 5 selling such products to shipyards, power companies or refineries. 6 Kaiser Gypsum sold such products to non-governmental customers in 7 California from approximately 1963 to 1974. These customers 8 consisted largely of building contractors or building materials 9 dealers. 10 Kaiser Gypsum has some retained sales orders and sales 11 invoices for some years which identify the purchasers of Kaiser 12 Gypsum products, the dates of sale, the amount of each product 13 sold, and, in some cases, the sites to which the products were to i* _ 14 be delivered. These documents do not distinguish between sales-of 15 asbestos-containing products and other products. 16 (j) Sales orders and sales invoices. See also Response to 17 Interrogatory .6(b). 18 IV. Types Of Products Kaiser Gypsum Never Made And Never Marketed 19 ' Kaiser Gypsum has never mined, milled or marketed asbestos. 20 Kaiser Gypsum never designed, manufactured, or marketed any 21 product in which amosite, crocidolite or other amphibole forms of 22 asbestos was used as a component. Kaiser Gypsum never designed, 23 manufactured, or marketed floor tile, pipe insulation or pipe 24 covering, refractory products, boiler insulation, acoustical 25 plaster, or sprayed fireproofing or sprayed thermal insulation 26 products. Kaiser Gypsum never designed, manufactured or marketed 27 any sort of brake products. It never designed, manufactured or 28 1 marketed paper products, textile products, or roofing products in 2 which asbestos was used as a component. Kaiser Gypsum never 3 designed, manufactured or marketed any products intended for use 4 in ships or shipyards, or any products intended for use in trains 5 or other railroad equipment or railroad facilities. 6 V. 7 Null-A-Fire Type-X Gypsum Wallboard Allegedly Contaminated Venniculite Ore 8 This part of Kaiser Gypsum's response, though not directly 9 called for by the subject interrogatories, is being made in light .0 of earlier versions of Kaiser Gypsum's responses to these .1 interrogatories and evolving knowledge, in the context of .2 historical regulatory uncertainties and disputes about whether vermiculite ore used as a component in some Kaiser Gypsum Null-A .3 Fire Type-X Gypsum Wallboard products may have- been contaminated L4 in a way that caused, certain workers, to be exposed to airborne L5 "asbestos." Kaiser Gypsum's position is that no Kaiser Gypsum L6 Null-A-Fire Type-X Gypsum Wallboard using vermiculice ore as a 11 component: could have been a substantial contributing factor to any disease caused by exposure to airborne asbestos fibers. As background, in 1954 Kaiser Gypsum introduced Nuil-A-Fire brand wallboard, a 5/8" thick gypsum wallboard that was approved by the Research Committee of the Pacific Coast Building Officials Conference and certified by the National Board of Fire Underwriters for a one-hour fire rating. This product was developed in response to the appearance of California building code requirements that walls in several types of public buildings must have such one-hour fire resistance. The term one-hour fire rating meant that, when used as a wall surface, the gypsum v,.:j) s* : ' '^'4. ^ \ \ J 1 wallboard would resist the passage of flame and heat for at least 2| one hour. The certified product'had to be made in accordance with 3 Underwriters Laboratories Code No. 3543. Wallboard products that 4 were fire rated were labeled as "Type X" to distinguish them from 5! ordinary gypsum wallboard products that had not passed fire-rating 6| tests. 7 When introduced in 1954, the primary component of Kaiser 8 Gypsum's Null-A-Fire wallboard was gypsum stucco, which is the 9 gypsum plaster that forms the greatest percentage by 'weighr of all 10! gypsum wallboard. Gypsum plaster, including wallboard scucco, 11 does not burn, and consequently, all gypsum plaster and gypsum 12 drywall construction poses less risk of fire than does wall . 13 construction featuring wood or plastic paneling. However, the 14 ordinary 5/8" gypsum wallboard did not pass the one-hour fire 15 test, because the heat of the test caused the gypsum plaster to 16| shrink and crack, letting the fire through in less than an hour. 17 Kaiser Gypsum, found that by.adding small proportions of glass 18 fiber and perlite a board could be constructed that would resist 19| shrinking and cracking under the heat of the fire test for the 20' required one-hour period. Perlite is a very light substance, 21 white in color, that looks like puffed breakfast cereal. It is 22! often used in soil for potted plants to help keep the soil from 23 caking. Perlite is made by heating little pieces of volcanic 24 glass to.very high temperatures, which causes them to pop like 25 popcorn. 26| Kaiser Gypsum continued to market its Null-A-Fire Type X 27 gypsum wallboard products that contained perlite for more than a 28 decade following -their introduction in 1954. However,, other manufacturers introduced fire-rated wallboard products that used vermiculite instead of perlite to provide added fire protection. Vermiculite is a mica-like mineral found in the ground in a number of places. In the 1890's it was known by gold prospectors as "fool's gold," because it sparkled in the sun like precious metal. Vermiculite does not weigh much, which makes it useful as a component of construction materials and t-he melting point of vermiculite is about 2500 degrees, which makes it valuable as fireproofing. "' Vermiculite consists of many layers of thin plates that have small amounts of water trapped in them. When heated, the water turns to steam causing these plates to expand. Such expanded vermiculite is used by nurseries everywhere to help hold air and moisture in plant soil so that, young plants will grow faster and stronger. Until 1965, Kaiser Gypsum could not use vermiculite to provide fire protection in gypsum wallboard,'because other companies had secured patents from the United States- government which gave them exclusive rights to use vermiculite in their gypsum wallboard products. Ir. 1965, Kaiser Gypsum secured patent licenses from other companies which authorized Kaiser Gypsum to begin with vermiculite in its wallboard products to provide increased protection against fire. Kaiser Gypsum then began to develop such. pall.board products and to present them for fire testing. Since vermiculite expands when it is heated, vermiculite used in a wallboard tends to offset the shrinkage that occurs in gypsum when it is heated, and thus, vermiculite could serve to help a wallboard to hold its shape and provide the desired fire 1 protection. Because the capacity to expand was desired, the 2 Kaiser Gypsum products used as 'the ingredient vermiculite that had 3 not previously been heat-expanded. This unexpanded vermiculite 4 was referred to sometimes as vermiculite ore. When testing and 5 fire code authorities recognized and certified these Kaiser Gypsum 6 products as fire-rated, or qualified to be marketed as "Type X," 7 Kaiser Gypsum began marketing vermiculite-containing gypsum 8 wallboard under its Null-A-fire brand. Kaiser Gypsum manufactured 9 limited quantities of 1/2" Null-A-Fire Type X wallboard beginning 10 in 1967, and began manufacturing 5/8" Null-A-Fire Type X wallboard 11 in 1969. It continued to market such products until it disposed 12 of the last of its gypsum business in April 1978. Like other 13 wallboard products, those Null-A-Fire wallboards consisted 14 primarily of gypsum piaster. The formulas varied over the years 15 but the vermiculite ore percentage did not exceed 4% by weight of 16 the products. 17 Controversy concerning vermiculite reflects the regulatory 18 proposals published and regulations adopted by the U.S. 19 Occupational Safety and Health Administration ("OSHA") and the 20 responses of vermiculite companies to those government actions. 21 OSKA is a U.S government agency, created by federal legislation in 22 1970, that adopts and enforces workplace safety and health 23 regulations. OSHA has been politically controversial from the 24 beginning. California originally established a parallel state 25 program administered by its Division of Occupational Safety and 26 Health, but that agency and program were terminated several years 27 ago. 28 VV:*-;/ 'j \i! The federal OSHA undertook to regulate exposure to "asbestos" 2 in the workplace as one of its first regulatory.undertakings, and 3 OSHA adopted regulations on asbestos in 1972. {See Kaiser 4 Gypsum's response to Interrogatory No. 15, below.) Thereafter, it 5 undertook to enforce those regulations. In due course, it began 6 to threaten manufacturers who used various substances other than 7 asbestos with charges of violating the OSHA asbestos exposure 8 regulations. This triggered a long-lasting legal and scientific 9 dispute concerning what minerals are "asbestos" for purposes of 10 the OSHA regulations and what minerals should be regulated like 11 asbestos even if they are not asbestos. 12 In that context, vermiculite supplier W.R. Grace & Co. 13 (hereinafter "Grace") issued an "Important Notice to Vermiculite 14 Ore Processors," dated March 17, 1976 warning that "employers of' 15 workers handling vermiculite ore" should be "aware of the OSHA 16 regulations," because OSHA. was applying them to Grace vermiculite 17 plants and proposed to make the regulation of dust mere strict 18 under the regulations. Grace stated that the issues related to 19 vermiculite reflected a "trampmineral "found in vermiculite 20 deposits" named "tremolite, defined by OSHA as one of the asbestos 21 family." Disputes over these OSHA proposals persisted for years. 22 Then, on June 20, 1986, OSHA published in the Federal Register (at 23 51 Fed. Reg. 22612) a "Final Rule" that defined "asbestos" to 24 include "tremolite." and applied asbestos exposure limits and 25 warnings to tremolite. However, shortly thereafter those 26 regulations were "stayed," that is, not made effective, by OSHA as 27 to tremolite and several other minerals to prevent the federal 28 courts from deciding whether the regulations were "arbitrary and V ?' J 1 capricious." (See 51 Fed. Reg. 37002; Oct. 17, 1986.) The scientific and regulatory debate continued for more years until OSHA published regulations in 1992 (57 Fed. Reg. 24310; June 8, 1992) declaring that some tremolite is "platy" or non-fibrous, and 5 "platy tremolite" would not be deemed to be asbestos. 