Document o97Kyj4JRoDO50N1KbM4JOkrE

18TH JUDICIAL DISTRICT COURT PARISH OF IBERVILLE STATE OF LOUISIANA PLAINTIFF'S EXHIBIT EXX 93 LORRAINE PEGGY WILLIAMS VERSUS MCCARTY CORPORATION, ET AL SUIT NO,: 39,404 DIVISION "D" EXXON CORPORATION'S RESPONSES TO PLAINTIFF'S FIRST SET OF INTERROGATORIES PROPOUNDED JUNE 19, 1991 Exxon Corporation ("Exxon"), responds to the "Plaintiff's First Set Of Interrogatories Propounded To Exxon Corporation June 19, 1991" as follows: I. GENERAL OBJECTION Exxon objects to these interrogatories to the extent that the language contained in the so-called "notice" or "instruction" portion of the interrogatories exceeds the provisions of the Louisiana Code of Civil Procedure and, to that extent, Exxon objects. Exxon further objects to the extent that the' interrogatories specifically seek information which is in the possession of attorneys and which might otherwise be covered by the attorney/client privilege. Finally, Exxon objects to that portion of the interrogatories which states that "knowledge of any of your agents or attorneys or others acting on your behalf shall be considered and deemed to be knowledge of the defendant." This portion of the instructions .clearly impinges on the attorney/client privilege and further goes beyond the requirements of law. Reserving its rights under all its objections, Exxon hereby responds to the interrogatories as follows: t wxutcsro/eAtGKMTii EM002636 INTERROGATORY NO. 1; Please describe the relationship which Exxon Corporation has with Esso Standard Oil Company, including but not limited to the following: (1) any acquisition, merger, etc. involving Exxon and Esso Standard Oil Cmopany; (2) the date(s) of any acquisition, merger, etc. listed in (1), above; (3) the agents of Exxon and Esso Standard Oil Company who executed any acquisition, merger, etc., listed in (1), above; and ' (4) any departmental or procedural change's resulting from any acquisition, merger, etc., listed in (1), above, pertaining to industrial hygiene and safety measures. RESPONSE TO INTERROGATORY NO. 1 Esso Standard Oil Company is a predecessor company of Exxon. Standard Oil Company of New .Jersey, a name by which that corporation was known since August 29, 1927, changed its name to Esso Standard Oil Company on January 28, 1948. Esso Standard Oil Company merged into Humble oil and Refining Company on December 31, 1959. Humble Oil and Refining Company changed its name to Exxon Corporation on January 1, 1973. Further responding to the numbered subparagraphs of Interrogatory No. 1, Exxon states: (1) None. (2) Not applicable. (3) Not applicable. (4) Not applicable. INTERROGATORY NO. 2: Please describe the relationship which Exxon Cczpw.aliwii !s with Standard Oil Company, N.J., including but not limited to the following: (1) any acquisition, merger, etc. involving Exxon and Standard Oil Company, N.J.; . wtutrsFo/oABorxrft 2EK002637 (2) the date(s) of any acquisition, merger, etc. listed in (1), above; (3) the agents of Exxon and Standard Oil Company, N.J. who executed any acquisition, merger, fete., listed in (1), above; and (4) any departmental or procedural changes resulting from any acquisition, merger, etc., listed in (1), above, pertaining to industrial hygiene and safety measures. RESPONSE TO INTERROGATORY NO. 2: ' See response to Interrogatory No. 1 above. Submitted by: Gary A. Bezet Bar Roll No. 3036 ' KEAN, MILLER, HAWTHORNE, D'ARMOND, McCOWAN & JARMAN Post Office Box 3513 Baton Rouge, Louisiana 70821 Telephone: (504) 387-0999 David W. Ledyard STRONG, PIPKIN, NELSON & BISSELL 1400 San Jacinto Building 595 Orleans Beaumont, Texas 77701-3255 Telephone: (409) 835-4581 ' CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing document has been mailed, postage prepaid, to all counsel of record. __ Baton Rouge, Louisiana, July____ , 1991. HaiVA-- Gary A. Bezet wiEJtrsro/CAftucNEK 3- EH002638 STATE OF TEXAS COUNTY OF HARRIS VERIFICATION * BEFORE ME, undersigned Notary, personally came and appeared: J. M.ahctl AJu who, being by me first duly sworn, did depose and state that he is the J-)T7C/2kI ' of Exxon Corporation and that he has read the foregoing response to interrogatories and that they are true and correct to the best of his knowledge, information and belief. A 7 SWORN TO AND SUBSCRIBED before me, this /?** day of _________, 1991. -'xf.ivCicLLiU:, '"-'A?<L/l <S 'Notary Public My commission expires Cl' 3!- 93 JKQUEUK & GOWK fetor* fttofc Mm \mm Ml Cmmmu Ct*7/H/ ! EH002639