Document npbq5OQMOqBXG68eD4111R8m1

PLAINTIFF'S EXHIBIT UC-205J CAUSE NO. CC9914101E PATRICIA ANN MCDONALD VS. GAF CORPORATION, ET AL. IN THE COUNTY COURT AT LAW NO. 5 DALLAS COUNTY, TEXAS DEFENDANT UNION CARBIDE CORPORATION'S OBJECTIONS AND ANSWERS TO PLAINTIFFS SECOND SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION AND FIRST REQUEST FOR ADMISSIONS TO: Plaintiff, Patricia Ann McDonald, by and through her attorney of record, Stephen Johnston, Baron & Budd, The Centrum, 3102 Oak Lawn Ave., Suite 1100, Dallas, Texas 75219. COMES NOW, Defendant Union Carbide Corporation, and makes and serves this its Objections and Answers to Plaintiff Patricia Ann McDonald's Second Set of Interrogatories, Request for Production and Request for Admissions. Respectfully submitted, DeHAY & ELLISTON, L.L.P. 3500 Bank of America Plaza 901 Main Street Dallas, TX 75202 (214)2102400 (214) 2102500 (telecopier) By; GARY D. ELLISTON State Bar No. 06584700 PAUL E. HAMILTON State Bar No. 08838800 ATTORNEYS FOR DEFENDANT UNION CARBIDE CORPORATION ___ DEFENDANT UNION CARBIDE CORPORATION'S OBJECTIONS AND ANSWERS TO PLAINTIFFS SECOND SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION AND FIRST REQUEST FOR ADMISSIONS Page 1 CERTIFICATE OF SERVICE I do hereby certify, that on this date, a true and correct copy of the above and foregoing Answers to Plaintiffs' Second Set of Interrogatories and Request for Production was forwarded via certified mail, return receipt requested to counsel for Plaintiff, Stephen Johnston, Baron & Budd, The Centrum, 3102 Oak Lawn Ave., Suite 1100, Dallas, Texas 75219, on this the 27th day of July, 2001. Paul E. Hamilton DEFENDANT UNION CARBIDE CORPORATION'S OBJECTIONS AND ANSWERS TO PLAINTIFFS SECOND SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION AND FIRST REQUEST FOR ADMISSIONS Page 2 GENERAL OBJECTION Union Carbide objects to Plaintiffs' entire ^et of Interrogatories, Requests for Production and Requests for Admission to the extent that they call for information about Union Carbide facilities or premises where the plaintiffs never worked. Over the course of its business. Union Carbide owned or operated a numerous amount of locations and premises. Ascertaining plant and employee practices for each Union Carbide facility or premises, even during a specified time frame, would be unduly burdensome, if possible at all. Moreover, the nature of the processes and work conducted at Carbide's various plants and facilities differed considerably, and information relating to another plant or facility is not necessarily relevant. OBJECTIONS TO DEFINITIONS AND INSTRUCTIONS DEFINITIONS AND INSTRUCTIONS OBJECTION NO. 1: Union Carbide objects to the instructions and definitions supplied by Plaintiffs with regard to these Interrogatories, Requests for Production and Requests for Admission on the grounds that the definitions are overly broad, vague and often inconsistent with the normal common usage and meaning of such words. As a result, these definitions constitute an unreasonable expansion of the Interrogatories, Requests for Production and Requests for Admission themselves. Union Carbide has therefore responded to this discovery consistently with the common understanding of the language used in the Interrogatories, Requests for Production and Requests for Admission. DEFINITIONS AND INSTRUCTIONS OBJECTION NO. 2: Union Carbide objects to Plaintiffs' definitions and instructions to the extent those definitions and instructions request Union Carbide to make any inquiry beyond that which is required by the Texas Rules of Civil Procedure or to the extent they seek to include documents not within Union Carbide's custody or control. DEFINITIONS AND INSTRUCTIONS OBJECTION NO. 3: Union Carbide objects to the terms "plant and facility" and "Defendants Premises at Issue" as defined because it renders these Interrogatories, Requests for Production and Requests for Admission over broad and not reasonably limited to matters which are relevant to the subject matter of this lawsuit or to the discovery of matters which are reasonably calculated to lead to the discovery of admissible evidence. Because Union Carbide has operated the Bound Brook and Marietta facilities DEFENDANT UNION CARBIDE CORPORATION'S OBJECTIONS AND ANSWERS TO PLAINTIFFS SECOND SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION AND FIRST REQUEST FOR ADMISSIONS Page 3 for a number of years, and because the various processes contained in those facilities have been altered significantly over the years, Union Carbide objects to this entire set of discovery on grounds that Plaintiffs have failed to provide Union Carbide with a sufficient amount of information concerning which specific units and buildings at each of the respective facilities that Plaintiff was allegedly present, the relevant time periods involved with each facility, and a description of the various jobs allegedly performed by Plaintiff at the Bound Brook and Marietta facilities. As a result of Plaintiffs failure to reasonably limit the scope of this discovery to those matters which are relevant and reasonably calculated to lead to the discovery of admissible evidence, Union Carbide is called upon to speculate as to whether or not it has been provided with a sufficient amount of information to enable it to adequately and thoroughly respond to the full breadth of Plaintiffs overly broad discovery. DEFINITIONS AND INSTRUCTIONS OBJECTION NO. 4: Union Carbide objects to the term "Time Period at Issue" as defined because it renders these Interrogatories, Requests for Production and Requests for Admission over broad and not reasonably limited to matters which are relevant to the subject matter of this lawsuit or to the discovery of matters which are reasonably calculated to lead to the discovery of admissible evidence. The years set forth in Plaintiffs work history are rarely consistent with those years set forth in Plaintiffs discovery requests, with the result being that Plaintiffs seek to impose upon Union Carbide, the overwhelmingly burdensome task of discovering information from time periods which are irrelevant to this lawsuit, beyond the scope of discovery, and not reasonably calculated to lead to the discovery of admissible, evidence. Therefore, where possible, in light of the significant burden imposed by Plaintiffs overly broad discovery requests, Union Carbide will attempt to provide Plaintiffs with general, plant specific information concerning the Marietta and Bound Brook facilities, but objects to providing information, where such information on the face ofPlaintiffs discovery responses, does not appear to be reasonably calculated to lead to the discovery of admissible evidence. DEFENDANT UNION CARBIDE CORPORATION'S OBJECTIONS AND ANSWERS TO PLAINTIFFS SECOND SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION AND FIRST REQUEST FOR ADMISSIONS Page 4 OBJECTIONS AND RESPONSES TO PLAINTIFF'S SECOND SET OF INTERROGATORIES, REQUESTS FOR PRODUCTION AND REQUESTS FOR ADMISSION GENERAL OBJECTIONS GENERAL OBJECTION NO. 1 Union Carbide states that trial preparation and factual investigation are ongoing. Union Carbide's answers to Plaintiffs Interrogatories and Requests for Production are based on information known to Union Carbide at this time. Union Carbide reserves the right, however to make reference at trial or at any hearing in this action to facts and documents not identified in these responses, the existence or relevance of which is later discovered by it or its counsel. By this reservation, Union Carbide does not in any way assume a continuing responsibility to update its responses to these Interrogatories and Requests for Production, and specifically objects to each of these interrogatories and requests to the extent that they seek to impose any such continuing obligation upon Union Carbide. GENERAL OBJECTION NO. 2 Union Carbide objects to Plaintiffs Interrogatories and Requests for Production in their entirety on the grounds that they are not reasonably framed in terms of the facts and subject matter ofthe present action, with the result that Union Carbide is called upon to speculate as to what information relevant to the present case, if any, may be deemed to fall within the scope of the interrogatories and requests as phrased. GENERAL OBJECTION NO. 3: Union Carbide also objects to all Interrogatories and Requests for Production insofar as they would require the disclosure of information protected by the attorney client privilege/work product doctrines. GENERAL OBJECTION NO. 4: Union Carbide objects to any request to provide information about any asbestos or asbestos-containing product that it manufactured, mined or sold other than the Bakelite products. The non-Bakelite products which may have included asbestos fiber as a component include the following: a tree sprout inhibitor used primarily to inhibit growth on telephone poles; Prestone radiator products; acetylene cylinder liners; a scarfer machine used to remove blemishes and imperfections from steel; and Calidria, a raw chrysotile fiber, with unique physical and chemical features and properties, sold in pelletized or fibrous forms to producers or manufacturers for use in their products, or production processes. Union Carbide no longer manufactures, mines or sells any of those products. Plaintiffs have raised no allegations of exposure to those products or to situations where exposure to those products would be expected. Fiber in the asbestos-containing products was DEFENDANT UNION CARBIDE CORPORATION'S OBJECTIONS AND ANSWERS TO PLAINTIFFS SECOND SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION AND FIRST REQUEST FOR ADMISSIONS Page 5 completely encapsulated and thus, not respirable. Calidria, due to its unique properties and characteristics, could not cause the hazards posed by other asbestos, and could not be used for insulation. Thus, information about those products is wholly irrelevant to this case. GENERAL OBJECTION NO. 5: Union Carbide also objects to any request to provide information about any Bakelite product other than Bakelite Phenolic Resin. Those products include the following: Epoxy resins and hardeners Phenoxy resins and solutions Polyethylene and Polypropylene Polystyrene and copolymers Polysuflone Polyvinyl acetate, polyvinyl chloride and copolymers Plaintiffs have raised no allegations of exposure to those products or to situations where exposure to those products would be expected. UDEL Polysulfone was manufactured and marketed for the limited use of Polaroid cases; fiber in the Polysulfone was fully encapsulated and thus, not respirable. Some polystyrene products may have included asbestos for experimental trail runs only. Union Carbide no longer manufacturer or sells those products. None of the other products ever included any asbestos content. Thus, information about any of the products listed above is wholly irrelevant to this case. GENERAL OBJECTION NO. 6: Union Carbide objects to this entire set ofInterrogatories and Requests for Production to the extent that it calls for information about Union Carbide employees or premises, or policies pertaining to Union Carbide employees or premises. Inasmuch as the plaintiffs do not allege that they or their decedents were ever employed by Union Carbide or worked at any job site