6 However, OSHA found other tremolite was fibrous or 7 "asbestiform" and that such "asbestiform tremolite" would be 8 regulated as asbestos. OSHA further limited these.regulations by 9 providing that even products with asbestiform tremolite would not 10 be subject to asbestos regulation if asbestiform tremolite "is 11 present in a product in concentrations less than 1.0 percent by 12 weight." 13 _ Kaiser Gypsum admits that for a limited number of years some 14 of its Null-A-Fire products contained vermiculite, but Kaiser 15 Gypsum denies that these products contained asbestiform tremolite. 16 Kaiser Gypsum further contends that any attempt under state law to 17 deem any products that have less than the amount that would 18 subject them to federal regulation to be asbestos-containing 19 products would be preempted by federal law and the Supremacy 20 Clause of the U.S. Constitution. 21 RESPONSE TO INTERROGATORY HO. 11: 22 Not applicable. 23 RESPONSE TO INTERROGATORY NO. 12: 24 Kaiser. Gypsum is unaware of entering into any such rebranding 25 agreements. : 26 RESPONSE TO INTERROGATORY NO. 13: ' 27 During 1952 Kaiser Gypsum purchased Joint Cement, Cover-Tex 28 texture paint and Kaiser-Tex texture paint from Wesco Waterpaints, i Inc., then located in Berkeley, California, that was packaged in 2 Kaiser Gypsum's name. It is unlcnown to Kaiser.Gypsum whether 3 asbestos was used as a component of those products. During 4! December 1953, after Kaiser Gypsum began manufacturing joint 5 compounds and texture paints, Kaiser Gypsum entered into an 6 agreement with Wesco Waterpaints, Inc., then located in Berkeley, 7 California, to purchase joint cement, topping compound and texture 8 paint packaged in Kaiser Gypsum's name for a^period of 90 days. 9 It is unknown to Kaiser Gypsum whether any purchases"were made 10 pursuant to this agreement or whether any products purchased had 11 asbestos as a component. In an abundance of caution, Kaiser 12 Gypsum is providing the information it has obtained from its 13 records. Kaiser Gypsum has no information demonstrating that any 14 product obtained from Wesco Waterpaints, Inc. was an asbestos- 15 containing product. Kaiser Gypsum knows of no other agreement 16 entered by it that provided for rebranding any product of another 11 company's which may have beer, an asbestos-containing product in , 18 Kaiser Gypsum's name for sale in California. . IS RESPONSE TO INTERROGATORY NO-^14: Kaiser Gypsum did not purchase or acquire asbestos from the "General Service Administration" or any branch or agency of the United States Government. RESPONSE TO INTERROGATORY NO. 15: Yes,..as. .to products marketed in 1972 or thereafter. (a) Beginning in 1972, in response to regulations adopted by the U.S. Occupational Safety and Health Administration (see 37 Fed. Reg. 11318, June 7, 1972), Kaiser Gypsum affixed caution labels to the packages and containers of its asbestos-containing 1 products. The OSHA regulations requiring this label were made 2 subject to the limitation that "no label is required where 3 asbestos fibers have been modified by a bonding agent, coating, 4 binder, or other material so that during any reasonably 5 foreseeable use, handling, storage, disposal, processing, or . 6 transportation, no airborne concentrations of asbestos in excess 7 of the exposure limits prescribed in paragraph (b) of this section 8 will be released." In light of then-existing ambiguities as to 9 what tests OSHA would recognize as adequate to demonstrate a 10 product's falling within this exception, Kaiser Gypsum applied the 11 caution label to all its then-manufactured products in which 12 chrysotile asbestos was used as a component. 13 Initially, the labels were four inches by eight inches in 14 size and had yellow backgrounds with red letters. They were 15 affixed to the bag or container of the product by adhesive in a 16 prominent place. Later, as new bags and containers were ' 17 purchased, the labels were printed onto the side of the bag or 18 container and are believed to have been the same color or colors 19 as the bag/container or the pointing thereon. The label read: 20 CAUTION: contains asbestos fibers; avoid 21 creating dust; breathing asbestos dust may 22 cause serious bodily harm. 23 (b) Beginning in 1972; exact date unknown. 24 (c) _This label caution remained the same during the 25 remaining time the products upon which it was used continued to 26 use asbestos as a component. 27 RESPONSE TO INTERROGATORY NO. 16: 28 Not applicable.  :-',! -. ; X ' '-wy 1 RESPONSE TO IMTERROG&TORY NO. 17: Most of Kaiser Gypsum's products were sold in the form of a powder or paste; therefore, the.name of the company was on the packaging of the product. However, Kaiser Gypsum's 2-hour fire rated ceiling tiles and suspended ceiling lay-in board products (in which asbestos was used as a component were specially marked because they looked similar to other Kaiser Gypsum mineral fiberboard ceiling tiles and lay-in boards (that did not contain 9 asbestos as a component) and building inspectors wanted to be able 10 to check to make sure that 2-hour fire-rated products actually 11 were being used by the building contractor when those had been 12 specified. It is believed that each piece of 2-hour fire-rated 13 ceiling tile and suspended ceiling lay-in board was stamped on the 14 back with either the initial "KG" or the word "Kaiser Gypsum." 15 Such marking was employed during the entire period that the 2-hour 16 fire-rated products were manufactured by Kaiser Gypsum. 17 RESPONSE TO INTERROGATORY NO. 18: - 18 Harlan C. Dupuis, former Manager of Research and Development, 19 was deposed on April 16, 1985, in the following case: Katherine 20 Maksim v. CJ.S. Gypsum, et al., San Francisco County Superior Court 21 No. 768674. 22 Melissa A. Youngman, former Secretary/Treasurer, was deposed 23 on March 4 and 5, 1993, in the following cases: Donald Breslin v. 24 ABEX, et al,,..San. Francisco County Superior Court, Case No. 25 943928; Coy Cossev v. ABEX, et al., San Francisco County Superior 26 Court, Case No. 920148; Norma E. Olsen v. ABEX, et al., San 27 Francisco County Superior Court, Case No. 914076; Lynn Weimer v. 28 ABEX, et al., San Francisco County Superior Court, Case No. t'.'T f 1 914594; and Rav Person v. ABEX, et al., San Francisco County 2 Superior Court, Case No. 944872. 3 Thomas V. Smith, former Technical Supervisor for Accessory 4 Products, was deposed on March 11, 1992, in the following case: 5 Michael F. Richie, et al. v. Raybestos-Manhattan, et al., Superior 6| Court of the State of California for the County of San Francisco, 7 Civ. 933324. 8 RESPONSE TO INTERROGATORY NO. 19: 9 Kaiser Gypsum has no knowledge that it ever purchased or 10 otherwise acquired an asbestos-containing product line from 11 ahother company. 12| RESPONSE TO INTERROGATORY NO. 20: 3.3: Kaiser Gypsum has retained a number of brochures, pamphlets, 14 catalogs and other producr information documents. Many of these 15 documents discuss both asbestos-containing' products and other 16: produces, and many of the documents are similar. For these 17 reasons, rather than attempting to identify each individual 18 document, Kaiser Gypsum will make representative documer.es 19 available for inspection upon^reasonable notice at the offices of 20 Dillingham & Murphy, 225 Bus, 6th Floor, San Francisco, 21 California. 22 (a) through (c) - See statement above. 23 (d) To provide potential users of such products with 24 information about the products. 25 (e) Some of these documents still exist. 26 (f) See above statement. ' l.w.** 27 (g) See Response to Interrogatory No. 6(b). 28 t 1 RESPONSE TO INTERROGATORY NO. 21; 2 Not applicable. ` 3 RESPONSE TO INTERROGATORY NO. 22: 4 No, not to Kaiser Gypsum's knowledge. 5 RESPONSE TO INTERROGATORY NO. 23: 6 The interrogatories define "contract unit" to "mean a branch 7 or division of a defendant which has been or is now engaged in 8 installation and/or removal of 'raw asbestos, fibers * and/or 9 'asbestos-containing products'." Kaiser Gypsum never has had such 10 a unit. 11 RESPONSE TO INTERROGATORY NO. 24: 12 Not applicable. 13 RESPONSE TO INTERROGATORY NO. 25: 14 Kaiser Gypsum had product liability insurance during the 15 period of time it manufactured or sold asbestos-containing 16 products. , 17 18 19 20 21 22 23 24 25 26 27 28 l! F^SPONSE TO IKTEKROGATORY MO. 26: 2 (a)-(d) Kaiser Gypsum is'insured under a number of general 3 corporate liability insurance policies that were issued by primary 4 insurance carriers, including Truck Insurance Exchange, Fireman's 5 Fund, The Home Insurance Company and National Union Insurance 6 Company, which Kaiser Gypsum maintains provide coverage for 7 personal injury claims. Certain policy terms and conditions are 8 subject to disputes between Kaiser Gypsum anctits carriers. 9 Kaiser Gypsum also believes that it is insured under 'a number of 10 excess liability insurance policies that were issued by a number 11 of different insurance carriers, including some that may no longer 12 be capable of responding to their obligations. The terms and . 13 conditions of these excess policies may be subject to dispute. 14 Kaiser Gypsum will supplement this response in the event the 15 circumstances in a particular case may make mere detailed 16 information on insurance policies of relevance, taking into 17 account the carrier and dispute resolution status pertaining at 18 that time. DATE: 19 IL-ho fab -----------1----------; 20 21 22 23 DILLINGHAM & MURPHY Bv: LO* lls.