Document n98qMnj3K78VyQyXwnbkG2gj6

PLAINTIFF'S EXHIBIT WOLF, BLOCK, SCHORR and SOLIS-COHEN By: Anthony S. Minisi, Barry M. Klayman Identification Nos. 03082, 26097 Twelfth Floor Packard Building Attorneys For Defendant, Philadelphia, Pennsylvania 19102 Pittsburgh Corning (215) 977-2000 Corporation ^ VERNELL LONDON, Executrix of the Estate of BIRK REED : . . PHILADELPHIA COUNTY COURT OF COMMON PLEAS V. NICOLET INDUSTRIES, INC., et al. MAY TERM, 198 3 NO. 6849 ( 2268) A*SBESTOS CASE ANSWERS OF DEFENDANT, MAREMONT CORPORATION, PRODUCT IDENTIFICATION INTERROGATORIES Pittsburgh Corning Corporation directs these Interrogatories to all defendants pursuant to Rule 4005 of the Pennsylvania Rules of Civil Procedure. DEFINITIONS 1. "Person" shall mean an individual person, a corporation, partnership, or any other kind of entity. 2. The words "document" or "documents" shall have % the same meaning and scope as in Rule 4009 of the Pennsylvania Rules of Civil Procedure and shall include, without limitation, any written, printed, recorded or graphic matter or computer input or output, however produced or reproduced, that: (a) are now or were formerly in your possession, custody or control; or (b) are known or believed to be responsive to these interrogatories, regardless of who has or formerly had custody, possession, or control. 3. (a) "Identify" and "identity", when used with reference to a natural person, means to state his full name, present or last known address, present or last known title, position or business affiliation, his title, position or business affiliation at the time in question and a general description of his duties or the business in which he is engaged. (b) "Identify" and "identity", when used with respect to any other entity, means to state its full name, the address of its principal place of business and the name of its chief executive officers. (c) "Identify" and "identity", when used with respect to a document, means to state the name or title of the document, the type of document (e.g. letter, memorandum, tele gram, computer input or output, chart, etc.), its date, the person(s) who authored it, the person(s) who signed it, the person(s) to whom it was addressed, the person(s) to whom it was sent, its present location and its present custodian. If any such document was, but is no longer, in plaintiff(s') possession or subject to its control, state what disposition * was made of it and explain the circumstances surrounding, and the authorizing for, such disposition and the date or approximate date thereof. In the event that the document is produced in accordance with the Request for the Production of Documents filed herewith, then such production shall be sufficient identification of such document. 2- - INTERROGATORIES 1. Do you claim that plaintiff(s) worked with or was/were exposed to any materials or products containing asbestos which were produced by Pittsburgh Corning Corporation, Inc.? Yes. 2. Name specifically and describe in detail the materials or products produced by Pittsburgh Corning Corporation with which plaintiff(s) worked or to which plaintiff(s) was/were exposed. At Sun Ship Company, Chester, Pennsylvania as alleged in Paragraph 6 of plaintiff's Complaint. Investigation is continuing and this Answer will be supplemented if necessary. 3- - 3. For each material or product named in the preceding Interrogatory, state the following: (a) the dates of plaintiff(s') exposure to each particular material or product; ' Answering defendant believes plaintiff was exposed to 'insulation products of Pittsburgh-Corning in 1943. (b) the exact location at which plaintiff(s) was/were exposed to each particular material or product; See answer to #3 (a) . 4- - (c) the particular job which plaintiff(s) was/were performing at the time of each exposure; Unknown. i (d) the purpose for which each Pittsburgh Corning product or material was used at the time of each exposure. Unknown. 5- - 4. Has/have plaintiff(s) ever indicated in any manner that he/they has/have used or been exposed to any Pittsburgh Corning Corporation product or material? See Complaint. 5. Give complete details of any communication, oral or written, made by plaintiff(s) that you contend demonstrates that he/they was/were exposed to any Pittsburgh Corning Corporation product or material. Unknown. 6- - V ' 6. List all individuals who have any information regarding the allegation that plaintiff(s) was/were exposed to or worked with any asbestos-containing material or product manufactured by Pittsburgh Corning Corporation. Unknown. 7. Set forth all details of information possessed by the individuals named in the preceding Interrogatory. Not applicable. SWEENEY, SHEEHAN & SPENCER U)uW' By_ Walter Sr^Jenkins Attorney for Maremont Corporation OF COUNSEL: Anthony#*. Mini go. Barry M. Klayman Attorney for Defendant, Pittsburgh Corning Corp. * WOLF, BLOCK, SCHORR and SOLIS-COHEN Twelfth Floor Packard Building Philadelphia, Pennsylvania 19102 (215) 977-2000 7- - VERIFICATION WALTER S. JENKINS, ESQUIRE, hereby states that he is the attorney in this action and verifies that the statements made in the foregoing Pleading are true and correct to the best of his `I knowledge, information and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsifications to authorities. DATE: March 8, 1984 WALTER S.; JENKINS Donald j. P. Sweeney M. landon spencer George d. Sheehan p Counsel LAW OFFICES Sweeney, Sheehan & Spencer A PROFESSIONAL CORPORATION 19th FLCDR - THREE PENN CENTER PLAZA PHILADELPHIA, PENNSYLVANIA 19102 (215) S63-9B11 March 8, 1984 WALTER S. JENKINS GEORGE D. Sheehan, jr Thomas l. delevie Dennis L. Platt DANIEL F. MONAHAN peter I. Hahn ROBERT B. GOODYEAR Yvonne D. bach PETER CHALONER JOSEPH L. FELICIANI WARREN E. VOTER Anthony Minisi, Esquire Wolf, Block, Schorr & Solis-Cohen 12th Floor, Packard Building Philadelphia, PA 19102 RE: London V. MAREMONT, et al MAY TERM, 1983, NO. 6849 Our File #RG-1299_____________ Dear Mr. Minisi: Enclosed you will please find a copy of the Answer of Defendant, Maremont Corporation, to Product Identification Inter rogatories of Defendant, Pittsburgh-Corning Corporation, the original of which has been duly filed with the Court. . Very truly yours, SWEENEY, SHEEHAN & SPENCER By Walter S. Jenkins WSJ/gfg Enclosure cc: All Counsel (w/encl.)