controlled by Union Carbide, such information is irrelevant and immaterial to matters at issue in this case. Any information or knowledge which such information could be said to reflect could be asked for directly, without requesting irrelevant employment information. DEFENDANT UNION CARBIDE CORPORATION'S OBJECTIONS AND ANSWERS TO PLAINTIFFS SECOND SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION AND FIRST REQUEST FOR ADMISSIONS Page 6 RESPONSES REQUEST FOR ADMISSION NO. 1: Admit that raw asbestos fibers were an ingredient in the version of Bakelite manufactured at Union Carbide's facility in Bound Brook, New Jersey. RESPONSE: Union Carbide objects to this Request on grounds that it is vague and overly broad, in that it has not been reasonably limited in time or scope. Union Carbide further objects to the use of the terms "ingredient in the version of Bakelite manufactured," on grounds that said terms are unclear and undefined, with the result being that Union Carbide is called upon to speculate as to whether or not it has been provided with a sufficient amount of information to enable it to adequately respond to this unintelligible Request for Admission. Subject thereto, denied that Union Carbide manufactured one version ofphenolic molding compound; admitted that some formulations ofUnion Carbide's phenolic molding compounds contained asbestos as a filler until 1974. The Bakelite name has been widely used to refer to a variety of plastic or plastic-related products. Many of those products, or their antecedents, may have originally been manufactured by the Bakelite corporation. Union Carbide utilized Bakelite as a trade name to denote a variety of materials. Those materials included the following: Epoxy resins and hardeners, Phenolic Molding Compounds, Phenoxy resins and solutions, Polyethylene and Polypropylene, Polystyrene and copolymers, Polysulfone, and Polyvinyl acetate, polyvinyl chloride, and copolymers. DEFENDANT UNION CARBIDE CORPORATION'S OBJECTIONS AND ANSWERS TO PLAINTIFFS SECOND SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION AND FIRST REQUEST FOR ADMISSIONS Page 7 Only the phenolic molding compounds, in some brands only, were manufactured with asbestos. Most brands of Bakelite phenolic molding compounds never contained asbestos. In addition, UDEL Polysulfone, manufactured for a limited use for Polaroid camera cases, and some experimental polyethylene and polystyrene products, never put into full production, also contained quantities of asbestos fiber. REQUEST FOR PRODUCTION NO. 1: If you deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: Union Carbide objects to this Request to the extent that it is vague and overly broad in that it has not been reasonably limited in time or scope, and as such this Request constitutes an impermissible fishing expedition. K-Mart v. Sanderson, 937 S.W. 2d 429,430 (Tex. 1996). Union Carbide further objects to this Request on grounds that it fails to identify with any degree of reasonable particularity the types or categories of documents sought to be discovered in a manner consistent with the meaning of Rule 196.1 (b) of the Texas Rules of Civil Procedure, and as a result. Union Carbide is called upon to speculate as to what type of documentation, if any, might be responsive to the full breadth of this overly broad discovery Request. Union Carbide further objects to producing each and every document supporting our good faith, qualified denial as stated in response to a Request for Admission No. 1, on grounds that Union Carbide's objection and subsequent denial, is a direct result of Plaintiffs failure to provide Union Carbide with enough information concerning Alexander McDonald's work history, and therefore, it would be DEFENDANT UNION CARBIDE CORPORATION'S OBJECTIONS AND ANSWERS TO PLAINTIFFS SECOND SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION AND FIRST REQUEST FOR ADMISSIONS Page 8 unquestionably characterized as oppressive if Union Carbide was required to fully comply with the significant burden of production imposed by this Request, should the discovery sought be allowed. Without waiving these objections Union Carbide attaches Exhibit A in support of its partial denial of Request for Admission No. 1. Other responsive documents may be reviewed at Union Carbide's asbestos related document repository maintained at Kelley Drye & Warren, LLP. Union Carbide maintains a Repository ofasbestos-related documents and other material. The Repository includes a myriad ofdocuments and other material from Union Carbide's former Calidria business, from other former businesses which manufactured products which contained some asbestos, and from Union Carbide facilities which used and removed asbestos insulation and other asbestos products in accordance with the most advanced state-of-the-art industrial practices. The repository encompasses documents and material generated and received by Union Carbide employees orofficials, as well as published articles collected by Carbide employees and officials. Subjects which the documents and material discuss or pertain to include, but are not limited to, the following: Union Carbide's former Calidria business; the unique physical and chemical properties of the Calidria fiber, which engender the fiber's innocuous nature; information about asbestos containing products manufactured by Union Carbide or other producers; and information about other asbestos generally, including health officials of the other asbestos. The repository should include any of the material requested by this request to the extent that it remains in Union Carbide's possession. Upon plaintiffs request. Union Carbide will make its Repository, except privileged material, available to plaintiff for review and replication at a suitable time and place. DEFENDANT UNION CARBIDE CORPORATION'S OBJECTIONS AND ANSWERS TO PLAINTIFFS SECOND SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION AND FIRST REQUEST FOR ADMISSIONS Page 9 Union Carbide manufactured and sold its Bakeiite phenolic molding compound from 1939 to 1975. Many, if not most business documents pertaining to Bakeiite were probably destroyed pursuant to normal record retention guidelines. Union Carbide's document repository does, however include many Bakeiite related documents not destroyed, which will be indefinitely maintained. Those documents include the following: drafts for product labels; product formulations; manufacturing instructions and procedures; product and brand lists and descriptions; purchase records for asbestos fiber; and general business correspondence. REQUEST FOR ADMISSION NO. 2: Admit that raw asbestos fibers were an ingredient in the version of Bakeiite manufactured at Union Carbide's facility in Bound Brook, New Jersey, during the years 1950 to 1969. RESPONSE: Union Carbide objects to this Request on grounds that it is vague and overly broad, in that it has not been reasonably limited in time or scope. Union Carbide further objects to the use of the terms "ingredient in the version of Bakeiite manufactured," on grounds that said terms are unclear and undefined, with the result being that Union Carbide is called upon to speculate as to whether or not it has been provided with a sufficient amount of information to enable it to adequately respond to this unintelligible Request for Admission. Subject thereto, see Union Carbide's answer to Request for Admission No. 1. DEFENDANT UNION CARBIDE CORPORATION'S OBJECTIONS AND ANSWERS TO PLAINTIFFS SECOND SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION AND FIRST REQUEST FOR ADMISSIONS Page 10 REQUEST FOR PRODUCTION NO. 2: If you deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: See Union Carbide's answer ` Request for Production No. 1, including all objections asserted therein. REQUEST FOR ADMISSION NO. 3: Admit that Alexander McDonald would have been exposed to the raw asbestos fibers used in the production of Bakelite manufactured at Union Carbide's facility in Bound Brook, New Jersey. RESPONSE: Union Carbide objects to this Request on grounds that it is vague and undeniably overly broad, in that it has not been reasonably limited in time, scope, or in any manner designed to lead to the discovery of admissible evidence. Union Carbide further objects to this Request on grounds that, as drafted this Request is unclear and undefined, with the result being that Union Carbide is called upon to speculate as to whether or not it has been provided with a sufficient amount of information concerning which specific units and buildings at the Bound Brook facility that Plaintiff was allegedly present, the relevant time periods involved with each facility, and a description of the various jobs allegedly performed by Plaintiff at Bound Brook to enable it to adequately respond to this unintelligible Request for Admission. Union Carbide states that it has made a reasonable inquiry, but that the information known or easily obtainable is insufficient to enable Union Carbide to admit or deny this Request with specificity. Subject thereto, denied. The Bound Brook, NJ facility included numerous buildings throughout the years, all but 2 or 3 of which had no involvement in the production of phenolic molding compounds. See Union Carbide's DEFENDANT UNION CARBIDE CORPORATION'S OBJECTIONS AND ANSWERS TO PLAINTIFFS SECOND SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION AND FIRST REQUEST FOR ADMISSIONS Page 11 responses to Request for Admission No. 1. REQUEST FOR PRODUCTION NO. 3: If you deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: Union Carbide objects to this Request to the extent that it is vague and overly broad in that it has not been reasonably limited in time or scope, and as such this Request constitutes an impermissible fishing expedition. K-Mart v. Sanderson, 937 S.W. 2d 429, 430 (Tex. 1996). Union Carbide further objects to this Request on grounds that it fails to identify with any degree of reasonable particularity the types or categories of documents sought to be discovered in a manner consistent with the meaning of Rule 196.1 (b) of the Texas Rules of Civil Procedure, and as a result, Union Carbide is called upon to speculate as to what type of documentation, if any, might be responsive to the full breadth of this overly broad discovery Request. Union Carbide further objects to producing each and every document supporting our good faith, qualified denial as stated in response to a Request for Admission No.3, on grounds that Union Carbide's objection and subsequent denial, is a direct result of Plaintiffs failure to provide Union Carbide with enough information concerning Alexander McDonald's work history, and therefore, it would be unquestionably characterized as oppressive if Union Carbide was required to fully comply with the significant burden of production imposed by this Request, should the discovery sought be allowed. Without waiving objections, Union Carbide maintains a Repository of asbestos-related documents and other material. The Repository includes a myriad of documents and other material DEFENDANT UNION CARBIDE CORPORATION'S OBJECTIONS AND ANSWERS TO PLAINTIFFS SECOND SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION AND FIRST REQUEST FOR ADMISSIONS Page 12 from Union Carbide's former Calidria