___ PATRICK JT HAGAN, ESQ. E. JANE HELLS, ESQ. Attorneys for Defendant Kaiser Gypsum Company, Inc. 24 25 26 27 28 1 VERIFICATION 2 3 I, the undersigned say: ' 4 5 I have read the foregoing document; to the extent that the information set forth 6! in the foregoing document is personally known to me, die information is true and correct to 7 the best of my knowledge; to the extent that the information set forth in the foregoing 8 document is not known to me but is required by law to be provided in said responses, I believe 9 the responses to be correct; to the extent that the responses state legal objections, the responses 10 have been prepared by my attorneys based on their work product and other information known 11! to them, and are not within my personal knowledge. 12 I declare under penalty of perjury under the laws of the State of California, that 13 the foregoing is true and correct. 14 , Executed this day of . 1996, at San Ramon, California. 15 16 17: Kaiser Gypsum Compaiiy, Inc.'s 18 Updated Responses to Plaintiffs' Standard Interrogatories to 19 Defendants In Re: San Francisco Superior Court 20 Complex Asbestos Litigation 21! i 22 23 24 25 26 27 28 t 1 PROOF OF SERVICE BY MAXI. rC.C.J*.. 1013a. 2015.51 2 I, the undersigned, declare: 3 That I am employed in the City of San Francisco, County 4 5 of San Francisco, State of California; that I am over the age of 6 eighteen years and not a party to the within cause; that my 7 business address is 625 Market Street, Fourteenth Floor, San 8 Francisco, California 94105-3315. 9 That on today's date I served the attached: 10 11 KAISER GYPSUM COMPANY, INC. 'S UPDATED RESPONSES TO PLAINTIFF'S STANDARD INTERROGATORIES TO DEFENDANTS 12 on the parties in said cause, by placing a true copy of each 13 14 document enclosed in a sealed envelope with postage' thereon fully 15 prepaid, in the United States mail at San Francisco, California, 16 addressed as follows: 17 Alan R. Brayton, Esq. 18 Brayton Harley Curtis 19 222 Rush Landing P.Q. Box 2109 20 Novato, CA 96723 21 (see also attached service list) 22 I declare under penalty of perjury under the laws of 23 the State of California that the foregoing is true and correct. 24 25 Dated: December 30, 1996 26 27 Christine Willis 28 i IN RE COMPLEX ASBESTOS LITIGATION PLAINTIFFS' COUNSEL SERVICE LIST Bruce L. Ahnfeldt, Esq., P.O. Box 6078, Napa, CA 94581 . Law Offices of Marc C. Barulich, 1721 Court Street, Redding, CA 96001 Brayton Harley Curtis, 222 Rush Landing, P.O. Box 2019, Novato, CA 94948 Casey, Gerry, Casey, Westbrook, Reed & Schenk, 110 Laurel Street, San Diego, CA 92101, Attn: Frederick Schenk Law Offices of Jack K. Clapper, 62 Princess Street, Sausalito, CA 94965 Law Offices of Frank H. Finney, 2033 North Main Street, Suite 430, Walnut Creek, CA 94596 Law Offices Of Christopher E. Grell, 685 Market Street Suite 540, San Francisco, CA 94105 Visse & Yanez, LLP, One Daniel Burnham Court, Suite 220-C, San Francisco, CA 94109-5460 George W. Kilboume, Esq., 661 Augusta Drive, Moraga, CA 94556 Kenneth L. Knapp, Esq.. 1109 Quail Street, Newport Beach, CA 92660 yv Offices of J. Kenneth Lynch, One Sansome Street, Suite 2100, San Francisco, A 94105 McCarthy. Johnson & Miller, 595 Market Street, Suite 2200, San Francisco, CA 94105 Law Offices of John C. Robinson, 365 Notre Dame Drive, Vallejo, CA 94589 Robles & Gonzales, One Bayfront Plaza, Suite 900,100 S. Biscayne Boulevard, Miami, FL 33131 Steven B. Stein, Esq., One Embarcadero Center, Suite 2112, San Francisco, CA 94111 ` Law Offices of Sterns, Walker & Lods, 100 First Street, Suite 2300, San Francisco, CA 94104 * Wartnick, Chaber, Harowitz, Smith &Tigerman, 101 California Street, Suite 2200, San Francisco, CA 94111 707-224-6547 Fax: 707-224-2518 916-244-0988 415-898-1555 Fax: 415-898-1247 619-238-1811 Fax: 619-544-9232 415-332-4262 Fax: 415-331-5387 510-256-3307 Fax: 510-256-3308 415-541-9866 Fax: 415-541-9869 415-441-1707 Fax: 415-441-0340 510-372-3304' 714-851-1200 415-951-4616 Fax: 415-951-4653 415-882-2992 707-554-2393 Fax: 707-554-2394 305-371-5944 415-543-0152 Fax: 415-626-2185 415-896-5566 Fax: 415-986-5896 complxpl.lst TN"RF: COMPLEX ASBESTOS LITTGATION Defense Counsel Service List Revised 1/16/96 Adams, Nye, Sinunu & Walker, 633 Battery St, 5th Floor, San Francisco, <15/382-8955 CA 94-111, Attn: Barbara R. Adams ' - Fax: <15/982-2042 On behalf of: General Plumbing Supply Ca/Forderer Cornice Works, IncJPredsion Auto Parts/ The Bolster CoJTimes Mirror Co/Tha Brose CoJMonument Car Parts/Steel Grip, IncJAca Hardware/ Sears, Roebuck & CoJPotter Sectric/Buit Williams & Son, tno/Crossfietd Products CorpJ Plumbers Specialty Co_ Inc/Broadway-Webster Medical Plaza/Quafitex Co., Inc/Janos Industrial Insulation Corp/fTie'Industrial Maintenance Engineering Contracfing Co. (TIMEQ/Calaveras Asbestos/ Janos Industrial Corp. ' . Andersen, Bonnffield & Stevens, 1355 Willow Way, Suite 255, Concord, CA 84520 * 510/602-1400 Attn: RiA. Bonnifield ` Fax: 510/825-0143 On behalf of: Patrick J. Ruane, IncJPetrochemtcai Insulation, lncJQ.G. Supply, tncJCIose Building Materials, tncJGasket Engineering & Machine, Inc. Anderson, Galloway & Lucchese, 1676 North California Blvd,, Suite 500, . 510/943-8383 Walnut Creek, CA 94596, Attru Marty Everson ' Far 510/343-7542 On behalf oh Babcock & Wilcox * - Archer, McComas, Bresfin, McMahon & Chritton, 2033 N. Main St, Suite 800, 510/930-6600 P.O. Box 8035, Walnut Creek, CA 94596, Attn: Rand Chritton Far 510/930-6620 On behalf of: Hofmann CoJContinental Can CoJLa Habra Products, IncTBay City Boilers & Engineering/ Aetna Life &. Casualty CoTBank of Canton of Califomia/Sentry Insurance CoJZum Industries/Piedmont Lumber Co./Ohio Casualty Group/Carlisle CorpJCahill Construction CoJDurant Insulated Pipe CoJ Anning-Johnson CoA/ictor Equipment CoiCathedral Hill Hotel, Ino/Anderson, Rowe & Buckley/ Waldron, Duffy, IncJIreland-Rofcinson & Hadley, IncTDillingham Construct'on NA, lncTRoss Island Sand & Gravel CoJFatrfax Building Supply/J.G. MacPhee Company/Columbia Pipe 4 Supply Amelte, Hastie, McGee, Willis 4 Greene, One Market Plaza, Spear Street Tower, 415/495-4747 39th Floor, San Frandsco, CA 34105-1123, Attn: Otis McGee, Jr. Far 415/495-5123 On behalf of: Eaton Corp./Crown Coach, IncJChrysler CorpiAMC/NARMCO, IncJWorfd Savings 4 Loan Becherer, Beers, Murphy, Kannett & Schweitzer, 2200 Powell Street Sufte 805, 510/658-3600 Emeryville, CA 94608, Attn: Patrick J.Becherer On behalf ot Chrysler Corporafion/Bridgesone-Firestone, Inc. i Far 510/653-1151 ' Barger & Wolen, 101 California Street, Suite 4725, San Frandsco, CA 94111-5848 Attn: Gary A Bresee . Far On behalf of: The Equitable Life Assurance Sodety of the United States . ' 415/434-2800 415/434-2533 Law Offices of Susan L_ Benett, 1550 The Alameda, Suite 330, San Jose, CA 95125 408/287-2030 Attn: Susan L. Benett On behalf of: United Airlines . ' Far 408/287-1303 Bennett & Rowland, One Embarcadero Center, Suite 950, San Frandsco, CA 94111 Attn: Allison D; Daniets/Stanley M. Wessels * Far . On behalfott Honda North America, Inc. ' . . ` ' 415/956r4800 415/788-5948 Bennett, Samuelsen, Reynolds & Allard, 1951 Webster Street, Suite 200, . 510/444-7688 Oakland, CA 94612-2940, Attn: Richard L Reynolds ' Far 510/444-5849 On behalf of: Dresser industries, tno/Harfxsan-Walker/Indresco/O.C. McDonald CoJSIakey Brothers/ O.C.McDonald CoJFitt-Oes Moines,Inc. '___ _ ..................................' 'Arthur Paul Berg, Attorney at taw, Tha Woodlands, 1635 Wlbasso Way, ...... 1 Glendale. CA 91208, Attn: Arthur Pad Berg---------------------------------- ---------------- Far On behalf oft Rock.Woof Manufacturing Co. ; -, . __ . 818/547-9575 818/547-0461 . "Berry & Beny' Station D, P.O. Box70250 (1300 Clay Street, 9th Root), Oakland, 510/873-6700 CA94612-0250, Attn: Carolyn Collins. . Far 510/335-5117 Designated Defense Counsel' . , Beveridge & Diamond, One Sansome Street Suite 3400, San Frandsco, CA 94104 415/397-0100 Attn: Brett P. Moffett ' Far .On behalfof: Del Webb California CorpjMIes, Inc. _ Bishop, Barry, Howe, Haney 4 Ryder, 275 Battery SL, 12tii Roor, San Frandsco, 415/397-4238 ss-y.-.: 415/42143550 CA 94111, Attn: Nelson C. Barry ..........., ............ . Far 415/362-4730 ; On behalf of: PPG fndustries/Plant Products &. Supply Co7A.H. Bennett CaJPaalic Ship Repair 1960 -5 - Bjorfc, Lawrence, Poeschl 4 Kohn, 483 Ninth Street. Oakland, CA 84607 51Q/832-8134 Attn: Oorine P. Kohn Fax: 510/832-0461 On behalf of: Dunn-EdwaidsCorpJRockbestos/Cerro Metal Products Co, - Bledsoe, Cathcart, Diestet, Livingston & Pedersen, 601 California St, 16th Roor, . 415/981-5411 San Francisco, CA 94108, Attn: Gregory L Spaflas Fax: 415/981-0352 On behalf of: Cincinnati Gasket Packing & Mfg. CoiTJA. Cobb CoJBeronio Lumber CaJ Scherba's Auto Stores, Inc. ' Boornaztan, Jensen & Garthe, 1800 Harrison St, 25th Floor, 94612, Mailing: - 510/834-4350 P.O. Box 12925, Oakland, CA 94604, Attn: Robert Crow Fax: 510/839-1897 On behalf oh NACCO Materials Handling Group, ino. Successor-in-interest to HysterCo. Borton, Petrini & Conron, One Sansome St, Suite 1000, San Francisco, CA 94104 415/981-4415 Attn: Richard E. Kerb Fax: 415/391-5538 On behalf oh Ford Whoisale Co., IncJThrowbot, Inc. Boughey, Garvie 4 Bushner, One Post St, Suite 2400, San Frandsco, CA 94104 ' 415/398-4500 Attn: Todd J. Holcomb Fax: 415/398-2455 On behalf oh Service Engineering CoJH&H Ship Service Co./Matthew G. Norton Co./Southwest Marine ' Bowies 4 Verna, 2121 N. California Btvd,, Suite 875, P.O. Box 8180, Walnut Creek, 510/935-3300 CA 94596, Attn: Robert O.PhflBps, Jr. ... Fax: 510/935-0371 On behalf oh Anheuser-Busch, IncVKflpatrick's Bakeries Bradley, Curley 4 Asiano, 150 Spear St, 12th Floor, San Frandsco, CA 94105-T535 415/442-4888 Attn: Ann M. Asiano * Fax: 415/442-4884 On behalf oh Power Engineering & Equipment CoJInductotherm industries, Inc. ` Branson, FitzGerald 4 Howard. 