business, from other former businesses which manufactured products which contained some asbestos, and from Union Carbide facilities which used and removed asbestos insulation and other asbestos products in accordance with the most advanced state-of-the-art industrial practices. The repository encompasses documents and material generated and received by Union Carbide employees or officials, as well as published articles collected by Carbide employees and officials. Subjects which the documents and material discuss or pertain to include, but are not limited to, the following: Union Carbide's former Calidria business; the unique physical and chemical properties of the Calidria fiber, which engender the fiber's innocuous nature; information about asbestos containing products manufactured by Union Carbide or other producers; and information about other asbestos generally, including health officials of the other asbestos. The repository should include any of the material requested by this request to the extent that it remains in Union Carbide's possession. Upon plaintiffs request, Union Carbide will make its Repository, except privileged material, available to plaintiff for review and replication at a suitable time and place. Union Carbide manufactured and sold its Bakelite phenolic molding compound from 1939 to 1975. Many, if not most business documents pertaining to Bakelite were probably destroyed pursuant to normal record retention guidelines. Union Carbide's document repository does, however include many Bakelite related documents not destroyed, which will be indefinitely maintained. Those documents include the following: drafts for product labels; product formulations; manufacturing instructions and procedures; product and brand lists and descriptions; purchase records for asbestos DEFENDANT UNION CARBIDE CORPORATION'S OBJECTIONS AND ANSWERS TO PLAINTIFFS SECOND SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION AND FIRST REQUEST FOR ADMISSIONS Page 13 fiber; and general business correspondence. INTERROGATORY NO. 1: Please identify the brand name, manufacturer, and supplier of the raw asbestos fibers used in the production of Bakelite manufactured at Union Carbide's facility in Bound Brook, New Jersey during the years 1950 to 1969. Please include in your response the following: a. The year(s) each particular brand of raw asbestos fiber was used b. The quantity purchased in each year for each brand of raw asbestos fiber c. The fiber type of asbestos purchased, i.e. crocidolite, amosite, chrysotile, etc. RESPONSE:. Union Carbide objects to this Request to the extent that it is vague and overly broad in that it has not been reasonably limited in time or scope, and as such this Request constitutes an impermissible fishing expedition. K-Mart v. Sanderson, 937 S.W. 2d 429, 430 (Tex. 1996). Union Carbide further objects to this Request on grounds that it is unduly burdensome, and the oppressive and harassing nature of the burden entailed in identifying each and every sales document pertaining to the use of asbestos involved in the production of Bakelite at the Bound Brook facility, without the existence of any rational or reasonable limitation, substantially outweighs the probative value of the information sought should discovery be allowed. Subject thereto, Union Carbide responds as follows: All asbestos used by Union Carbide in phenolic resin consisted of short fiber chrysotile, except for long fiber (African blue) used in one brand of High Impact resin discontinued in the mid-1960's. Union Carbide purchased the short-fiber asbestos from the Carey-Canada Company. Union Carbide maintains a Repository of asbestos-related documents and other material. The DEFENDANT UNION CARBIDE CORPORATION'S OBJECTIONS AND ANSWERS TO PLAINTIFFS SECOND SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION AND FIRST REQUEST FOR ADMISSIONS Page 14 Repository includes a myriad ofdocuments and other material from Union Carbide's former Calidria business, from other former businesses which manufactured products which contained some asbestos, and from Union Carbide facilities which used and removed asbestos insulation and other asbestos products in accordance with the most advanced state-of-the-art industrial practices. The repository encompasses documents and material generated and received by Union Carbide employees or officials, as well as published articles collected by Carbide employees and officials. Subjects which the documents and material discuss or pertain to include, but are not limited to, the following: Union Carbide's former Calidria business; the unique physical and chemical properties of the Calidria fiber, which engender the fiber's innocuous nature; information about asbestos containing products manufactured by Union Carbide or other producers; and information about other asbestos generally, including health officials of the other asbestos. The repository should include any of the material requested by this request to the extent that it remains in Union Carbide's possession. Upon plaintiffs request, Union Carbide will make its Repository, except privileged material, available to plaintiff for review and replication at a suitable time and place. Union Carbide manufactured and sold its Bakelite phenolic molding compound from 1939 to 1975. Many, if not most business documents pertaining to Bakelite were probably destroyed pursuant to normal record retention guidelines. Union Carbide's document repository does, however include many Bakelite related documents not destroyed, which will be indefinitely maintained. Those documents include the following: drafts for product labels; product formulations; manufacturing instructions and procedures; product and brand lists and descriptions; purchase records for asbestos DEFENDANT UNION CARBIDE CORPORATION'S OBJECTIONS AND ANSWERS TO PLAINTIFFS SECOND SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION AND FIRST REQUEST FOR ADMISSIONS Page 15 fiber; and general business correspondence. REQUEST FOR PRODUCTION NO. 4: Please produce all ordering and sales documents pertaining to the purchase or acquisition of such raw asbestos fibers for use in the production of Bakelite manufactured at Union Carbide's facility in Bound Brook, New Jersey during the years 1950 to 1969, including but not limited to invoices, price quotations, purchase orders, requisitions, bills of lading, and other purchasing and/or shipping documents of similar nature. RESPONSE: See Union Carbide's response to Interrogatory No. 1, including all objections asserted therein. REQUEST FOR ADMISSION NO. 4: Admit that raw asbestos fibers were an ingredient in UDEL Polysulfone manufactured at Union Carbide's facility in Bound Brook, New Jersey. RESPONSE: Union Carbide objects to this Request on grounds that it is vague and overly broad, in that it has not been reasonably limited in time or scope. Union Carbide further objects to this Request on grounds that Union Carbide is called upon to speculate as to whether or not it has been provided with a sufficient amount of information to enable it to adequately respond to this unintelligible Request for Admission. Union Carbide states that it has made a reasonable inquiry, but that the information known or easily obtainable is insufficient to enable Union Carbide to admit or deny this Request with specificity. Subject thereto, denied. DEFENDANT UNION CARBIDE CORPORATION'S OBJECTIONS AND ANSWERS TO PLAINTIFFS SECOND SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION AND FIRST REQUEST FOR ADMISSIONS Page 16 REQUEST FOR PRODUCTION NO. 5: If you deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: Union Carbide objects to this Request to the extent that it is vague and overly broad in that it has not been reasonably limited in time or scope, and as such this Request constitutes an impermissible fishing expedition. K-Mart v. Sanderson, 937 S.W. 2d 429, 430 (Tex. 1996). Union Carbide further objects to this Request on grounds that it fails to identify with any degree of reasonable particularity the types or categories of documents sought to be discovered in a manner consistent with the meaning of Rule 196.1 (b) of the Texas Rules of Civil Procedure, and as a result. Union Carbide is called upon to speculate as to what type of documentation, if any, might be responsive to the full breadth of this overly broad discovery Request. Union Carbide further objects to producing each and every document supporting our good faith, qualified denial as stated in response to a Request for Admission No. 4, on grounds that Union Carbide's objection and subsequent denial, is a direct result of Plaintiffs failure to provide Union Carbide with enough information concerning Alexander McDonald's work history, and therefore, it would be unquestionably characterized as oppressive if Union Carbide was required to fully comply with the significant burden of production imposed by this Request, should the discovery sought be allowed. REQUEST FOR ADMISSION NO. 5: Admit that raw asbestos fibers were an ingredient in UDEL Polysulfone manufactured at Union Carbide's facility in Bound Brook, New Jersey, during the years 1950 to 1969. DEFENDANT UNION CARBIDE CORPORATION'S OBJECTIONS AND ANSWERS TO PLAINTIFFS SECOND SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION AND FIRST REQUEST FOR ADMISSIONS Page 17 RESPONSE: Union Carbide objects to this Request on grounds that it is vague and overly broad, in that it has not been reasonably limited in time or scope. Union Carbide further objects to the use of the terms "ingredient in UDEL Polysulfone," on grounds that said terms are unclear and undefined, with the result being that Union Carbide is called upon to speculate as to whether or not it has been provided with a sufficient amount of information to enable it to adequately respond to this unintelligible Request for Admission. Union Carbide states that it has made a reasonable inquiry, but that the information known or easily obtainable is insufficient to enable Union Carbide to admit or deny this Request with specificity. Subject thereto, denied. REQUEST FOR PRODUCTION NO. 6: Ifyou deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: Union Carbide objects to this Request to the extent that it is vague and overly broad in that it has not been reasonably limited in time or scope, and as such this Request constitutes an impermissible fishing expedition. K-Mart v. Sanderson, 937 S.W. 2d 429, 430 (Tex. 1996). Union Carbide further objects to this Request on grounds that it fails to identify with any degree of reasonable particularity the types or categories of documents sought to be discovered in a manner consistent with the meaning of Rule 196.1 (b) of the Texas Rules of Civil Procedure, and as a result, Union Carbide is called upon to speculate as to what type of documentation, if any, might be responsive to the full breadth of this overly broad discovery Request. Union Carbide further objects to producing each and every document supporting our good faith, qualified denial as stated in DEFENDANT UNION CARBIDE CORPORATION'S OBJECTIONS AND ANSWERS TO PLAINTIFFS SECOND SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION AND FIRST REQUEST FOR ADMISSIONS Page 18 response to a Request for Admission No. 5, on grounds that Union Carbide's objection and subsequent denial, is a direct result of Plaintiffs failure to provide Union Carbide with enough information concerning Alexander Me'' nald's work history, and therefore, it would be unquestionably characterized as oppressive if Union Carbide was required to fully comply with the significant burden ofproduction imposed by this Request, should the discovery sought be allowed. REQUEST FOR ADMISSION NO. 6: Admit that Alexander McDonald would have been exposed to the raw asbestos fibers used in the production of UDEL Polysulfone manufactured at Union Carbide's facility in Bound Brook, New Jersey. RESPONSE: Union Carbide objects to this Request on grounds that it is vague and undeniably overly broad, in that it has not been reasonably limited in time, scope, or in any manner designed to lead to the discovery of admissible evidence. Union Carbide further objects to this Request on grounds that, as drafted this Request is unclear and undefined, with the result being that Union Carbide is called upon to speculate as to whether or not it has been provided with a sufficient amount of information concerning which specific units and buildings at the Bound Brook facility that Plaintiff was allegedly present, the relevant time periods involved with each facility, and a description of the various jobs allegedly performed by Plaintiff at Bound Brook to enable it to adequately respond to this unintelligible Request for Admission. Union Carbide states that it has made a reasonable inquiry, but that the information known or easily obtainable is insufficient to enable Union Carbide to admit or deny this Request with specificity. Subject thereto, denied. DEFENDANT UNION CARBIDE CORPORATION'S OBJECTIONS AND ANSWERS TO PLAINTIFFS SECOND SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION AND FIRST REQUEST FOR ADMISSIONS Page 19 REQUEST FOR PRODUCTION NO. 7: If you deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: Union Carbide objects to this Recast to the extent that it is vague and overly broad in that it has not been reasonably limited in time or scope, and as such this Request constitutes an impermissible fishing expedition. K-Mart v. Sanderson, 937 S.W. 2d 429,430 (Tex. 1996). Union Carbide further objects to this Request on grounds that it fails to identify with any degree of reasonable particularity the types or categories of documents sought to be discovered in a manner consistent with the meaning of Rule 196.1 (b) of the Texas Rules of Civil Procedure, and as a result, Union Carbide is'called upon to speculate as to what type of documentation, if any, might be responsive to the full breadth of this overly broad discovery Request. Union Carbide further objects to producing each and every document supporting our good faith, qualified denial as stated in response to a Request for Admission No. 6, on grounds that Union Carbide's objection and subsequent denial, is a direct result of Plaintiffs failure to provide Union Carbide with enough information concerning Alexander McDonald's work history, and therefore, it would be unquestionably characterized as oppressive if Union Carbide was required to fully comply with the significant burden of production imposed by this Request, should the discovery sought be allowed. DEFENDANT UNION CARBIDE CORPORATION'S OBJECTIONS AND ANSWERS TO PLAINTIFFS SECOND SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION AND FIRST REQUEST FOR ADMISSIONS Page 20 INTERROGATORY NO. 2: Please identify the brand name, manufacturer, and supplier of the raw asbestos fibers used in the production of UDEL Polysulfone manufactured at Union Carbide's facility in Bound Brook, New Jersey during the years 1950 to 1969. Please include in your response the following: a. The year(s) each particular brand of raw asbestos fiber was used b. The quantity purchased in each year for each brand of raw asbestos fiber c. The fiber type of asbestos purchased, i.e. crocidolite, amosite, chrysotile, etc. RESPONSE: Union Carbide objects to this Interrogatory on the basis that this Interrogatory is overly broad and vague and constitutes and impermissible fishing expedition. K-Mart v. Sanderson, 937 S.W. 2d 429, 430 (Tex. 1996). . Union Carbide further objects to this Interrogatory on the grounds that Plaintiff has not alleged that he was exposed to asbestos-containing products manufactured by Union Carbide during the relevant time period and as such this Interrogatory is not reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR PRODUCTION NO. 8: Please produce all ordering-and sales documents pertaining to the purchase or acquisition of such raw asbestos fibers for use in the production ofUDEL Polysulfone manufactured at Union Carbide's facility in Bound Brook, New Jersey during the years 1950 to 1969, including but not limited to invoices, price quotations, purchase orders, requisitions, bills of lading, and other purchasing and/or shipping documents of similar nature. RESPONSE: Union Carbide objects to this Request to the extent that it is vague and overly broad in that it has not been reasonably limited in time or scope, and as such this Request constitutes an DEFENDANT UNION CARBIDE CORPORATION'S OBJECTIONS AND ANSWERS TO PLAINTIFFS SECOND SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION AND FIRST REQUEST FOR ADMISSIONS Page 21 impermissible fishing expedition. K-Mart v. Sanderson, 937 S.W. 2d 429, 430 (Tex. 1996). Union Carbide further objects to this Request on grounds that it is unduly burdensome, and the oppressive and harassing nature of the burden entailed in identifying each and every sales document pertaining to the use of asbestos involved in the production of UDEL Polysulfone at the Bound Brook facility, without the existence of any rational or reasonable limitation, substantially outweighs the probative value of the information sought should discovery be allowed. Subject thereto. Union Carbide responds as follows: Union Carbide states that any information which might be responsive to the full breadth of this overly broad Request may possibly be derived from the records contained in the repository. Therefore, the burden of deriving the answer is substantially the same for the requesting party as for the responding party. Union Carbide states that upon Plaintiff s request. Union Carbide will make its repository available to Plaintiff at a mutually agreeable place and time, for inspection and duplication at Plaintiffs expense. REQUEST FOR ADMISSION NO. 7: Admit that raw asbestos fibers were an ingredient in UDEL Polysulfone manufactured at Union Carbide's facility in Marietta, Ohio. RESPONSE: Union Carbide objects to this Request on grounds that it is vague and overly broad, in that it has not been reasonably limited in time or scope. Union Carbide further objects to this Request on grounds that Union Carbide is called upon to speculate as to whether or not it has been provided with a sufficient amount of information to enable it to adequately respond to this DEFENDANT UNION CARBIDE CORPORATION'S OBJECTIONS AND ANSWERS TO PLAINTIFFS SECOND SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION AND FIRST REQUEST FOR ADMISSIONS Page 22 unintelligible Request for Admission. Union Carbide states that it has made a reasonable inquiry, but that the information known or easily obtainable is insufficient to enable Union Carbide to admit or deny this Request with specificity. Subject thereto, denied. REQUEST FOR PRODUCTION NO. 9: Ifyou deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: Union Carbide objects to this Request to the extent that it is vague and overly broad in that it has not been reasonably limited in time or scope, and as such this Request constitutes an impermissible fishing expedition. K-Mart v. Sanderson, 937 S.W. 2d 429,430 (Tex. 1996). Union Carbide further objects to this Request on grounds that it fails to identify with any degree of reasonable particularity the types or categories of documents sought to be discovered in a manner consistent with the meaning of Rule 196.1 (b) of the Texas Rules of Civil Procedure, and as a result, Union Carbide is called upon to speculate as to what type of documentation, if any, might be responsive to the full breadth of this overly broad discovery Request. Union Carbide further objects to producing each and every document supporting our good faith, qualified denial as stated in response to a Request for Admission No. 7, on grounds that Union Carbide's objection and subsequent denial, is a direct result of Plaintiffs failure to provide Union Carbide with enough information concerning Alexander McDonald's work history, and therefore, it would be unquestionably characterized as oppressive if Union Carbide was required to fully comply with the significant burden of production imposed by this Request, should the discovery sought be allowed. DEFENDANT UNION CARBIDE CORPORATION'S OBJECTIONS AND ANSWERS TO PLAINTIFFS SECOND SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION AND FIRST REQUEST FOR ADMISSIONS Page 23 REQUEST FOR ADMISSION NO. 8: Admit that raw asbestos fibers were an ingredient in UDEL Polysulfone manufactured at Union Carbide's facility in Marietta, Ohio during the years 1951 to 1970. RESPONSE: Union Carbide objects to this Request on grounds that it is vague and overly broad, in that it has not been reasonably limited in time or scope. Union Carbide further objects to the use of the terms "ingredient in UDEL Polysulfone," on grounds that said terms are unclear and undefined, with the result being that Union Carbide is called upon to speculate as to whether or not it has been provided with a sufficient amount of information to enable it to adequately respond to this unintelligible Request for Admission. Union Carbide states that it has made a reasonable inquiry, but that the information known or easily obtainable is insufficient to enable Union Carbide to admit or deny this Request with specificity. Subject thereto, denied. REQUEST FOR PRODUCTION NO. 10: If you deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: Union Carbide objects to this Request to the extent that it is vague and overly broad in that it has not been reasonably limited in time or scope-andas such this Request constitutes an impermissible fishing expedition. K-Mart v. Sanderson, 937 S.VV. 2d 429, 430 (Tex. 1996). Union Carbide further objects to this Request on grounds that it fails to identify with any degree of reasonable particularity the types or categories of documents sought to be discovered in a manner consistent with the meaning of Rule 196.1 (b) of the Texas Rules of Civil Procedure, and as a result, DEFENDANT UNION CARBIDE CORPORATION'S OBJECTIONS AND ANSWERS TO PLAINTIFFS SECOND SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION AND FIRST REQUEST FOR ADMISSIONS Page 24 Union Carbide is called upon to speculate as to what type of documentation, if any, might be responsive to the full breadth of this overly broad discovery Request. Union Carbide further objects to producing each and every document supporting our good faith, qualified denial as stated in response to a Request for Admission No. 8, on grounds that Union Carbide's objection and subsequent denial, is a direct result of Plaintiff s failure to provide Union Carbide with enough