643 Bair Osiand Rd., Suite 400, P.O. Box 2189, 415/365-7710 Redwood City, CA 94064-2189, Attn: Henry D. Rome Fax: 415/364-52S7 On behalf oh Synkoloid/Gow Supply CoJVailey Stucco & Putty Plant IncJArtra Group, Inc., Successor to Dutch Boy. Inc/Pine Cone Lumber Co., Inc. Brobeck, Phleger 4 Harrison, One Market Plaza, Spear Street Tower, 415/442-0900 San Frandsco, CA 94105, Alin: William P. Griffin Fax: 415/442-1010 On behalf oh Fibreboard Carp/Atlantic Richfield/CIBA-Geigy CorpJWestem MacArthur CoJ Brobeck, Phleger 4 Harrison, One Market Plaza, Spear Street Tower, 415/442-0900' San Frandsco, CA 94105, Attn: John Carlson- Fas 415/442-101Q On behalf oh LD. Brinkman Co. ' Brobeck, Phleger 4 Harrison, 4675 MacArthur Court, Suite 1000, Newport Beach, 714/752-7535* CA 92660-1846, Attn: KathleneW. Lowe . Fas 714/752-7522 On behalf oh Koli Real Estate Group, Inc. ' Bronson, Bronson 4 McKinnon, 505 Montgomery St, San Frandsco, CA 94111 415/986-4200 Attn: Lawrence M. Cireili Fas 415/982-13S4 On behalf oh BOC Group, Incl/Airco Gas & Gear CorpJEiectricai Insulafion Suppliers, Inc. Brown, Pistone, Huriey 4 Van Vlear, 8001 Irvine Center Drive, Suite 900, 714/727-0559 - Irvine, CA 92718, Attn: Michael K. Woider - Fas 714/727-0656 On behalf oh Advance Mechanical Contractors, Inc. - .. . Capps, Staples, Ward, Hastings & Dodson, 1777 Botelho Drive, Suite 100, . .. .... . 510/939-4411 Walnut Creek, CA 94596, Attn: Marsha L Stephenson . " . . . . .. "Fas 510/939-5241 J'On behalfoh Graybar Etedrie/U.S. Borax, fac_ -------- ici Carroll, Burdick 4 McDonough, 44 Montgomery St, Suite 400, San Frandsco, 415/989-5900 CA 94104, Attn:-James B. Clapp/TRobertG. Miller Fas --415/989-0932 On behalf oh McDonnell Douglas CorpJLevi Strauss & CoTSchlage Lodc/CF. Braun/Oscar E. Erickson/__ ;.fngetsdII-Rand CbJUlP. Stevens'4 Co^'fncJD. Zelinsky 4 Sons, fnc/Qre'DrarCorpJSuperior Boiter.yVbrfcsC "Carroll, BurtJTck 4 McDonough, 44 Montgomery St, Sutte 400, San Frandsco, 415/989-5900 ..CA 94104,Attn: Teke Kelley'... '_____ ... 1..' _,._Fas =415/989-0932 1 On behalf oh Ericsson, Inc. (Anaconda) `' - Carroll, Burdick 4 McDonough, 44 Montgomery St, Suite 400, San Frandsco, 415/989-5900 CA 94104, Attn: Roberta J.Beringer . Fas-- -415/989-0932 On behalf oh St Francis Hotel/Seias Corporation of America/Home Savings ofAmerica --------- ----- Caswell, Belt, Hillison, Burnside 4 Greer, 5200 N. Patel Ave.. Fresno, CA 93704-2228 209/225-6550 ' .(Mail: P.O. Box 5259, Fresno, CA 93755-5259), Klin: RandoifKrbechefc '-~===Eac =209/225-7912 On behalf oh Terminal Air Brake Supply, Inc. . Clapp, Moroney, Baltagamba, i**vs & Vucfnich, 4400 Bohannon Drive, Sutu, idO, 415/327-1300 Menlo Park, CA 94025, Attn: Christopher W..Wood Fax: 4157327-3707 On behalf oh E.V. Roberts & Associates, Inc/Acousta-Lita/FloorcrafflO Camino Parts Co/Clauda Short Dodge/Guy F. Atkinson Co/Keystone Consolidated fodustries/Power Boiler Sales, IncJDelmer's Brakes/ VUrsmer & Becker Contracting Engineers/Archie Brothers, IneJCteaver Brooks, A Division ofAqua-Chem/ Pacific Mechanical Corp/Coca-Coia Ca/Venton Plastering/South Bay Taping/Western States Stone Co, Coddington, Hicks & Danforth, 555 Twin Dolphin Dr,, Suita 300, Redwood City, 415/592-5400 CA 94065, Attn: David Levine ' Fax: 415/532-5027 On behalf oh United Airlines, IncJHexcal Corp. .' Connor & Bishop, 870 Market St, Su3a 600, San Francisco, CA 94102 415/434-3006 Attn: Charles S. Bishop ' Fax: 415/434-1445 On behalf oh fvfna Safety iAppCancss Co/Wabash Power Equipment Co, Cooper, White & Cooper, 201 California St, 17th Floor, San Francisco, CA 94111 .415/433-1900 Attn: Christopher J. Mead/John P. Makin ' Fax: 415/433-5530 On behalf oh California Hydronics Corporation Cooper, White & Cooper, 201 California SL, 17th Root, San Francisco, CA 94111 415/433-1900 Attn: Lawrence J. Siskind/Daniel A. Metsel Fax: 415/433-5530 On behalf oh The Kendall Company . . . Crosby, Heafey, Roach t May, 1999 Harrison Street Oakland, CA 94612 510/763-2000 Attn: Jude Warren Fax: 510/273-6866 On behalf oh Chrysler Corp/AMC/Hobart Brothers CoJDelaval Steam Turbine CoJIMO Industries/ Bridgestone/Firestone, lnc/Union Pacific Railroad Co/Lincoin Electric Co/FJ3. Lathrop Construction Co. Crosby, Heafey, Roqch & May, 1999 Harrison Street, Oakland, CA 94612 510/763-2000 Attn: Julie Linn ' ` Fax: 510/273-3866 On behalf oh Phillips Petroleum Co/Gaylord Container Corp/Tosco CorpJSpreckels Sugar Co. Cullom & Burtand, 550 California St, Suite 700, San Francisco, CA 94104 415/781-7999 Attn: Freeman D. Cullom Fax: 415/788-0335 On behalf oh Crane Packaging/John Crane-Houdaiile Cyril & Crowley, 456 Montgomery St, 17th Floor, San Francisco, CA 94104 415/989-1100 Attn: Wendy J. Hannum/Mark D. Fenske Fax:' 415/421-6651 On behalf oh Colberg, Inc/TRW CorpjMoore^McCormack Resources Cyril & Crowley, 456 Montgomery SL, 17th Floor, San Francisco, CA 94104 415/989-1100 Attn: Michael W. Ffeld/Mark D. Skilling Fax 415/421-6651' On behalf oh Pyramid Investment Corp/Transamerica Corporafion/TIG Premier insurance Co. . Danaher, Tedford, Lagnese & Neal, P.C., 700 Capitol Place, 21 Oak Street, 203/247-3633 Hartford, CT 06106 . Fax 203/5471321 On behalf oh Pittsburgh Coming Corporation Daniels, Baratta & Fine, 1801 Century Park East, 9th Roor, Los Angeles, CA 90067 310/556-7900 Attn: Stephanie J. Berman Fax 310/556-2807 On behalf oh Highland Stucco & Lime Products, Inc. Davidoviiz & Yaron, 111 Pine Street 12th Root Sari Frandsco, CA 94111-5614 ' 415/65^2929 Attn: Jeffrey J. Fadeff - - ----------- . . Fax -415/358-2930 On behalfoh Todd Shipyard/Mervyn's/Pierce Enterprises/American Standard, IncJTrana CoJ ' - Railroad Friction Products Corp/Colombini Construction - ~Oewey Ballanfine,"333 South Hope Street Los Angeles' CA 90071 - - - --r213i6264J399 On behalf oh Champion International Corp. .. . Fax 213/625-0562 : Dickson,'CarfsorilfcCampfllo, 120 BroadwayrSurte'300,SantaMonfcaVCA90407, -"310/451-2273 . Mailing:P.O_Box2122^Santa Monica^CA90407-2122.Attn: Eric M. Zyia -----Fax: --310/451-9071 - On behaif oh R.T. Vanderbilt CoJPfeBr.Tnc/American Cyariamid -- Dickson, Cartrion '& Campilto, 120 Broadwa*y,'Su"ite 300, Santa Mon`ica, CA 90407 310/451-2273 Mailing: P.O.Box2122, Santa Monica, CA 90407-2122, Attn: Roxanne M. Wilson Fax -310/451-9071 On behalf oh Plant Insufation Company (Subic Bay only) Dillingham & Murphy, 625 Market Street 14th Fioor, San Francisco, 415/895-G4QQ CA94105-3315, Attn:John Dahlberg Fax 415/882-4202 On behalfoh AT&TTechnoiogies/Conoco, Inc.:~ :-/ ' " -2' ' Dillingham & Murphy, 625 Market Street, 14th Floor, San Francisco, CA 841ua-3315 415/896-0400 Attn: William K. Bessel . Far 415/764-1970 On behalf oft Kaiser Cement CorpiKaiser Gypsum Co^ tneJGasket Spectaifiss, IrtcJ p P Dolan Lumber CoJGouUs Pumps, Inc. Drath, Clifford, Murphy, Wennerholm & Hagen, 44 Montgomery Street, Suita 1500, 415/392-3006 , San Francisco, CA 34104, Attn: John M. Drath Far 415/391-3348 On behalf of: USX Cotp. ' Dryden, Margotes, Schimaneck, Hartman, Kelly & Wait, One California St, Su2e 2600, 415/362-6715 San Francisco, CA 84111, Attn: Lawrence Margoles Far 415/362-0638 On behalf oft FJggie International IncJFord Motor CoJSherwin-Williams CoiPhSGjps Petroleum CoJ MadeTrucks, tncJOSrien CorpJCapco Pipe Co., incJJaguar Cats Duncan, Ball, Evans & Ubaldi, 641 Fulton Avenue, Second Floor, Sacramento, 916/488-1666 CA 95825, Attn: Jerry M. Duncan Far .916/488-1629 On behalf oft Mercy San Juan Hospital Ericksen, Arbuthnot, Brown, KHduff 4 Day, 530 Water St, Sate 720, Oakland, 510/832-7770 CA 94607-3746, Attn: William J. Hoback Far 510/832-0102 On behalf oft BJ\ Goodrich CoVNatkin & Co. , ' Ericksen, Arbuthnot, Kflduff, Day 4 Lindstrom, Inc., 20 Califbmia Street, Suite 300, 41S/362-7126 San Frandsco, CA 94111-4803, Attn: AndrewP. Sdar ' Far 415/362-S401 On behalf oft Aratex/Aramark Services, Inc. (Successor-in-interest to U.S. industrial Glove Co.) Sydney E. Fairfaairn, Attorney at Law, Seven Mt Lassen Drive, Suita D-134, 415/479-0940 San Rafael, CA S4S03, Attn: Sydney E. Fairbaim Far 415/479-0940 On behalf oft H. Goldman 4 Sons Farella, Braun 4 Martel, 235 Montgomery St, 30th Floor, San Francisco, CA 94104 415/9S4-4400 Attn: Dennis M. Cusack/Bany T. Ryan On behalf oft Shorenstein Co./Rockwell International John D. Feeney, Southern Pacific Lines, law Dept, 8th Floor, One Market Plaza, 415/541-1000 San Francisco, CA 94105 ' Fax: 415/541-1734 On behalf oft Southern Pacific Transponation Co. . Fenton 4 Keller, 2801 Monterey-Safinas Highway, P.O. Box 791, Monterey, CA 93942 408/373-1241 On behalf oft Loriilard Tobacco Co. , Far. 408/373-7219 Flynn, Delich 4 Wise, $80 California Street Suite 1750, San Francisco, CA 94104 415/693-5566.. Attn: Faye Lee . - Far 415/693-0410 On behalf oft General Steamship International, Lid. Folger 4 Levin, 275 Battery Street 23rd Boor, San Frandsco, CA 94111' 415/986-2800 Attn: Julia Mattof Far 415/986-2827 On behalf oft Amfac Distribution CorpJHitton Hotels Corp. Christie L. Fraser, A Law Corporation, 201 Filbert Street San Frandsco, CA 94133 415/394-8880 Attn: Christie L Fraser . . ' Far 415/394-5665 . On behalf oft Pan-Pacific Supply Co., Inc. Fredrickson, Mazeika 4 Grant 550 West *C* Street Suite 1410, San Diego, . 619/234,1722 CA 92101, Attn: Tomas V.Mazeika - *' Far 619/234-1753 ;On behalf oft Unlvetsfiy Mechanical & Engineering Contractors - -.Freeburg, Judy 4 Nettels,600 South Lake Avenue, 2nd Boor, - . 818/5854150 - "`Pasadena, CA 91106-3955,"Attn: J. Lawrence Judy '................. .....................Far' "818/585-0718 ~ ' On behalf oft Ffintkote/Gensiar/Blue Diamond___ ...___ . ___________ ____________ 'Frost 4 Healy.l930 Sonoma Btvd.'Valtejo.'CA 94590, Attn: NorbertU. Frost --707/643-5696 ' _On'behaIfoft Napa"Gfove Corine. Far --707/6434919; Galtawa, Brown, Kraescit Kauffroath, 2207J Street Sacramento, CA 95816 916/444-8364 : : Attn: Walter Gallawa --. ------- - . rOn behalfof: Amsfed Industnes/Griffin Wheel Co.'~ ' Far .'-916/444-5921........ - - - Gardiner, Koch & Hines, 53 West Jackson Bivd., Suite 1550, Chicago, !L 60604 312/362-0000 . Attn: Tom Gardiner ........ .. . . . Far : 312/362-0440 On behalfoft ElEs Corporation" '' . 