information concerning Alexander McDonald's work history, and therefore, it would be unquestionably characterized as oppressive if Union Carbide was required to fully comply with the significant burden of production imposed by this Request, should the discovery sought be allowed. REQUEST FOR ADMISSION NO. 9: Admit that Alexander McDonald would have been exposed to the raw asbestos fibers used in the production of UDEL Polysulfone manufactured at Union Carbide's facility in Marietta, Ohio. RESPONSE: Union Carbide objects to this Request on grounds that it is vague and undeniably overly broad, in that it has not been reasonably limited in time, scope, or in any manner designed to lead to the discovery of admissible evidence. Union Carbide further objects to this Request on grounds that, as drafted this Request is unclear and undefined, with the result being that Union Carbide is called upon to speculate as to whether or not it has been provided with a sufficient amount of information concerning which specific units and buildings at the Marietta facility that Plaintiff was allegedly present, the relevant time periods involved with each facility, and a description of the various jobs allegedly performed by Plaintiff at Marietta to enable it to adequately respond to this unintelligible Request for Admission. Union Carbide states that it has made a reasonable inquiry, DEFENDANT UNION CARBIDE CORPORATION'S OBJECTIONS AND ANSWERS TO PLAINTIFFS SECOND SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION AND FIRST REQUEST FOR ADMISSIONS Page 25 but that the information known or easily obtainable is insufficient to enable Union Carbide to admit or deny this Request with specificity. Subject thereto, denied. REQUEST FOR PRODUCTION NO. 11: If you deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: Union Carbide objects to this Request to the extent that it is vague and overly broad in that it has not been reasonably limited in time or scope, and as such this Request constitutes an impermissible fishing expedition. K-Mart v. Sanderson, 937 S.W. 2d 429, 430 (Tex. 1996). Union Carbide further objects to this Request on grounds that it fails to identify with any degree of reasonable particularity the types or categories of documents sought to be discovered in a manner consistent with the meaning ofRule 196.1 (b) of the Texas Rules of Civil Procedure, and as a result, Union Carbide is called upon to speculate as to what type of documentation, if any, might be responsive to the full breadth of this overly broad discovery Request. Union Carbide further objects to producing each and every document supporting our good faith, qualified denial as stated in response to a Request for Admission No. 9, on grounds that Union Carbide's objection and subsequent denial, is a direct result of Plaintiffs failure to provide Union Carbide with enough information concerning Alexander McDonald's work history, and therefore, it would be unquestionably characterized as oppressive if Union Carbide was required to fully comply with the significant burden of production imposed by this Request, should the discovery sought be allowed. DEFENDANT UNION CARBIDE CORPORATION'S OBJECTIONS AND ANSWERS TO PLAINTIFFS SECOND SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION AND FIRST REQUEST FOR ADMISSIONS Page 26 INTERROGATORY NO. 3: Please identify the brand name, manufacturer, and supplier of the raw asbestos fibers used in the production of UDEL Polysulfone manufactured at Union Carbide's facility in Marietta, Ohio during the years 1951 to 1970. Please include in ''our response the following: a. The year(s) each particular brand of raw asbestos fiber was used b. The quantity purchased in each year for each brand of raw asbestos fiber c. The fiber type of asbestos purchased, i.e. crocidolite, amosite, chrysotile, etc. RESPONSE: Union Carbide objects to this Interrogatory on the basis that this Interrogatory is overly broad and vague and constitutes and impermissible fishing expedition. K-Mart v. Sanderson, 937 S.W. 2d 429, 430 (Tex. 1996). Union Carbide further objects to this Interrogatory on the grounds that Plaintiff has not alleged that he was exposed to asbestos-containing products manufactured by Union Carbide during the relevant time period and as such this Interrogatory is not reasonably calculated to lead to the discovery of admissible evidence. DEFENDANT UNION CARBIDE CORPORATION'S OBJECTIONS AND ANSWERS TO PLAINTIFFS SECOND SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION AND FIRST REQUEST FOR ADMISSIONS Page 27 REQUEST FOR PRODUCTION NO. 12: Please produce all ordering and sales documents pertaining to the purchase or acquisition of such raw asbestos fibers for use in the production of UDEL Polysulfone manufactured at Union Carbide's facility in Marietta, Ohio during the years 1951 to 1970, including but not limited to invoices, price quotations, purchase orders, requisitions, bills of lading, and other purchasing and/or shipping documents of similar nature. RESPONSE: Union Carbide objects to this Request to the extent that it is vague and overly broad in that it has not been reasonably limited in time or scope, and as such this Request constitutes an impermissible fishing expedition. K-Mart v. Sanderson, 937 S.W. 2d 429, 430 (Tex. 1996). Union Carbide further objects to this Request on grounds that it is unduly burdensome, and the oppressive and harassing nature of the burden entailed in identifying each and every sales document pertaining to the use of asbestos involved in the production of UDEL Polysulfone at the Marietta facility, without the existence of any rational or reasonable limitation, substantially outweighs the probative value of the information sought should discovery be allowed. Subject thereto, Union Carbide responds as follows: Union Carbide states that any information which might be responsive to the full breadth of this overly broad Request may possibly be derived from the records contained in the repository. Therefore, the burden of deriving the answer is substantially the same for the requesting party as for the responding party. Union Carbide states that upon Plaintiff s request, Union Carbide will make its repository available to Plaintiff at a mutually agreeable place and time, for inspection and duplication at Plaintiffs expense. DEFENDANT UNION CARBIDE CORPORATION'S OBJECTIONS AND ANSWERS TO PLAINTIFFS SECOND SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION AND FIRST REQUEST FOR ADMISSIONS Page 28 REQUEST FOR ADMISSION NO. 10: Admit that raw asbestos fibers were an ingredient in Polyethlene products manufactured at Union Carbide's facility in Bound Brook, New Jersey. RESPONSE: Union Carbide objects to this Request on grounds that it is vague and overly broad, in that it has not been reasonably limited in time or scope. Union Carbide further objects to this Request on grounds that Union Carbide is called upon to speculate as to whether or not it has been provided with a sufficient amount of information to enable it to adequately respond to this unintelligible Request for Admission. Union Carbide states that it has made a reasonable inquiry, but that the information known or easily obtainable is insufficient to enable Union Carbide to admit or deny this Request with specificity. Polyethylene and Polystyrene were never manufactured by Union Carbide for sale containing asbestos fillers. Therefore we object to answering this Interrogatory because it is not calculated to lead to the discovery of admissible evidence. Any experiments with Polyethylene and Polystyrene compounds would have involved very small amounts of asbestos. Any exposure to Alexander McDonald would have been diminimous. REQUEST FOR PRODUCTION NO. 13: If you deny the foregoing request, in whole or in part, produce all documents supporting your denial. DEFENDANT UNION CARBIDE CORPORATION'S OBJECTIONS AND ANSWERS TO PLAINTIFFS SECOND SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION AND FIRST REQUEST FOR ADMISSIONS Page 29 RESPONSE: Union Carbide objects to this Request to the extent that it is vague and overly broad in that it has not been reasonably limited in time or scope, and as such this Request constitutes an impermissible fishing expedition. K-Mart v. Sanderson, 937 S.W. 2d 429, 430 (Tex. 1996). Union Carbide further objects to this Request on grounds that it fails to identify with any degree of reasonable particularity the types or categories of documents sought to be discovered in a manner consistent with the meaning of Rule 196.1 (b) of the Texas Rules of Civil Procedure, and as a result, Union Carbide is called upon to speculate as to what type of documentation, if any, might be responsive to the full breadth of this overly broad discovery Request. Union Carbide further objects to producing each and every document supporting our good faith, qualified denial as stated in response to a Request for Admission No. 10, on grounds that Union Carbide's objection and subsequent denial, is a direct result of Plaintiffs failure to provide Union Carbide with enough information concerning Alexander McDonald's work history, and therefore, it would be unquestionably characterized as oppressive if Union Carbide was required to fully comply with the significant burden of production imposed by this Request, should the discovery sought be allowed. See also Request for Admission No. 10, including all objections set forth therein. REQUEST FOR ADMISSION NO. 11: Admit that raw asbestos fibers were an ingredient in Polyethylene products manufactured at Union Carbide's facility in Bound Brook, New Jersey, during the years 1950 to 1969. RESPONSE: Union Carbide objects to this Request on grounds that it is vague and overly broad, in that it has not been reasonably limited in time or scope. Union Carbide further objects to this DEFENDANT UNION CARBIDE CORPORATION'S OBJECTIONS AND ANSWERS TO PLAINTIFFS SECOND SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION AND FIRST REQUEST FOR ADMISSIONS Page 30 Request on grounds that Union Carbide is called upon to speculate as to whether or not it has been provided with a sufficient amount of information to enable it to adequately respond to this unintelligible Request for Admission. Union Carbide states that it has made a reasonable inquiry, but that the information known or easily obtainable is insufficient to enable Union Carbide to admit or deny this Request with specificity. Polyethylene and Polystyrene were never manufactured by Union Carbide for sale containing asbestos fillers. Therefore we object to answering this Interrogatory because it is not calculated to lead to the discovery of admissible evidence. Any experiments with Polyethylene and Polystyrene compounds would have involved very small amounts of asbestos. Any exposure to Alexander McDonald would have been diminimous. REQUEST FOR PRODUCTION NO. 14: If you deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: Union Carbide objects to this Request to the extent that it is vague and overly broad in that it has not been reasonably limited in time or scope, and as such this Request constitutes an impermissible fishing expedition. K-Mart v. Sanderson, 937 S.W. 2d 429, 430 (Tex. 1996). Union Carbide further objects to this Request on grounds that it fails to identify with any degree of reasonable particularity the types or categories of documents sought to be discovered in a manner consistent with the meaning of Rule 196.1 (b) of the Texas Rules of Civil Procedure, and as a result, Union Carbide is called upon to speculate as to what type of documentation, if any, might be DEFENDANT UNION CARBIDE CORPORATION'S OBJECTIONS AND ANSWERS TO PLAINTIFFS SECOND SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION AND FIRST REQUEST FOR ADMISSIONS Page 31 responsive to the full breadth of this overly broad discovery Request. Union Carbide further objects to producing each and every document supporting our good faith, qualified denial as stated in response to a Request for Admission No. 11, on grounds that Union Carbide's objection and subsequent denial, is a direct result of Plaintiffs failure to provide Union Carbide with enough information concerning Alexander McDonald's work history, and therefore, it would be unquestionably characterized as oppressive if Union Carbide was required to fully comply with the significant burden of production imposed by this Request, should the discovery sought be allowed. See also Request for Admission No. 11, including all objections set forth therein. REQUEST FOR ADMISSION NO. 12: Admit that Alexander McDonald would have been exposed to the raw asbestos fibers used in the production of Polyethylene produces[sic] manufactured at Union Carbide's facility in Bound Brook, New Jersey. RESPONSE: Union Carbide objects to this Request on grounds that it is vague and undeniably overly broad, in that it has not been reasonably limited in time, scope, or in any manner designed to lead to the discovery of admissible evidence. Union Carbide further objects to this Request on grounds that, as drafted this Request is unclear and undefined, with the result being that Union Carbide is called upon to speculate as to whether or not it has been provided with a sufficient amount of information concerning which specific units and buildings at the Bound Brook facility that Plaintiff was allegedly present, the relevant time periods involved with each facility, and a description of the various jobs allegedly performed by Plaintiff at Bound Brook to enable it to DEFENDANT UNION CARBIDE CORPORATION'S OBJECTIONS AND ANSWERS TO PLAINTIFFS SECOND SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION AND FIRST REQUEST FOR ADMISSIONS Page 32 adequately respond to this unintelligible Request for Admission. Union Carbide states that it has made a reasonable inquiry, but that the information known or easily obtainable is insufficient to enable Union Carbide to admit or deny this Request with specificity. Polyethylene and Polystyrene were never manufactured by Union Carbide for sale containing asbestos fillers. Therefore we object to answering this Interrogatory because it is not calculated to lead to the discovery of admissible evidence. Any experiments with Polyethylene and Polystyrene compounds would have involved very small amounts of asbestos. Any exposure to Alexander McDonald would have been diminimous. REQUEST FOR PRODUCTION NO. 15: If you deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: Union Carbide objects to this Request to the extent that it is vague and overly broad in that it has not been reasonably limited in time or scope, and as such this Request constitutes an impermissible fishing expedition. K-Mart v. Sanderson, 937 S.W. 2d 429, 430 (Tex. 1996). Union Carbide further objects to this Request on grounds that it fails to identify with any degree of reasonable particularity the types or categories of documents sought to be discovered in a manner consistent with the meaning of Rule 196.1 (b) of the Texas Rules of Civil Procedure, and as a result, Union Carbide is called upon to speculate as to what type of documentation, if any, might be responsive to the full breadth of this overly broad discovery Request. Union Carbide further objects to producing each and every document supporting our good faith, qualified denial as stated in DEFENDANT UNION CARBIDE CORPORATION'S OBJECTIONS AND ANSWERS TO PLAINTIFFS SECOND SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION AND FIRST REQUEST FOR ADMISSIONS Page 33 response to a Request for Admission No. 12, on grounds that Union Carbide's objection and subsequent denial, is a direct result of Plaintiffs failure to provide Union Carbide with enough information concerning Alexander McDonald's work history, and therefore, it would be unquestionably characterized as oppressive if Union Carbide was required to fully comply with the significant burden of production imposed by this Request, should the discovery sought be allowed. See Request for Admission No. 12, including all objections set forth therein. INTERROGATORY NO. 4: Please identify the brand name, manufacturer, and supplier of the raw asbestos fibers used in the production ofPolyethylene products manufactured at Union Carbide's facility in Bound Brook, New Jersey during the years 1950 to 1969. Please include in your response the following: a. The year(s) each particular brand of raw asbestos fiber was used b. The quantity purchased in each year for each brand of raw asbestos fiber c. The type of asbestos purchased, i.e. crocidolite, amosite, chrysotile, etc. RESPONSE: Polyethylene and Polystyrene were never manufactured by Union Carbide for sale containing asbestos fillers. Therefore we object to answering this Interrogatory because it is not calculated to lead t" 'he discovery of admissible evidence. Any experiments with Polyethylene and Polystyrene compounds would have involved very small amounts of asbestos. Any exposure to Alexander McDonald would have been diminimous. DEFENDANT UNION CARBIDE CORPORATION'S OBJECTIONS AND ANSWERS TO PLAINTIFFS SECOND SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION AND FIRST REQUEST FOR ADMISSIONS Page 34 REQUEST FOR PRODUCTION NO. 16: Please produce all ordering and sales documents pertaining to the purchase or acquisition of such raw asbestos fibers for use in the production of Polyethylene products manufactured at Union Carbide's facility in Bound Brook, New Trsey during the years 1950 to 1969, including but not limited to invoices, price quotations, purchase orders, requisitions, bills of lading, and other purchasing and/or shipping documents of similar nature. RESPONSE: Union Carbide objects to this Request to the extent that it is vague and overly broad in that it has not been reasonably limited in time or scope, and as such this Request constitutes an impermissible fishing expedition. K-Mart v. Sanderson, 937 S.W. 2d 429, 430 (Tex. 1996). Union Carbide further objects to this Request on grounds that it is unduly burdensome, and the oppressive and harassing nature of the burden entailed in identifying each and every sales document pertaining to the use of asbestos involved in the production of Polyethylene at the Bound Brook facility, without the existence of any rational or reasonable limitation, substantially outweighs the probative value of the information sought should discovery be allowed. Subject thereto. Union Carbide responds as follows: Union Carbide states that any information which might be responsive to the full breadth of this overly broad Request may possibly be derived from the records contained in the repository, therefore, the burden of deriving the answer is substantially the same for the requesting party as. for ~ the responding party. Union Carbide states that upon Plaintiffs request, Union Carbide will make its repository available to Plaintiff at a mutually agreeable place and time, for inspection and duplication at Plaintiffs expense. Polyethylene and Polystyrene were never manufactured by Union Carbide for sale containing DEFENDANT UNION CARBIDE CORPORATION'S OBJECTIONS AND ANSWERS TO PLAINTIFFS SECOND SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION AND FIRST REQUEST FOR ADMISSIONS Page 35 asbestos fillers. Therefore we object to answering this Interrogatory because it is not calculated to lead to the discovery of admissible evidence. Any experiments with Polyethylene and Polystyrene compounds would have involved very small amounts of asbestos. Any exposure to Alexander McDonald would have been diminimous. REQUEST FOR ADMISSION NO. 13: Admit that raw asbestos fibers were an ingredient in the version of Polystyrene manufactured at Union Carbide's facility in Bound Brook New Jersey. RESPONSE: Union Carbide objects to this Request on grounds that it is vague and overly broad, in that it has not been reasonably limited in time or scope. Union Carbide further objects to this Request on grounds that Union Carbide is called upon to speculate as to whether or not it has been provided with a sufficient amount of information to enable it to adequately respond to this unintelligible Request for Admission. Union Carbide states that it has made a reasonable inquiry, but that the information known or easily obtainable is insufficient to enable Union Carbide to admit or deny this Request with specificity. Polyethylene and Polystyrene were never manufactured by Union Carbide for sale containing asbestos fillers. Therefore we object to answering this Interrogatory because it is not calculated to lead to the discovery of admissible evidence. Any experiments with Polyethylene and Polystyrene compounds would have involved very small amounts of asbestos. Any exposure to Alexander McDonald would have been diminimous. DEFENDANT UNION CARBIDE CORPORATION'S OBJECTIONS AND ANSWERS TO PLAINTIFFS SECOND SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION AND FIRST REQUEST FOR ADMISSIONS Page 36 REQUEST FOR PRODUCTION NO. 17: If you deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: Union Carbide objects to this Request to the extent that it is vague and overly broad in that it has not been reasonably limited in time or scope, and as such this Request constitutes an impermissible fishing expedition. K-Mart v. Sanderson, 937 S.W. 2d 429, 430 (Tex. 1996). Union Carbide further objects to this Request on grounds that it fails to identify with any degree of reasonable particularity the types or categories of documents sought to be discovered in a manner consistent with the meaning of Rule 196.1 (b) of the Texas Rules of Civil Procedure, and as a result, Union Carbide is called upon to speculate as to what type of documentation, if any, might be responsive to the full breadth of this overly broad discovery Request. Union Carbide further objects to producing each and every document supporting our good faith, qualified denial as stated in response to a Request for Admission No. 13, on grounds that Union Carbide's objection and subsequent denial, is a direct result of Plaintiffs failure to provide Union Carbide with enough information concerning Alexander McDonald's work history, and therefore, it would be unquestionably characterized as oppressive if Union Carbide was required to fully comply with the significant burden of production imposed by this Request, should the discovery sought be allowed. See also, Request for admission No. 13, including all objections set forth therein. REQUEST FOR ADMISSION NO. 14: Admit that raw asbestos fibers were an ingredient in the version of Polystyrene manufactured at Union