1 _ __ ~GtaneHT4 Fores, 101416th Street PlO. Box3212,-Modesto, CA95353 ' -* ' '` '"'."209/521-6260 --%> .rr-V ~ lAttn:Robert?.cores ------------------------ -- Far --209/521-5971 , ------- OrTbefialfdffMotor Parts-Distributors Gibson, Dunn & Crutcher, One Montgomery Street, San Francisco, CA 94104 415/393-8200 Attn: Wilttam 0. Connefl ' Far 415/986-5309 - On behalf aft Champion Internationa] Corp. GHhts, Nicora, Minor & Sullivan, 30 Ragsdale Drive, Suite 201, Monterey, CA 93940, Attic Timothy J. Minor/Staven D. Penrose . - 408/373-5900 Fax: 408/373-5991 On behalf of: Morton international, lncJTWokol Corporation Glaspy & Glaspy, 100 Pringle Avenue, Suite 750, Walnut Creek, CA 94598 ' ; 510/947-1300 Attn: David W. White Fax: 510/947-1594 On behalf of: Gartock, kicJCoitIndustries/The Mills 8uitding/Fairmont Hotel CoJSacramento Tires, Batteries& Accessories/Anchor Packing CoJLockheed ShipbuScfing CoJTriValley Growers/Paccar Glaspy & Glaspy, 353 Sacramento St, SuiteTSOO, San Francisco, CA 94111 415/398-8261 Attn: Brian S. O'Malley On behaif of. Monison Knudsen Corp. - Far 415/338-4416 . .. .Glynn, Cetta & Lange, 100 Pringle Avenue, Sufta 600, Walnut Creek, CA 84596 510/210-2800 .Attn: James D. Lehmann Far 510/945-1975 On behalfof: 1. du Pont de Nemours & Co. Goldstein & Phillips, One Embarcadero Center, 8th Floor, San Frandsco, CA 94111 On behalf of: Norca Corp. . Gordon & Rees, 275 Battery St, 20th Floor, San Francisco, CA 94111 - 415/986-5900 Attn: Richard D. Fike - Far 415/986-8054 On behalf of: Nebraska Boiler Co., IncJJ.W. & Sons/l_N. Curtis & Sons/Westem Building Materials/ Fraser-Edwards CoJHoiloway & Freeman, Inc. Gordon & Rees, 275 Battery Street, 20th Floor, San Francisco, CA 94111 415/986-5900 Attn: Sara Spees On behalfah Dow Coming Carp. Gordon A Rees, 275 Battery Street 20th Floor, San Frandsco, CA 94111 Far 415/986-8054 415/986-5900 Attn: Michael T. lucey/S. Mitchelt Kaplan Far 415/886-3054 On behalf of: Bendix (Allied Corp.)/AiIied-Signal, Inc. . Gordon & Rees, 275 Battery Street 20th Floor, San Frandsco, CA 94111 415/986-5900 Attn: Michael T.lucey - Far 415/986-3054 On behalf oft FOSECO, Inc. -- Gordon & Rees, 275 Battery Street 20th Roar, San Frandsco, CA 94111 ; 415/98S-5SGQ. Attn: Jewel Kolling Basse . Far 415/986-5900 On behaif of: Union 09 of California (UNOCAL) Gordon & Rees, 275 Battery Street 20th Roor, San Frandsco, CA 94111 415/986-5900 Attn: Thomas C. Crosby Far 415/986-8054 On behalf of: Triple A Machine Shop/Eastco/Industrral Safety Corp. Gordon & Rees, 275 Battery Street 20th Floor, San Frandsco, CA 94111 415/986-5300 Attn: P. GerhardtZacher/Richard D. Fike Far 415/986-8054 On behalf oft Rapid American Carp. Gordon &. Rees^275 Battery Street 20th Roor, Sanfrandsco, CA 94111 ..... -415/985-5300 -Attn: P-GerhardtZacher/ThomasC. Crosby . . -OnbehaffoW.R. Grace & Co.--Conn.' ' ' ................ . - Far 415/986-8054 ' v: " Grace, Skocypec, Cosgrove & Schirm, 57Q0WIhhire Bfai., Cute 30QH. Los Angeles, 213/487-6660 . _ CAtfCf&Gffitn: PMIp R- Cosgrove 5o*V/\ flower, IjM f<, Far 213/487-4896 '.On behalf oft General Motors Corporation ------- ^Graham & James. One Maritime Plaza. 3rd Roor, San Frandsco,CA94111 . .... .415/954-0200 ,Atth;AndrewLPart t -' .. ' " . ""'Far "'415/391-2493 On behalf of Sealift Ino/Mobit Qil/GoodyearTira & Rubber CoJAmerada Hess/Alcoa CoJHendy International/ Matson Navigation CaJPacrfic Coast Shipping/WatermanSteamship CaJChevron/WeyertiauseriLykes Bros/ . Crowley Marifime CoJNafional Bulk Catriers/Mormac Marine/Seaiand Service, tncJVfctory Carriers/ , - ' Keystone Shipping CoJDelta Unes/Centrat Gulf Shipping/Marine Transport Un.es/Farreli Transport Lines/ ' " NedKoyd Unes/Bay Tankers/Interocean Management/Marffime Overseas Corpi/DMI Bulk Management Co/ ` Standard 03 ofCatifomia/West Coast Shipping CoJWatters Marine, InoJPadfc Dry Dock/Apex Marine/ . - American President Lines/Global Marine Drilling/Padffc Gulf Marine ' Gudmundson, Siggins, Stone & Skinner, One Embarcadero'Center, Suite 1350; ;415/391-4200 --- San Frandsco, CA 94111, Attn: Richard J. Siggins Far 415/989-4739 On behalf oft American Cyanamid - - -- .^ ' __________ . _____________ ._ iJ Haight, Brown & Bonesteel, 201 Sansome St, Sate 300. San Francisco. CA34104 415/986-7700 } Atln: 1 r" _ Oberg Fax: 415/986-6945 .On behalf oft CCR Oefandarrts/Ohia Locomofive Crane CoJLord Corparatfan/MCA/Unwersal City Studios, Inc/ San Francisco Sourdough Bakeries, Ine/Tarkett, Inc. . _____ Hake & Joyce, 100 Spear Street Sute 310, San Francisco, CA 941 OS Attn:VUaQamM. Hake . Fax On behalf of: Avon Products, Inc/Diamond Walnut Growers, Inc. ______ Hancock, Rotftert & Bunshoft, Four Embarcadera Canter, 10th Floor, San Francisco, CA 94111, Attn: James P. Barber, Merton A Howard Fax 415/512-7100 415/512-7103 41 S/981-5550 415/955-2599 On behalf oft Borden, thc/American Suzuki Motor Corp. ______ Hancock, Rotherti Bunshoft, Four Embarcadera Center, 10th Floor, San Francisco, 415/981-5550 CA 84111. Attn: Ray L Wong _ On behalf oft General Cable/American PremierUnderwritars Fax 415/955-2599 - ______ Hanna, Brophy. MacLean, McAleer & Jensen, 535 Market Street Suite 900, 415/543-9110 ~ San Francisco, CA 34105, Attn: Neville H. McGHchrist Fax On behalf oft Manvilte Sales CoipJDel \tonta Foods ` ______ Hardin, Cook, Loper, Engel & Bergez, 1999 Harrison St. 18th Floor, Oakland, CA 94612, Attn: Eugene Brown, Jr. ' . .Fax 415/896-0901 510/444-3131 510/839-7940 On behalf oft Oakfabco/Haiwick Chemical Corp./Complete Auto Parts/Hartford Fire Insurance/ Hartford Accident & Indemnity CoJUniversity of Southern CaRfomia/ELD. BuUard/Beltlndustries/ ' J.H. Frtzmaurice. IncJKahaia HDton Hotel/Mortell Company - ______ Hardin, Cook, Loper, Engel &. Bergez. 1999 Harrison St, 18th Floor, Oakland, CA 510/444-3131 94612, Attn: Peter A. Strotz Far. 510/839-7940 On behalf of: ICI Composites, IncTICl Americas, Inc. -Hardin, Cook, Loper, Engel A Bergez, 1999 Harrison St, 18th Floor, Oakland, CA 94612, Attn: Bruce McLeod/Stephen J. Valen Fax 510/444-3131 510/839-7940 On behalf of: Rhone-Poulenc Basic Chemicals Co. (Stauffer Chemical) . Hardin, Cook, Loper, Engei & Bergez, 1999 Harrison St, 18th Floor, Oakland, CA ' ~ 94612, Atln: Bruce Mik.eod/Peter A. Strotz Fax 510/444-3131 510/833-7940 On behalf oft The Dow Chemical Company ______ Hardin, Cook, Loper, Engei & Bergez, 1999-Harrison St, 18th Floor, Oakland. CA 510/444-3131 94612. Attn: Marshall A. Thompson : Fax 510/839-7940. On behalf oft Alta Building Materials Company Hardy Erich Brown & Wilson, 1000 G Street Sacramento 95814, Mailing: P.O. Box 13530, Sacramento, CA 95853-4530, Attn: Brian Charter .- Fax 916/449-3800 916/449-3888 On behalf oft Goodyear Tire & Rubber CoiThe Dexter Corporafon/McPhail's, Inc. ______ Brett R. Harrell, P.O. Box 1130, Modesto, CA 95353 209/579-3717 On behalf oft EL & J. Gallo Winery Fax 209/579-3719 ______ Harrington, Foxx, Dubrow & Canter, 611 W. Sixth St, 30th Floor, Los Angeles, CA - 213/489-3222 ' 90017, Alin: William H. Finney ' Fax 213/623-7929 On behalf oft Ford Motor CoJNavistar International TransportationCo. -. Hassard Bonn!ngton,.Two Embarcadera Center, Suite 1800, San Francisco, CA 415/288-9800 CA 94111^3993, Attn: Robert M. Hambtett " 5 " Fax: 415/288-9801 - ------- On behalf oft: Kaiser Hospitals, tncJEl Cammo Hospital/Golden Gateway Building CoJGolden Gateway ... __ __ Holding CorpJPerini Land & Development Co./Paramount Development Assoc. " Hefner, Stark.8LMaroEs.2710 Gateway'Oaks Drive,' Suite 300 South, Sacramento," ----- 916/925-8820 ^xx^CA95833.Attn:StephenS.Tait ------- -----..-Fax ..916/925-1127 ^.On behalf oft. Ktfkhfl! Rubber Company - - ' _ Heller, Ehrman, White s. McAuBffe, 333 Bush Street, San Fraricscd, CA 94104-2878 ''415/772-6000 " "Attn:Ann G. Grimaldi - ~~ ................................ - . - On behalf oft Wiegmann &Rcse Intemafional/PennzoO Company Fax 415/772-6268 _ Hill, Farrer & BurriH,445 South Figueroa Street 35th Floor, Los Angeles, CA 90071 213/620-0460 ` Attn: Craig Jl Whitney ........1 - _ Fax 213/524-4840 ' VOn behalfoft Atchison. Topeka 4 Santa Fe Railroad Co. - -- ------- - . __- Hitt Genson, Even, Crandall &. Wade, 505 Shatto Place, Los Angeles, CA 90020 818/393-4811 Attn: Gene Gensbn ~ ~~ --- --r ~ Fax x:-213/380-8S46 lOn behalf oft Uniroyal. Inc._____ r . Hoge, Fenton, Jones & Appel, Inc,, 60 South Market St, Suite 1400, San Jose, 4087287-0501 CA 95113-2396, Attn: Nora Frimann . Fax: 408/287-2583 On behalf of: The Austin Company/American Rubber Manufacturing CoJContainer Corp. OfAmerica Howarth ASmith, 700 South Rower Street Suite 2900, Los Angeles, CA 90017 213/955*9400 Attn: Thomas F. Vandenburg Fax: 213/622-0791 On behalf ofc Georgia-Pacific Corporation ' Howrey & Simon, 550 South Hope Street Suite 1400, Los Angeles, CA 90071 213/892-1800 Attn: Kathryn M. Conway Fax: 213/892-2300 On behalf oft Mohawk Flush Doora, Inc. Hudgins & Hunt 135 Main Street Suite 1350, San Frandsco', CA 94105 415/979-0100 Attn: Kevan T. Hunt Fax: 415/979-0747 On behalf of: Uniroyai, Inc. .. Law Offices of Michael R. Hudson, 500 Sansome Street Suite 601, - ,415/882-1556 San Frandsco.-CA 94111, Attn: Mchael R- Hudson Fax: 415/886-143Q On behalf at Skinner Corporation Hyde A Holcomb, 1646 North California Bivd., Suite 550, Walnut Creek, CA 34596 510/939-7700 Attn: Patrick J. Hyde . . Fax: 510/939-2248 On behalf of. The Ctorox Company . - Timothy M. Hyden, Attorney at Law, 18 Crow Canyon CL, #380, San Ramon, CA 94583 510/831-0636 On behalf of: Economy Rubber & Gasket Inc. "Fax: 510/831-8483 imar, Tadfock A Keeney, 180 Montgomery St. Suite 1000, San Francisco, CA 94104 415/989-8687 Attn: Robert C. Keeney/Edgar Hawkyard Far 415/989-7640 On behalf oft A.W. Chesteron Co./George Raymond Co./Raymond Interior Systems-North Imai, Tadlock A Keeney, 180 Montgomery St. State 1000, San Francisco, CA 94104 415/989-8687 Attn: Theodore T. Cordery On behalf oft See's Candies/Campbell Soup CoASimpson Paper Co./Humboldt Bay Pulp Co1 Elliott CoJRich-Tex, IncJBasic Vegetable Products/James River CorpVAnchor Hocking Co. Jackson, Tufts, Cole A Black, 650 California Street San Francisco, CA 94108 415/433-1950 Attn: Lynn A. Starr ' Far 415/392-3494 On behalf-of: Fort Kent Holdings, Inc. . Jacksori A Wallace,'580 California Street 15th Floor, San Frandsco, CA 94104 415/982-6300 Attn: John R. Wallace Far 415/982-6700, On behalf oft New York Life Insurance Co./Fluor Corp./Radiator Spedatty/Landor A Assodates/Ferro CorpJ Kraft General Foods, fncJMnwhite, IncJM. Slayen AAssodates/Repubtic Supply CoJFraser's Boiler Service/ The Okonite Co/Plant Insulation CoJArmco, lneJChicago Firebrick CoJAlfred Dunhill of London/Wale Apparatus CoJHamon Cooling Tower Co./Bethlehem Apparatus/Crown Zelterbach International, Inc. Jaffe, Trutanich, Scatena A Blum, 155 Sansome Street, Suite 700, San Frandsco, 415/397-9006 CA 94104, Attn: Michelle M.Lambre Far 415/397-1339 On behaif oft KSC Recovery ' , Jedeikin, Green, Meadows A Schneider, 300 Montgomery Street Suite 450, 415/781-7050 San Frandsco, CA 94111, Attn: Joseph Jedeikin <. Far 415/421-5658 .On behalf oft Cfty National Bank/Sunset Homes, IncJBryan Steam CorpJE. A J. Gallo Winety/Heubldn/ _ -Beaulieu Vineyards _. ' ` Jeffrey A Heinemannr685 Market Street, Suite 330, San Frandsco, CA 94105 " -- --~ .415/543-8970 -- On behalf oft Burnham Corporation Far 415/543-2670 - .