Carbide's facility in Bound Brook, New Jersey, during the years 1950 to 1969. DEFENDANT UNION CARBIDE CORPORATION'S OBJECTIONS AND ANSWERS TO PLAINTIFFS SECOND SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION AND FIRST REQUEST FOR ADMISSIONS Page 37 RESPONSE: Union Carbide objects to this Request on grounds that it is vague and overly broad, in that it has not been reasonably limited in time or scope. Union Carbide further objects to this Request on grounds that Union Carbide is called upon to speculate as to whether or not it has been provided with a sufficient amount of information to enable it to adequately respond to this unintelligible Request for Admission. Union Carbide states that it has made a reasonable inquiry, but that the information known or easily obtainable is insufficient to enable Union Carbide to admit or deny this Request with specificity. Polyethylene and Polystyrene were never manufactured by Union Carbide for sale containing asbestos fillers. Therefore we object to answering this Interrogatory because it is not calculated to lead to the discovery of admissible evidence. Any experiments with Polyethylene and Polystyrene compounds would have involved very small amounts of asbestos. Any exposure to Alexander McDonald would have been diminimous. REQUEST FOR PRODUCTION NO. 18: If you deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: Union Carbide objects to this Request to the extent that it is vague and overly broad in that it has not been reasonably limited in time or scope, and as such this Request constitutes an impermissible fishing expedition. K-Mart v. Sanderson, 937 S.W. 2d 429, 430 (Tex. 1996). Union Carbide further objects to this Request on grounds that it fails to identify with any degree of reasonable particularity the types or categories of documents sought to be discovered in a manner DEFENDANT UNION CARBIDE CORPORATION'S OBJECTIONS AND ANSWERS TO PLAINTIFFS SECOND SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION AND FIRST REQUEST FOR ADMISSIONS Page 38 consistent with the meaning of Rule 196.1 (b) of the Texas Rules of Civil Procedure, and as a result, Union Carbide is called upon to speculate as to what type of documentation, if any, might be responsive to the full breadth of this overly broad discovery Request. Union Carbide further objects to producing each and every document supporting our good faith, qualified denial as stated in response to a Request for Admission No. 14, on grounds that Union Carbide's objection and subsequent denial, is a direct result of Plaintiff's failure to provide Union Carbide with enough information concerning Alexander McDonald's work history, and therefore, it would be unquestionably characterized as oppressive if Union Carbide was required to fully comply with the significant burden of production imposed by this Request, should the discovery sought be allowed. See Also Request for Admission No. 14, including all objections set forth therein. REQUEST FOR ADMISSION NO. 15: Admit that Alexander McDonald would have been exposed to the raw asbestos fibers used in the production of Polystyrene manufactured at Union Carbide's faciiity in Bound Brook, New Jersey. RESPONSE: Union Carbide objects to this Request on grounds that it is vague and undeniably overly broad, in that it has not been reasonably limited in time, scope, or in any manner designed to lead to the discovery of admissible evidence. Union Carbide further objects to this Request on grounds that, as drafted this Request is unclear and undefined, with the result being that Union Carbide is called upon to speculate as to whether or not it has been provided with a sufficient amount of information concerning which specific units and buildings at the Bound Brook facility that Plaintiff was allegedly present, the relevant time periods involved with each facility, and a DEFENDANT UNION CARBIDE CORPORATION'S OBJECTIONS AND ANSWERS TO PLAINTIFFS SECOND SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION AND FIRST REQUEST FOR ADMISSIONS Page 39 description of the various jobs allegedly performed by Plaintiff at Bound Brook to enable it to adequately respond to this unintelligible Request for Admission. Union Carbide states that it has made a reasonable inquiry, but that the information known or easily obtainable is insufficient to enable Union Carbide to admit or deny this Request with specificity. Polyethylene and Polystyrene were never manufactured by Union Carbide for sale containing asbestos fillers. Therefore we object to answering this Interrogatory because it is not calculated to lead to the discovery of admissible evidence. Any experiments with Polyethylene and Polystyrene compounds would have involved very small amounts of asbestos. Any exposure to Alexander McDortald would have been diminimous. REQUEST FOR PRODUCTION NO. 19: Ifyou deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: Union Carbide objects to this Request to the extent that it is vague and overly broad in that it has not been reasonably limited in time or scope, and as such this Request constitutes an impermissible fishing expedition. K-Mart v. Sanderson, 937 S.W. 2d 429, 430 (Tex. 1996). Union Carbide further objects to this Request on grounds that it fails to identify with any degree of reasonable particularity the types or categories of documents sought to be discovered in a manner consistent with the meaning of Rule 196.1 (b) of the Texas Rules of Civil Procedure, and as a result, Union Carbide is called upon to speculate as to what type of documentation, if any, might be responsive to the full breadth of this overly broad discovery Request. Union Carbide further objects DEFENDANT UNION CARBIDE CORPORATION'S OBJECTIONS AND ANSWERS TO PLAINTIFFS SECOND SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION AND FIRST REQUEST FOR ADMISSIONS Page 40 to producing each and every document supporting our good faith, qualified denial as stated in response to a Request for Admission No. 15, on grounds that Union Carbide's objection and subsequent denial, is a direct result of Plaintiffs failure to provide Union Carbide with enough information concerning Alexander McDonald's work history, and therefore, it would be unquestionably characterized as oppressive if Union Carbide was required to fully comply with the significant burden of production imposed by this Request, should the discovery sought be allowed. See also, Request for Production No. 15, including objections set forth therein. INTERROGATORY NO. 5: Please identify the brand name, manufacturer, and supplier of the raw asbestos fibers used in the production of Polystyrene manufactured at Union Carbide's facility in Bound Brook, New Jersey during the years 1950 to 1969. Please include in your response the following: a. The year(s) each particular brand of raw asbestos fiber was used b. The quantity purchased in each year for each brand of raw asbestos fiber c. The type of asbestos purchased, i.e. crocidolite, amosite, chrysotile, etc. RESPONSE: Polyethylene and Polystyrene were never manufactured by Union Carbide for sale containing asbestos fillers. Therefore we object to answering this Interrogatory because it is not calculated to lead to the discovery of admissible evidence. Any experiments with Polyethylene and Polystyrene compounds would have involved very small amounts of asbestos. Any exposure to Alexander McDonald would have been diminimous. DEFENDANT UNION CARBIDE CORPORATION'S OBJECTIONS AND ANSWERS TO PLAINTIFFS SECOND SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION AND FIRST REQUEST FOR ADMISSIONS Page 41 REQUEST FOR PRODUCTION NO. 20: Please produce all ordering and sales documents pertaining to the purchase or acquisition of such raw asbestos fibers for use in the production ofPolystyrene manufactured at Union Carbide's facility in Bound Brook, New Jersey during the years 1950 to 1969, including but not limited to invoices, price quotations, purchase orders, requisitions, bills of lading, and other purchasing and/or shipping documents of a similar nature. RESPONSE: Union Carbide objects to this Request to the extent that it is vague and overly broad in that it has not been reasonably limited in time or scope, and as such this Request constitutes an impermissible fishing expedition. K-Mart v. Sanderson, 937 S.W. 2d 429, 430 (Tex. 1996). Union Carbide further objects to this Request on grounds that it is unduly burdensome, and the oppressive and harassing nature of the burden entailed in identifying each and every sales document pertaining to the use of asbestos involved in the production of Polyethylene at the Bound Brook facility, without the existence of any rational or reasonable limitation, substantially outweighs the probative value of the information sought should discovery be allowed. Subject thereto, Union Carbide responds as follows: Union Carbide states that any information which might be responsive to the full breadth of this overly broad Request may possibly be derived from the records contained in the repository. Therefore, the burden of deriving the answer is substantially the same for the requesting party as for the responding party. Union Carbide states that upon Plaintiff s request. Union Carbide will make its repository available to Plaintiff at a mutually agreeable place and time, for inspection and duplication at Plaintiffs expense. Polyethylene and Polystyrene were never manufactured by Union Carbide for sale containing DEFENDANT UNION CARBIDE CORPORATION'S OBJECTIONS AND ANSWERS TO PLAINTIFFS SECOND SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION AND FIRST REQUEST FOR ADMISSIONS Page 42 asbestos fillers. Therefore we object to answering this Interrogatory because it is not calculated to lead to the discovery of admissible evidence. Any experiments with Polyethylene and Polystyrene compounds would have involved very sr '1 amounts of asbestos. Any exposure to Alexander McDonald would have been diminimous. DEFENDANT UNION CARBIDE CORPORATION'S OBJECTIONS AND ANSWERS TO PLAINTIFFS SECOND SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION AND FIRST REQUEST FOR ADMISSIONS Page 43 EXHIBIT "A" THE STORY OF MODERN PLASTIES It in the manner of (he popular radio quizzes, you asked any gruup of pco pie to "name five articles made of BakeQto plastics." the average man or woman would probably receive a poifect *mre. They would mention items that are visible to the eye, items of everyday use, such as the tele phone handset, the base of an elec tric toaster, the closure aa a bottle, an automatic pencil, a cnkjtful bracelet. We ore so accustomed tu such ar ticles that the real contribution of these plastics tn modem living Is seldom recognized. Back of these familiar articles and devices are thou sands of plastic applications that you never see. In modem communication --fho radio, the telct2hcne;_injnod*m transportation -- the automobile end the airplane; in the generation, trans mission and use oi electric power front the central elation to the switch box tn your home, those plastics meei a countless number oi vital needs that would lake volumes to describe. And so rapidly are plastics finding * place in our daily lives ihal a list at aurrent uses would be out of darn lire day it came off the press.' If, however, you were