-Jones, LaMore, Brazier A Riddle, 1570 The AIameda, Suite 150, San Jose, CA -^^-408/280-6800 - L95126-2306,Attn:JamesC.Jones -- - --j-------- - --- Far -408/275-6284 -J ^On behalf oft Caterpflla'rv'fhc.' _____*1--1____ 1.1^1___ _.. - ~w._. " Jordan, Keeier A Seligman,Two Embarcadero Center, 19th Roor, 415/397-4600 ~~ .. San Frandsco, CA 94111-3984, Attn:David H. Gartehore ................... .. ,:.Far ...415/392-2059 ., On behalf oft Stone A Webster Engineering Corporation ............ . Kaufman A Logan, l-TI-Pfee Street Suite 1300, San Frandsco, CA 94111 415/392-6677 Attn: Peter J' Logan . . Far 415/391-4639 On behalf ofc First Interstate Bank . - - - r- - - - - .-------------------.-l---- Keck, Mahin A Cate, One Maritime Plaza, 23rd Roor, San Frandsco, CA 94111-3577 415/392-7077 ~Attn: RobertE. Paterson 3.3 _'3-'-333=3:31- '. ~ ~~-'~.~E5Far-E3415/392-3S6S-3~ . .. On behalf of: Abex Corporation/Wheelabrator Group, Inc. Kaesat, Young Logan, Four Embarcadero Canter, Sute.1500, San Frandsco, +15/883-0616 CA 34111, Attn: Robert A. Bleicher '. Far +15/981-7729 On behalf ofc Lear Siegler Diversified Holdings CorpJProgresso Foods CoJPuilman Standard, Inc/ TUtta Lewis Foods, Inc/Tishman Realty Construction Co/The Pullman Company Kenney, Burd Markowitz, Two Embarcadero Center, SuSe +70, San Francisco, +15/337-3100 CA 34111, Attn: Stephen C. Kenney On behalf ofc BP Chemicals - Kinder, Wuerfei Cholafcian, 555 Montgomery St, 3th Floor, San Francisco, CA 34111, Attn: EdwinS. Nakagawa Fax: -* Fax: +15/397-3170 " +15/338-1551 415/338-3301 On behalf ofc Yoffetnd Materials Co. Kfnsella, Boesch, Fujikawa Towle, 1301 Avenue ofthe Stars, 7th Floor, . 310/201-2000 Los Angeles, CA 90067, Attn: Leonard M. Tavera Fax: 310/284-5020 On behalf at Parkar-Hannffin CorpJEIS Division . . Knight, Boland A Riprdan, 88 Kearny Street Suita 1310, San Francisco, CA 34104 ` 415/362-0684 Attn: Samuel G. Ware Fax: 415/956-2750 On behalf ofc Metropolitan Life insurance Co. Knox, Lemmon, Anapolsfcy Sheridan, 300 Capitol Mail, Suite 1170, Sacramento, 816/448-9911 CA 95814, Attn: Susan J. Sheridan Fax: 916/448-2563 On behalf ofc Kenworth Trucking Co. Knox Ricksen, 1999 Harrison Street Sufte 1700, Oakland, CA 34612 Attn: Stephen S. Harper - .510/893-1000 Fax: ` *510/446-1946 On behalf ofc Combustion Engtneering/Syntex Corp/Oshkosh Truck CorpJMeyers Chemicals/ Weils Fargo Bank/GIktden CoJSodthwestem Portland Cement Lafayette, Kumagai & Clarke, 100 Spear St, Suite 400, San Francisco, CA 94105 Attn: Kevin M. Clarke Fax: On behalf ofc Procter Gamble/Folger Coffee Co/KMart Corporation La Foliette, Johnson, De Haas, Fester Ames, 50 California Street 35th Floor, San Francisco, CA 94111, Attn: Joanne Rosendin Fax: On behalf ofc Grefco, Inc/General Refractories Co. La Foitette, Johnson, De Haas, Fester Ames, 50 California Street 35th Floor, San Francisco. CA 94111, Attn: Kelley Reid - Fax: 415/357-4600 415/896-0683 415/433-7610 415/392-7541 415/433-7610 415/392-7541 On behalf of: Gentex Corp. . Landels, Ripiey Diamond, 350 Steuart Street San Francisco, CA 94105-1250 Attn: Morgan Gilhuly Fax: On behalf oft Jit Simplct/Stanford University Hosp&i/Stanford University Lane Powell Spears Lubersky, Two Embarcadero Center, Suite 2330, San Francisco, CA 94111, Attn: Kevin C. Mayer Fax: 415/788-5000 415/788-7550 415/421-8624 415/421-8625 On behalf ofc Hercules, Inc./Mobil 03 CorpJHofmann CoJChevron/Ashland, Inc. . Larson Burnham, 1901 Harrison St, 11th Ft, Oakland 94612, Mailing: P.O. Box 119, 510/444-6800 Oakland, CA 94604, Attn: Walter Rundrn Fax: _5_1_0_/_8_3_5_-_6_6_6_6 dn behalf ofc D.W. Nicholson CorpJGotdan Gate Dtywaj.1, Inc/Stata Shingle Co/Jack Horton Dryw?II, fnci . McGuire & Hester/General Veneer fytfg. CoJHyatt Corp./Frank E.Conneii Son/Coast Sheet Metai/ J&H Marine industrial Engineering Co/Cairforriia Drywati CoJWafworth CoJPnidenfel insurance Co/ ' Carter Construction CoJDaniei Smith Pjasterfirg, focA/ictor Kemp Co.ZFrederickMeiswmket.lnc/ V., Whittaker CorpJBorg-WamerCorpjMannington MHIs/Hiiton Hotels Corp/CaDfomta Shingle & Shake Co/ "Goodman Lumber CoJBaker's Pride Oven Co^Inc/GreatWestern Bank/MedaiCon Carpets/Unrvar Corp/ Reynolds Metals CojWP-Hayward CoJFruehaufTrailer CorpJBorg-Wamer Automotive, Inc/ ' ' -CentralSi^ ~~"" ~-~r Le Bouef, Lamb, Greene MacRae, One Embarcadero Center, San Francisco, --'-----415^51-1100 _CA 9+111, Attn: Lorraine A. Barrabea'.f_--: ~';lc Fax: - 415/951-1180 On behalf ofc Alcoa Company ~ ` ........................ Lemieux O'Neill, 200 Norte Westlake Blvd., Suite 100, Westlake Village, CA91362-3755,Attn:TanLlCody ,-r ' 805/495-4770 Fax: 805/495-2787 `On behalf ofc OFCCO Construction, tnc (Oil Field Construdion Company, Inc) Lewis, D'Amato, Brisbojs &Jiisgaard, 221_North Figueroa Street Suite 1200, 213/250-1800 "Los'Angefes,' CA 90012, AtiihrSteven Mark :Faxr--213/250-7900 On behalf of: American Standard, Inc/Prudential Insurance V\ Liefaman, Rainer, & Walsh, 3255 Wilshtre Blvd., 12th Roor, Los Angeles, 213/387-0777 ` CA 90010, Attn: Craig Nelson - Fax: ' 213/383-6754 On behalf of: Riverside Cement Co. (Amcord, Inc.) tossing Elston, 100 Fast Sheet 25th Floor, San Francisco, CA 94105 415/882-4200 " Attn: Kevin Gray Fax: 415/882-4050 On behalf of: Hunt-Wesson, Inc. . Low, Ball Lynch, 601 California Street San Francisco, CA 94108 415/981-6630 ' Attn:CelesteM.Scott .. - Fax:, 415/982-1634 On behalfof; Beck Electric Suppty/JA. Sexauer/Tha Montague CojCroenigar & Co./Scctt.Company/ Moore Dry Dock Ca/EF. Mitehler/San Jose Drywall CorpJAllas Heating & Ventilating Co., IMJ Johnson & Maps Construction CoJDougiass Insulation Co., IncJThe Branson Schoot/Sono-Ceit CoJ MBL, Inc/John Ray CoJDyson-Ktssner-Maran CorpTBrown Sheet Metal & Mechanical/Caen CoJ Darcoid Company of Cafifomta/Peartis Auto Suppty, Inc. - -. Lynch, Loofbourrow, G3ardi Grummer, 50 Francisco Street, Suita 400, ' 415/397-2800 ' San Francisco, CA 94133, Attn: RobertV. Betette Fax: 415097-0937 On behalf oh CD. Ericson Co,, incJCalifomta State Automobile Association/Shamrock Materials, tncj Wright-Austin Co, tncJMasonita CorpJAP. Green Services, IncJArrteocan Bittrite, Inc/Swiiierton Walberg/ Van Bokkelen Cole CoJJ.C. Penney Cosine. . Mackenroth Ryan Jacobson Fong, 1610 Arden Way, Suite 250, Sacramento 95815, 916/924-1912 ` Mailing: P.O. Box255800, Sacramento. CA 95865, Attn: James R. Wright Fax: 916/923-3872 On behalf oh Deere Company < _ Marron, Reid Sheehy, 601 California Street Suite 1200, San Francisco, CA 415/434-0800 ' 94108, Attn: Michael Marron . Fax: 415/986-1374 On behalf oh Georgta-Parific/Coloniai Sugar & Refining, Ltd. _ McCutchen, Doyle, Brown & Enersen, Three Embarcadero Center, San Frandsco, 415/393-2000 " CA 94111 ,.Attn: Patricia Thrash Fax: 415/393-2286 On behalf oh Shapell Industries, IncJU.S. Steet/C&H Sugar CoJJames River It IncJAttantic Richfield/ American President Unes/McKesson CorpJCathoCc Healthcare West . McCutchen, Doyle, Brown Enersen, 1331 N. California Blvd., 5th R., Walnut Creek, 510/975-5331 " CA 94596, Mailing: P.O. Box V, Walnut Creek, CAS45S6, Attn: Susan A. Ogdfe Fax: 510/975-5390 On behalf oh Exxon Corp./Texaco, IncJCoastal WestVentures/Domtar Gypsum America, IncJ Bombantier, IncJAubum Technology, Jnc. . _ McGtynn, McLorg Ritchie, 177 Steuart St. SuSe 200, San Francisco, CA 94105 415/543-9000 Attn: Craig M. Stainbrook ` - Fax: 415/543-8300 On behalf oh Ross General Hcspital/The Clorax Co. <? _ Mdnemey & Dillon, One Kaiser Plaza, 18th Roor, Oakland, CA 94612 510/465-7100 Attn: Caret K. Watson Fax: 510/465-8556 On behalf oh University Mechanical Engineering Contractors _ McLemore, Collins Toschi, 200 Webster Street Suite 350, Oakland, CA 94607 510/835-3400 ~ Attn: Gregory M. Doyle . Fax: 510/835-7800 On behalf oh Northwestern Equipment Supply Co., Inc. - McNamara, Houston, Dodge, McClure Ney, 1211 Newell, Suite 202, Walnut Creek, 510/939-5330 ~ Mailing: P.O. Box 5288, Walnut Creek, CA 94596; Attn: Thomas E. Pfafzer "Fax: - 510/939-0203 - On behalf oh St Joseph's Hospital/Congoleum/Dap, IncJPlibrico Sales Service, IncJSutter Memorial . Hospftai/Sutter General Hospital/FMC CorpJDameron Hospital/American Tenazzo Co. ' --- McNamara, Houston,Dodge,McCtura Ney, 1211 Newell, Suite 202, WalnutCreek, - .510/939-5330 - _ -Mafling: PD. Box 5288, Walnut Creek,CA 94596, Ato: Douglas C. McClure ..... . _Fax .,.,.510/939-0203 _ ... _oiTbehaifotUniroyaI,tn !" I " . ~V 1" ~ ' . T "" ' ~""7~ - _ Mendes~ Mount 725 South Figueroa Street 19th Floor, Los Angeles, CA 90017 ' 213/955-7700 -f'Attn: Suzanne N. McNulty/Richard Nelson ' Fax 213/955-7725 -.On behalf of: Lockheed CorpJBP Chemicals (HfTCO)/Curfis-WrightCorp. .......................... . * Miller, Morton, Cailiat Nevis, 50 W. San Fernando St, Suita 1300, San Jose, 408/2S2-1765 CA 95113, Attru Pamela j.SIberstein . ' - Fax - 408/292-4484 ' & --OribehalfohB.T.MandniCo^ tncJBrookman Co. -- -- -. ------- _ JMisciagna Coiombatto, 27 Maiden Lane, 4th Roor, San Francisco, CA 94108 415/391-^6182 ^FAttnrP. Richard Coiombatto ^Fax 5rjf15/391-2904 ,~-~Z ... On behalf oh Metalciad Insulation Co. Mitchell, SUberberg 4 Knupp, 11377 West Olympic Boulevard, Los Angeles, 310/312-2000 CA 30064-1683. Attn: Hayward J. Kaiser Fas 310/312-3100 On behalf of: Shapco, Inc. Moor* 4 Associates, One Bnbarcadaro Center, Suite 1200, San Franc-sco, CA84111 . 415/384-7004 Attn: Robert Moore Fax: 415/981-1582 On behalf oft. Claremont Hotel Corporation ' Morgensfein 4 JubeHrer, One Market Plaza, SpearStreet.Tower, 32nd Floor, 415/896-0666 San Francisco, CA 94105,Attn: Charles LaGrave ' Fax 415/896-5592 On behalf oft Owens-UGno&Crosby Steam 4 Valve Co./Cathedral HOI Hotel, IncJSan Francisco Ladies' Protection 4 Relief Sodetyrtibbey-Owans-Ford/ra Aerospace/Sammons/Dbtoh Bofler Works, Inc. Morton 4 Lacy, Three Embarcadero Center. Suite 2280, San Francisco. CA 34111 415/236-9000 Attn: Alan EL Lacy Fax 415/398-3205 On behalf oft EH. O'Neill Co., tnc/J-E. Staigetwald .. Hunger, ToKes 4 Olson, 33 New Montgomery Tower, 19th Floor, San Francisco; - 41 S/512-4000 CA 94105-9781, Atbu M. ESzabeth Deane Fax 415/512-4077 On behalf oft Tennessee Gas Pipeline Company ______ NIcol 4 Isaac, 4002 22nd Street, San Francisco, CA 94114, Attn: Usa Nfcof On behalf oft California Safety 4 Supply Co. . 415/821-4497 Fax 415/821-0791 ______ O'Brien 4 Hammond, 220 Sansome St, 7th Floor, San Franosco, CA 94104 415/362-2040 Attn: James D. Hammond Fax 415/362-1050 On behalf oft LaSalle Deitch Co., IncJUniversal Foods CorpTNabisco Brands/B.F. Goodrich ______ O'Connor, Cohn, Dillon 4 Barr, 101 Howard St, 5th Floor, San Franosco, CA 94105 415/281-8888 Attn: Mark Oium . ' Fax 415/281-8890 On behalf oft Federal-Mogul CorpA/allen Safety Supply CoJAlliedSignal (Allied Chemicai)/Vapor CorpJ Walgreen Co. Orrick, Herrington 4 Sutcliffe. 400 Sansome Street San Francisco, CA 94111 415/392-1122 Attn: James R. Madison '- Fax 415/773-5759 On behalf oft Grove Valve & Regulator Co. . I__ Otis 4 Hogan, One Maritime Plaza, Suite 1600, San Francisco, CA 94111-3506 415/362-4442 Attn: J. Morrow Otis Fax 415/362-7332 On behalf oft WT1 Rust Holdings, IncJRust Industrial Services, incJRalph M. Parsons Co. ______ Pace Drywall, Legal Department P.O. Box 573, Concord, CA 94522 ; 510/602-0900. Fax ______ Pacific Beil Legal Dept, 140 New Montgomery Street Suite 1015, San Francisco, CA 94105, Attn: Gerard J.Donnelian - Fax 510/602-0905 415/542-2880, 415/882-4458 ______ Paetzold, White 4 Brodsky. 101 California St, Suite 1875, San Francisco, CA 94104 415/249-0966 Attn: Cheryl Brodsky ' Fax 415/249-0964 On behalf oft Chiquita Brands/American President Lines/EJ. Barteils.Coj'Phelps Dodge industries/ Todd Shipyards ______ Pave, McCord, Jacobs 4 Berkes, 15303 Ventura Boulevard, Suite 1400, . 818/783-8820 Sherman Oaks, CA 91403, Attn: Mark W. Lau Fax 818/78^0959 _ On behalf oft California Portland Cement CoJCalMat Co^Industrial Asphalt ______ Perkins Core, 1999 Avenue ofthe Stars, 9th Floor, Los Angeles,' CA90067-6109 310/788-9900 - -.--Attn:Sibyl D.Marshall -- ---i-v ^ - Fax .310/788-3399 ' ' On behalf oft Custodts-Cottrell, Inc. ' - PiUsbury, Madison 4 Sutra,225 Bush St, San Francisco 94104; Mailing: P.O. Box7880, 415/983-1000 ------------San Ftandscq~CA94120,Attn:MarteBasst;_______ J...-1.1 ' ... Fax _.415/38-2096_ * On behalf oft Beiftlehem Steel Corp. PiUsbury, Madtson'4 Sutra, 400 Captol Mall, Suite 1700, Sacramento, CA 95814 916/441-0868 "Attn: Benjamin Webster/Frank Sieglfe ........ Fax 916/441-3583 ' On behalf oft Aerojet General Corp. ' " ' _ _ Pittsburgh Coming Corporation, 800 Presque Isle Dr., Pittsburgh, PA 15239 ' 412/733-3838 Attn: Gerald A. DeSimone ~ - - Fax 412/733-5849 _ Pond, Shjeflo 4 WohL 1730 S. E Camino Real, 6th Floor,San Mateo, CA 94402 . .415/341-2901 . . Attn: Michael A. Fox ............ ....................... ...............1 '___ Fax 415/341-2258 =On Behalf oftThorpe Insulation Co. --'xxcxrrrr Popelka, Allard, McCawan & Bondonno, 160 W. Santa Clara St, 12th Root, 408/298-6611 \ San Jose, CA 95113-1721, Attn: John P. Cardosi Fax: . 408/275-0814 On behalf oft Grampofira & Company . Porter, Scott, Weiberg & Oeiehant, 350 Unfversiiy Avenue, Suita 200, Sacramento, 81S/92S-1431 ' CA 95865, Attn: Eltsa Ungerman . Rax: 916/327-3705 On behalf of: Economy Lumber CojMJnton's Lumber & Supply Co/ANCO Insulations, Inc. ' . Porter, Scott, Weiberg & Oeiehant, 350 University Avenue, Suite 200, Sacramento, 916/329-1461 ` CA 35865, Attn: Craig A. Caldwell ' Fax: 916/327-3706 On behalf of: Van Housen Auto Parts '' Pray, Price, Williams & Russell, 555 East Ocean Boulevard, Sufe 810. 310/436-1231 ' Long Beach, CA 90802-5055, Attn: Bruce Bothwelt Far 310/435-6384 On behalf of: Bay Cities Crane & Rigging, Inc. . Freuss, Walker & Shanagher, 595 Market St, 16th Floor, San Francisco, CA 94105 - .415/978-2600 " Attn: Thomas W. Pulliam, Jr. Far ',415/378-2613 On behalf of: American Honda Motor Co., IncJMarsh & McLennan, IncJLac cfAmiante du Quebec, Uee/ Hottingsowrth & Vose/Monsanto CoJHobartCorp/Federated Metals-ASARCO - _ Prindte, Decker AAmaro, 369 Pine Street, Suite 800, San Frandsco,CA 94104 415/788-8354 Attn: Mary Kirk HiUyard Far 415/788-3625 ' On behalf of: Auburn Manufacturing CoJAB. Boyd CoJArgo International CorpJBodeGravel CoJ Wheeler Protective AppareW.T. Thorpe, IncJJ.T. Thorpe & Son, tnc/Hajoca CorpMM. Detrick Co/ Frederick Metswinkel, inc/D. Cummins Corp/Gerber Products, Inc/Syd Carpenter Marine Contractors/ Pacific Bell/Lockheed CorpJTri Valley Growers/Playboy Enterprees/Mervyn's/Gnion Lumber CoJFeuer CorpJ Gangi Brothers'Packing Co/Henty Vogt Machine Co/Geyser Peak Winery/Famlan CorpJSauthem Tate/ American Housing Guild/Bird CorpJBoise Cascade/Mayta & Jensen/Powerfine Oil Co/Etemit IncJ American Biitrite, Inc/Dean's Material. Inc. d/b/a Construction Material Suppliers, Inc/Hayward Lumber CoJ Kaiser Steel Rasources/Champion Industrial Contractors/Singer Safety CoJPoweriine Oil CoJ Robertshaw Controls Co/Seal Methods, IncJPillar Industries, IncJDel Webb Corporation Prusik, Selby, Daley & Swan. 303 W. Madison St, Suite 1600, Chicago, 1L 60606 312/553-4700 On behalf oft Wheeler Protective Apparel . Fax: 312/553-0332 Raifman & Edwards, 131 Steuart Street Fourth Roor, San Francisco, CA 94105-1230 415/284-6700 Attn: Jon Logan Edwards -- Fax: 415/284-6701 On behalf oft American Crane & Equipment Corporation : .. _ Rankin, Sproat & Pollack, 1800 Harrison St, Suite 1616, Oakland, 94612, Mailing: 510/465-3322 " P.O. Box 28755, Oakland, CA 94604, Attn: Thomas A Trapani - Fax: S1Q/465-3006 On behalf oft Peninsula Hospital/Califomia Pacific Medical Center/Ralph K. Davies Medical Center/ ' St Mary's Hospital/St Luke's Hospital/John Muir HospSal/Summit Medical Center/Alta Bates Hospital/ ML Zion Hospital/St Francs Hospital/Sutter Health Pacific/Sutter Memorial Hospital/Sutter General Hospital/ Reisinger & McAuley, 1050 Northgate Dr., Suite One, San Rafael, CA 94903 415/499-1033 Attn: Jerry L WflEams Fax 415/499-0329 On behalf oft San Pablo Plumbing CoJNoble Auto Parts/J.G. MacPhee Co. _ Rice, Fowled Booth & Banning, 275 Battery Street 27th Roor, San Francisco, 415/339-9191 CA94111, Attn:M.Felicia Gay . . ..... Fax 415/399-8192 ' On behalf oft Mobil O0 Corporafion/borr-OGver, Ina/Matthew G. Norton Co.' _ Rivfcin, Radler 4. Kramer. Pest Office Box 14609, Santa Rosa. CA 95402 '-707/576-8033" Attn: Christopher A Crevasse . . Fax 707/576-7955 On behalfoft Kimberly-Clark CorpJDAR. Industrial Products, Inc. l *. -v. z: - ~ _ Ropers, Majeskf, Kohn & Bentley, 670 Howard Street San Francisco, CA 94105 . _:41S543-4800_ - Attn: John Curran Ladd r-C. . . T. : ,T:: ~;IFax ~7415/5'I2-1574 " ~~ On behalf oft The Cannery/Cyprus Aniax Minerals Co/Calfox, Inc/Generat American Transportation Corp/ ' Porter Warner Industries, tnc/E.V. Roberts 4 Associates, Inc/The Bank of CaUfarraa/GrinneH CorpJ . _____ Embarcadera Center Assocrates/Wesfinghouse Bedric Corp/Rome Cable Carp/Dfnwiddia Construction/ - Genuine Parts Co/Glas-Cal Apparatus Co/OakMB Improvement Co/Oahu Sugar Co/Lucfcy Stares/Prudential Insurance Company ofAmgrica/CaCfomia Safety & Supply .. . ' . *. . V~~ Mark H. Rosenthal, EseffiftO-CatifoiTuu St! 30th Floor, San Francisco. CA 9411 f ;.415/986-1364 ; / On behalf oft Crown Cork&Seal 425 sSc>................ J____ Fax _415/36IM615 ___J '.'=\ ' ---r .,<^1 ,rN&>, *-- :rw } Rust, Armenia, Schwartz, Lamb & Blits, Post Office Box 41958, Sacramento, 316/972-8300 ) CA 95841, Attn; Duane Skelton Far: 916/972-7878 On behalf of: Melrose Lumber Supply/Tynan Lumbar Co., InoMnton's Lumber* Supply S&p Company, 100 Shoreline Highway, Buildmg B, Suite 315, MW Valley, CA 34941 415/332-0550 ' Attn: WaSamM. Bitting Far 415/332-9023 On behalf oft General Brewing CojLucJcy Lager Brewing Co.. . St Clair, McFetridge & Griffin, One Montgomery St, Suita 1400, San Francisco, . 415/421-2462 ' CA 94104, Attn: Anthony Griffin Far 415/421-2462 On behalfof Bank ofAmerica NT & SA St Peter* Cooper, Three Embarcadero Center, Suita 2900, San Francfeco, CA 94111 415/955-0700 ' Attn: Michael St Peter . Far 415/955-0711 On behalf oh ACandS, Inc. . Sack and Associates, 1433 Webster Street Su3e 200, Oakland, CA 94612 - 510/444-6453 ' Attn: William S. MOTer -Far 510/444-3753 On behalf of. Ralph M. Parsons CoJChicago Bridge & Iron Ca . Sainick A Cote', 190 Newport Center Drive, Suite 100, Newport Beach, CA 92660 714/644-9400 Attn: Frederick B. Sainick On behalf oh San Joaquin Refining ' * ` . Far 714/644-1142 . Samaha, Grogin, Stuiberg, 35 North Lake Avenue, Suite 810, Pasadena, CA . 818/584-1388 ' 91101-1855, Attmjhomas J. Samaha . Far 818/584-6664 On behalf of Hood Corporation ` . Sarrail, Lynch & Halt, 44 Montgomery Street 34th Floor, San Francisco, CA 94104 .415/398-2404 Attn: Brian D. Harrison ' Far 415/391-9076 On behalf oh Safeway, Inc. _ Scadden, Hamilton * Ryan, 580 California St, Suite 140Q, San Francisco. CA 94104 415/362-5116 Attn: Greg Mitchell Far 415/364-4214 On behalf of: Supra, IncJTrans-European Motors/Bliott Co/Excetsior, IncJBank of California/ Dover Resources/EG*G Sealol, IncVAIfred Conhagen, IncTFoster Wheeler Corpj'Riley Stoker Carpi Liberty Mutual Insurance CoA/aHey Nitrogen Producers/Greene Tweed Co./Southern Cafifomia Jobbers/ National Auto Parts/H.J.