again to re sume a quizzing r&ie and ask your group. "What ars thsso pushes that have become so Important to our CopyElylat 1390. SakUt* <*!Rr?drii(oii comfort and well-being?" you might hare difficulty a obtaining an accu rals description. The purpose of this booklet, therefore, Is to provide as answer to that question, not in the language of ihe chemist or the en gineer, but in simple terns that can be understood by everyone, WHAT A** PLASTICS? In lire ordinary sense "plastic" moans "capable of being molded ut mod elea, as clay," and. no doubt the earliest plastic material was the primitiro potter's cler- Broadly spealdng.rubber, day, glass, Portland cement, and other materials may be classified as plastics. However, the term "Mod uli Ploatica" is generally applied to a group oi synthetic organic materials which are made plastic by the use of heat and are capable of being molded or pressed into hninhftd parts and products. WHAT IS "BAKILtTE"? What manner of material is It that on one hand rivals precious gems (n depth of beauty and color for eoa- yet be employed for protective hel mets to safeguard workers on sky. scrapers from falling rivets because it will ant shatter at all? That seeming paradox is answered by thti fact that BalceHm plastics aro not one material, hut many. "Bakelite" is a trade-mark tdeutifyiag phe nolic. urea, cellulose-acetate, polysty rene. and other plasties, developed by lire Bakalite Research Laboratories to meet the varied needs of unr mod em industrial world. The trade-mark "Bakelite" was derived bum the name of Dr- l. H. Baekeland, noted for bis discovery of phenol resinoid end suhsoquoat far-reaching develupmente that haw laid the groundwork (or the rapid development of the modem plastics industry, IN WHAT FORMS ARE BAUELITS MATERIALS AVAILABLE? Sakeltto Corporation produces basic, or primary, matenals which in mor: Instances am converted mtg finished products by ether manufacturers nr fabricators. These materials are sup plied in leveral forms suitable fur fabrication by various proccemng methods, euch as molding, laminat ing, sod castinq. Thaw are Bakelite molding ma terials in powder, sheet aud qranuia form. Bakelite hoat rBacbvo varnishes for the pmductiuii of laminated plas tic: materials. Transparent cast rcrinois. Oil-acluble resins iorpMul* <uid vanishes. Plywuod-bondiag materUls. in film and liquid form. Flexible rasuviids Cor waterproofing doth. And many other types of roemoids for specific industrial reads. 1W 0*101* or PLASTICS Lika everything else, plastics can be traced back to the three kingdoms of nature--animal, vegetable and mineral. The raw material? from the mine, forest end farm are trans formed by the magic of chemistry into useful materials of industry. However, you will not recognize nature's materials in the finished plas tic products. In the course of their trip through the Baleolio factory they are converted Into totally new forms that ere more uniform, more stable, and more useful to our modem world, A listing of the natural sources of the chemicals and other materials that enter into the production of Bakelite products would take ua on a journey that would encompass the globe. From coal we obtain phe nol, carbon dioxide for ureas, benzol far dyes, as well ts s host al other materials whose names aro recognized only by th* chemist, but whose properties ore utilised by you every day. The quamoe furnish Asbestos, used for fillers in the manufacture of heatresistant plastics. Timber provides woodflour used as a filler in genual-purpose Bakelite molding materials. Tt also la tho source u( pulp for paper used in lamtriited materials. Cotton is the basts fur celluloacacetate plastics. It also furnishes fillers for phenolic and urea ma terials. Natural gas provides a sonma of ethylene, the basis for polyvinyl plas tics. From the farm and the ranch flow numerous other products: ":T"nl tela from lire stock, a source of glycerins used In the manufacture of alkyd res ins that torus the base for languors and enamels ... linseed ofl. derived from flaxseed, and ehinawood ail ob tained from tong wees, both oi which form the vebidee for durable, quick drying Bakelite taolu finishes ,.. flu* say Itean, now an Important domes tic crop, which provides fillers for molding materials and also serves as the basis for special types of syn thefic resina ... sugar cans and beet sugar which pra-rule source <i{ ethyl alcohol ucod as a MfAJvJ I#** Tnyf G*a? Uat.wei^1^ solvent in the manufacture ot Sakelilu resin solutions. AH ECONOMIC PARTNERSHIP Thus, the farmer, the miner, the rancher, and the lumberman have close ties with the plastics industry. They Increase their income by sell ing their products to Bokelita Plastics Hranlquartera. In return, they spend a portion nf that income tor the fin ished plastic products that make thefr homes more livable, their livoe acre enjoyable. In this cycle you have the. perfect example of the modern pertnerthip of induetry and science on one hand, and those who make their living through the cultivation ot the throe kingdoms oi nature on the other, the-results of which benefit nut only the partners, but everyone in every walk uf Ufa. This ever-widening economic part nership did not happen over night It is the continuous story of the world demanding new and better tilings. It is the sags of the chemist, the inven tor. the engineer--vnen and women whose risiou and initiative provided a means of meeting those increasing demands. Ths first phenolic resin that Doctor Baekeland produced fn 1907 pos sessed certain properties that made it immediately desirable to the in dustrial world. Ito very success In mooting those needs revealed other needs that in tum led to the creation of newer materials with widely vary ing characteristic*. Thus, today, thore are more than 2,000 distinct materials available at Bokelite Plastics Head quarters. SBnVINO VIRTUALLY EVERT RANCH Or INDUSTRY Benuae of the extremely broad range of plastics available, and the amaz ing versatility of each al these ma terials. il is impossible to list all die countless thousands of Bokelite uses. However, the applications described in the following paragraphs serve to emphasize two Important facto. First, dm unique combination of use ful properties that arc in herent in Baleelite plastics, and ****** second, the ex tent to which these plastics have 'become indiapetiMble to modern living. For example, plastics, because oi their chemical inertnese and resist ance to solvent*, ore widely cm- ployed la the chemical and textile processing Industrie*. The exceptional insulating qualities of BekBlite materials have made them highly successful in railway signal equipment where human urea de pend upon unfailing service. Their fine appearance, beautiful colors, aad rich lustre have added greatly to Improved product styling. Modem daatgoers have found in BakeUta plastics a medium for combining functional, as well as esthetic, designs in Special heat-resistant properties hare led to the widespread adoption of plastics for handles on cooking utenaUs and electrical appliances. Probably there is no place in industry In which equipment receives hauler service >> machine-made (jiF* products. They are making the world easier to loolr at *1 well as to livo in. As bonds for abrasive materials they have enabled manufacturers to operate grinding wheels at Snareasod speeds, with greeter safety to the operator. Bakelite Plybond wood adhesives are revolutionizing the plywood and veneering industries, transforming '''plywoods into a superior synthetic lumber. Heat humidity, water, ver mis, and fungi --none of these ene mies of ordinary wet glued Veneers can impair the lasting qualities of BeVnlilo resinoid-bonded plywood. X4` than in oil well Arillinq. Bakelite irnpact-rasisluil plastics used in the valve assembly and as shoe guides of such equip ment withstand pressures of 172,000 pounds--strength qroater then yuu would expect from concrete. Laminated materials are widely em ployed for wall paneHnq, table, coun ter and bar tops, radio insulation, stletil gears end pinions, and as tem perature insulation stripe around the door* of mechanical refrigerators, to mention Just a few usee. In paints and varnishea, BalceUt* synthetic reams have provided longer deeonitva and protective life for fin ishan by establishing new standards cil durability in an industry where basic methods had not changed radi cally since the days of the Pharaohs. They have speeded up the drying time of air-dry finishes and have answered some of the problems in surface coating that have plagued * mannfacturera for conturto*. * Flexible Bakslite retaa- aids are nuw employed in tbs waterproofing of fabrics. Among the outstanding uses far this now prod net are draperies, and upholstery, ovening wraps, shower curtains, beach wear and sports wear. A BaVefite matrix material used for the forming of rubber printing plates has brought about important econ omies in iMtter-prcce printing. Still another farm of pUctics. cast retinoids, provide beautiful transpar ent end translucent materials which rival nature's own jewels in depth of color and brilliance. Plastics play vital roles in the world of science, aa durable housings for scientific instruments, for X-ny tube shields. os handles on phyai dans' instruments. As part of the dentist's equipment, even for modern denial plaice, they aid the scientist in his dally efforts to main* life more Tftjrth living. Where you seek reereaHou and dateileinment, you will find Bakellts plastics ready to carve you. Fulling teels, gun stocks, sports glasses, bil liard halls, ere made of plastics. And, if you like cards, you will find plastic cribbage boards, duplicate boards, poker chips and racks and other ac cessorius. big aids in enjoying your favorite pastime. nsSEAJtCK AND SFVEttJPMEMT In little more than a quarter century the words "Bakeiite PUsrica" have be come household terms, so rapidly have these modem materials become a pail of our doily existence. The tre mendous strides that have been made in this relatively short span of yeans la a tribute to the Importance of Scien tific Heaesreh. At Bloomfield, New lerssy, there are several acres of buildings devoted solely to Bokelite Research and Development. Here men experienced in every branch of science are scanning the Bakelilo hoiiiona for new uses of plasties. They are devoting themselves to the development of new applications as yet undreamed of by the layman. Thces are the men who win tnoko our lives ffo or ten yearn from now more comfortable, our homes mere beautiful. These are the men who may bring industry sad the ihree kingdoms of nature still closer to gether In the common endeavor to create new enterprises that wilt pro vide more work for more people. mtftaKrtd hm tbart dtattajuah leUU mnau tietund bf OnrparAltoa. 9*dw Um "1** * t&i ausmi* cal wf la or "n*1--yii(<ty. i> orntbo}* u* Wlb iwMr M pnttni aoJ hura nm *tf lakthta CQrp9iUan' jwAtgtt. BAKELITE CORPORATION PLASTICS HEADQUARTERS uskeaac, orncffstr 247 PARK AVF.NUE. NfcW YORK, N. Y. aawc orrionc: CKtO&OO RbmbAKD KAATPOKB . PBTROJT LO* KtiQZhZS AH rRAffOtSCC flCATTbK PLANTS AT BOUND BROOK AND SLOOMFTRbD, f, tf. BAKELITE CORPORATION QT CANADA, LTDl3 DUTTERIJf STREET, TORONTO, ONTARIO, CANADA VrUUrt la V, 5, A. ** total PAGE.09 **