-Heinz CorpJNestle Food CoiDurametallic CorpTColgate-Palmofive/ United Technologies CorpJRobertson-Caca CorpTCIayton Industries ' _ Schaffer & Lax, 5757 Wilshire Blvd., Suite 600, Los Angeles, CA 90036 213/934-4300. Attn: Kevin J. McNaughton Far 2137931-5630 On behalf of. U.S. Mineral Products Co. _ Schofield & Schiller, 100 Pringle Ave., Suite 510, Walnut Creek, CA 94596 510/934-3600 ' Attn: Carol Meyer 57o- On behalf of Keily-Moore Paint Co./Regents of the University of Caiifomta/Airport Auto Parts, Inc./Farmers Underwriters Assocafion/Pedc Jones Construction CoJC.L. Peck Contractor ' Schuler*. Kessst 3435 Witshrre Boulevard, Suite 1970, Los Angeles, CA90010-1S01 213/365-0924 ' Attn: Elizabeth M.Kessel Far 213/365-0933 On behalf of Aluma Systems * "- . .* Schwabe, Williamson * Wyatt.1211 SW Filth Ave., Suites 1600-1950, Portland, - ; 503/222-9981 ~ OR 97204-3795, Attn: MargaretHoffmanFar " 501/796-2900 On behalfof Oregon StaeTMfe ^ : --- -1 ~ -------------- ;------------ Sedgwick, Detert, Moran * Arnold, One Embarcadero Center, 16th Floor, . 415/781-7900 ~ San Francsco, CA 94111,Attn: HollyA. Harris ' V -;--~Far '> VlS/781-2635 On behalf of Scandura, IncJHennessy Industries, IncJIngalls ShipbuiMng/Standard OilofCalifornia/' - ... .. Shell Oil CoTSoco-Lynch CorpJGeneral Bectric CoiPhilfips Peiroteum CoJPacificGas'S Bectric Co/ Chevron, U.SJL, IncJGtass Containers CorpTConsolidated lnsulation/Hawaan Bectric/Siena Pacific/ CPCtntemafional/GulfOff lr . c ' Sedgwick, Detert, Moran S Arnold, 801 South Figueroa street 18th Boor, Los Angeles, 213/426-6900 ' CA 90017-5556, Attn: JahrrR; Surge' Far 213/426-6921 . On behalf of Caterpillar, Inc. ---... .. - ........................... -............ . . . _' Seyfarth, Shaw, Fairweather* Geraldson,T01 California Street Suite 2900, ~ 415/397-2823 ' San Francisco,CA94111,Attn:Peter E.Romo - ..... ^^.^Far '415/397-3549 . ~On behalf of ManfotrCorpJNwpoitNews ShfpbmTding"& DryDocfcCoTBayBecking Co.,-Jnc. ----^=f: -........... - n -- *1SV _ _ Daniel M. Shapiro, Attorney at Law, 333 South Grand Ave,, Suite 2850, Los Angeles, 213/825*7400 CA 90071 Fax: 213/825-0303 On behalf of: Calmar Distributing Co., tnc. Shea & Gardner, 1800 Massachusetts Avenue N.W., Washington, D.C. 20036 . Attn: Laura Quinn On behalf oft Rockwell International . Sheppard, Muffin, Richter & Hampton; Four Embarcadero Center, 17th Floor, Fax: 202/828-2000 202/828-2195 415/434-4914 San Francisco, CA 94111, Attn: Gary J. Nevoto Fax: 415/434-3S47 On behaifoft American Optical Co. Sheppard, Muffin, Richter & Hampton, Four Embarcadero Carter, 17th Root, San Frandsco, CA 94111, Attn: John F. Runkef, Jr. Fax: 415/434-4914 415/434-3947 On behalf aft American National Can Co. ' Sidley 4 Austin, 555 West Fifth Street Los Angeles, CA 90013-1010 . 213/896-6000 Attn: Alan Au Fax: 213/898-6600 On behalf oft Midwest Fewer Systems Sinclair & Hill, Post Office Box 992710, Redding, CA 36099-2710 Attn: Craig A. Sinclair (100 e. Cypress Ave., Suita 200) 918/228-9700 Fax: 916/226-9481 On behalf oft Mercy Metfical Center/Mercy Hospital of Redding Skeef, Henke, Evenson & Roberts, 900 Fourth Avenue, Sufte 3801, Seattle, WA 98164, Attn: Eric Richter ` 208/823-1031 Fax: 208/828-2033 On behalf oft Olympic Steamship Co. Sorem & Pastore, 2565 Camlno def Rio South, Sufte 101, San Diego, CA 92108 619/574-1545 Attn: Joseph A. Pasture ' . Fax: 619/574-1200 On behalf oft Fryer-Knowles, Inc. Southern Pacific Transportation Co.'Law Department, 10860 Gold Center Dr., 916/789-5824 Sufte410, Rancho Cordova, CA95S7G, Attn: Michael L Johnson Fax: 916/789-5827 Stark, Welts, Rahl, Schwartz 4 Schieffer, 1999 Harrison Street, Suite 1300, 510/834-2200 Oakland, CA 94612, Attn: May Lee Tong Fax: 510/763-5121 On behalf of. Cassiar Mining Carp. . Steele & Sales, P.C.. 700 5th Avenue, Suite 5511, Seattle, WA 98104 Attn: Katherine M. Steele ~ 206/682-2202 Fax: 206/682-1224 On behalf oft E.J. Bartells Co. Steefel, Levitt & Weiss, One Embarcadero Center, Sufte 2900, San Francisco, 415/788-0900 ` CA 94111, Attn: Barry W. Lee Fax: 415/788-2019 On behalf oft Cal-Steam/Westbume Supply, tncJMoran Supply/Plumbers Supply Sterling & Clack, 101 Howard Street Suite 400, San Francisco, CA 94105 415/543-5300 ` ' Attn: Rex M. Clack Fax: 415/543-3335 On behalf oft Olympic Steamship Co./Pope &. Talbot Inc. _ Stevens, Drummond & Gifford, 1910 Olympic Boulevard, Sutie 250, Walnut Creek, - 510/944-5550 * CA 94596, Attn: David A. Gifforcf . ... . Fax: 510/256-9669 On behalf oft. North American Refractories CoJAetna Rubber & Suppty/Asbestos Corporation, UdJx . ^Wagner Electric CarpJBel! Asbestos/Azrock Industries/CooperIndustries, tnc. .. Francis Si Stiitman,.Attorney at Law; 1601 Bayshora Highway, Sufte 3Q1r . .415/692-7492 'Burt!ngame~CA94010 :T~.: ' 1 ` ~'-v---r-"-------- Fax: 415/692-9144- . On behalf oft Montgomery, Ward & Co. _ . . ____________"-Stumbos W& nMiaaswo*n,t 21I5V1 *RVivtVeIr Plaza Drv SufelOO, Sacramenf--o--T; C-A-.-9-5-8-3-3 ~ -- --=---9--167567-8211 ^=z=zzxMailinyPn.OA:.BBmJ^cO8r6N8J^' Sa^merifofcCA.9O5C8O0H4/tfcAAHawn*:DBr*rarl`dTl'iTftrlritoOnOiars--.5^^^~f=^--F&a. x:^-=-991;`6/567-8212 ' " rrr--.-OWUtt ubenhtoaulf owift F ruehauf CorpJKetsay-Hayes'Co.' ------ --'--XT - ~. " ---- . , , Sturgeon, iKre.nlle.r., nPuh:inlli;ps- & Gee, 388 Market SSltrraeoett RSuuritfoe 67Q, SSaann PFrraannr*d=sac~o-i, ' '"''41i5r/95543800 CA941t1,Ato:Brockb.Phinrpsv==^r.-r ::^.-" ' ` . Fax r:415/355-0810 On behalfoft Atchfeon, Topeka 4 Santa Fe Railway CoJBuriinglon Northern RaHroad Co. J . Tarkington, O'Connor & O'Neill, One Market Plaza, Spear Street Tower, 41st Roar, 415/777-5501 San Frandsco, CA 94105, Aftrn Deborah Ltndblom - iOn behalfoft Western Brafce/Fricfion, fnc/imperial HoltyCorp. ^iotly Sugar) Fax . -415/546-4962 .^Thayer, Harvey, Hodder& Gregersonv1100 Fourteenth Street Suite F, Modesto, ---- .--209/523-3300 ~CA 95353 (MaD: P.a.-Box-3465r'Mo3esto, CA 95353), AttnrJanet B. Hodder -^Fax~-&209/523-3393 ' _On behalf oft Rosevflie Tefephone_Campany________________ ___ ________ ^___ VT . Thaien, Marrin, Johnson & Bridges, Two Embarcadera Canter, San Frandsco, 415/392-6320 T CA 941 tl, Alta: Jennffer A. Kuenster Far 415/421-1063 On behalf oh Kaiser Aeratecft/Kaiser Aluminum & Chemical CorpJBechtei CorpJSequoia Ventures, Inci Robert E- McKee, InciKaisar Center, InciMack Trucks, tncJFremont Group, inc. . Thelen, Marrin, Johnson & Bridges, 333 South Grand Avenue, 34th Floor, 213/621-9800 Los Angeles, CA 90071, Attn: Paul Lax Far 213/623-4742 * On betelfofcM.W. Kellogg/Dresser Industries*Inc. - ' Thompson & Heller, 400 Captol Malt, 26th Floor, Sacramento, CA 95B14 . 916/498-7300 Attn: PhflSp Bonolto Far 916/4SS-7350 On behalf oft Velkimoid, Inc/Hopeman Brothers/GreatLakes Carbon Corp/Hcorltte Insurance Coi Dravo Ccrporafion/Federated Department Stores ' . . ______ Tilly & Graves, 500 Washington St, Suite San Francisco, CA 94111 Attn; Patrick O'Keefe 300 415/955-8925 Far 415/955-3933 On behalf oh Owens-Coming Fibergfas Carp. ______ Time OB Company, P-O. Sox 2447, Seattle, WA 98124 206/285-2400 Attn: Ron Kokesh ' - Far 206/286-4488 ______ TIMEC Company, 155 Corporate Place, Vallejo,.CA 9459Q, Attn: BrentA. Babow 707/642-2222 . (The Industrial Maintenance Engineering Co.) Far 707/646-2719 ______ TitcheU, Maftzman, Mark, Bass, Ohleyer & MIshel, 650 California St, 29th Floor, 415/392-5600 San Francsco, CA 94108, Attn: Philip 8, Bass/Richard C.Insalaco On behalf oh American Brass & Iron Foundry '" Far 415/981-5027 ' ______ Vogl & Meredith, 456 Montgomery St, 20th Floor, San Frandsco, CA 94104 415/398-0200 Attn: Jean Yeh - Far 415/398-2820 On behalf oh American Asbestos CoJPadSc Pipe/ San Mateo Lumber CoJAvocet Enterprises, inci Pacific Supply CoiW.EL Mushet Co. ______ Waisworth, Franklin, Bevins & McCall, 580 California Street Suite 1335, 415/781-7072 San Frandsco, CA 94104, Attn: Robert M. Channel Far 415/391-6258 . On behalf oh Bishop Wholesale, InciFncdon Materials, JnciCalifomia Builders Hardware/Dowman Products/ Pacific Holiday Towers, UdJHamiiton Materials/Seiby, Battersby & Co./Daniel Smith Plastering, Inci Western Water Works/Southem California Edison CoiThomas Dee Engineering CoiQuintec Industries/ Rite Engineering Manufecturing/Stanley Folb.-lncJK.R. Anderson/American Chemet CorpJSupreme . Auto Parts/Saberhagen Holdings, inc. (The Brower Co.yCarter CoTSan Diego Gas & Seciric/Bondex . . Intemafioriai/Custom BuilcSng Producis/Martin Madsen CoiBaltimore Ennis Land CoJMacAulay Foundry, ' InciW.W. Henry Co. - ______ Waisworth, Franklin, Bevins &. McCall, 1 City Boulevard West Suite 308, 714/634-2522 Orange, CA 92668-3604, Attn: Michael T. McCall Far 714/634-0686 On behalf of. Gibson-Homans ' _____ White, Gorman & Baker, One Market Plaza, Spear Street Tower, 3th Floor, . 415/541-3720 San Frandsco, CA 94105, Attn: Margaret T. Gorman -- Far 415/541-3738 - On behalf oh 870 Market Street Assodates/Anchor Brewing CoJDiana Fruit CoiAmerican Energy . . Products/Hales & Symons/Hasfceli CorpJBig B Lumberteria/Lindsay international, InciStructural r:-- - -Caatfng. fncjEtiottG/ove CoiGeome P.ReiritiesCo.. 1 ' " '' I-WilCanis. RomanskL Potverari & Skeiton, 152 North Third St, Suita 600, 408/275-8262 ' ~ San'Jbse,CA95112,Attn:Alan J. Zapata ' Far 408/294^6707 .. . ... On behatfof. EpoxyTite CorpJBay Rubber CaiYrueta Qrywafi & Painting/Basco Drywall & Painting-Coi ' -MecTPackS^'SSupply .. . --^-Wilson. Efeer: MoskowitzTEdefinan & Dicker,.650 California Street, 14th Floor, ^ 415/433-0990 ' --San Francseo, CA`94108, Attn: Colleen A. Peck 5 .r -Far '415/434-1370 '-' _ . On behalf oh Kubota CorpJDurabla Mfg. Co., InciAsbestos Products Mfg. CcrpJH&A Construction Carpi' - - - - Asbestospray --'-1 --- Law Offices ofRobert fC Wright, 301 N. Lake Ave., Suite 700,'Pasadena, CA 91101 818/796-2664 On behalf oh The Budd Company ' " "................... Far 818/796-1601 ___ .Wright, Robinson, Mceammon, Osthimer& Tatum, 44 Montgomery St, 18th Roor, 415/391-7111 J * TSan Francfeco. CA 94104, Attn: Mark P. Krinsfcy -Onb. ehalf oh aSan. Fra--n--d-s--c--o-_G__r_a__vAel-C/oI iJ.S. Guerin. Ca_-- Far 415/391-8766 If . - irrrWrigRt^Robihson-, McC^mrnon.Osthimer&Tatunv&f Montgomery StJ3th Floor, ; 415/391-7111 San Frandsco, CA 94104, Attn: Myles E. Fladager " ' ' ~ Far" 415/391-8766 .On behalfoh Freighlliner Cofp.-------- - ~;z rt4