Document o9GjMjjv0eEO6aDa01xVYRV4o

1 ITED STATES DISTRICT COURri WESTERN DISTRICT OF KENTUCKY AT LOUISVILLE BETTYPEERENBOOM, ET AL PLAINTIFFS VS. B.F.GOODRICH COMPANY, ET AL DEFENDANTS ) ) ) ) a J- fast ) CIVIL ACTION NO. 81-0698 L (A) ) ) ) ) ANSWERS OF DEFENDANT, B. F. GOODRICH COMPANY, TO PLAINTIFF'S INTERROGATORIES OF NOVEMBER 10, 1982 1. List all personnel within Defendant corporation's structure who had contact with personnel within the Manufacturing Chemists Association, herafter MCA, in the period 1964-1974. A. It is impossible for this Defendant to know each individual within its Corporate Structure who may had some contact with the Manufacturing Chemists Association at any one period of time. However, the following witnesses are deemed by the Defertfent to be the most knowledgable people within its Corporate Structure who had any significant contacts with the Manufacturing Chemists Association with respect to the subject matter of this litigation: Before 1973, W. E. McCormick, retired, 419 Dorchester Road, Akron, Ohio, 44320. After 1973, Maurice N. Johnson, M.D., Director of Toxicology, B.F. Goodrich Company, 500 South Main Street, Akron, Ohio. 2. Who among the Defendant's personnel in the period 1964-1974 had knowledge of MCA's findings of potential health hazards connected with exposure to hydrocarbous, such as vinyl chloride. A. See answer to Number One above. tOOSGTOZ BFG02287 { 3. List all personnel who had contact with officials of the De fendant Union in Louisville regarding possible health hazards to plant workers due to exposure to vinyl chlroide. A. See Answer #3 of the Amended Response of Defendant, B. F. Goodrich Company, to Plaintiff's Request for Production of Docu ments of February 25, 1982. With that qualification in mind, the personnel within the plant here in Louisville who would have had primary responsibility for such communication with the employees would have been: 1. From June 1943 to August 1973, H. P. McMath (Deceased) 2. From August 1973 to May 1976, W. E. Pember, (now employed by Phillip Morris Company in Richmond, Virginia) 3. From May 1976 to January 1982, Mr. G. R. Pruitt, B. F. Goodrich Company, 500 Sbuth Main Street, Akron, Ohio 4. From January 1982 to present, Mr. W. G. Pop, B* F. Good rich Company, Louisville, Kentucky 4. List those union officials so advised (as outlined in #3, supra), when, where and how advised. A. See Answer #3 of the Amended Response of Defendant, B. F. Good rich company, to Plaintiff's Request for Production of Documents of February 25, 1982. 5. Attach hereto copies of any/all notice, warnings or such were given to Defendant Union or its members. A. See Answer #3 of the Amended Response of Defendant, B. F. Good rich Company, to Plaintiff's Request for Production of Docu ments of February 25, 1982. 6. List whereabouts, title and availability of the following per sonnel within Defendant's corporation structure. BFG02288 TT 20198002 (a) W. E. McCormick - Retired, 410 Dorchester Road, Akron, Ohio, 44320. (b) P. J. Lawrence - (Under the assumption that the person iden tified should be P. H. Lawrence) Retired, Post Office Box 1874, Vero Beach, Florida, 32960 (c) R. H. Wilson - Deceased (d) W. M. Larson - Retired, 31550 Trillium Trail, Pepper Pike, Ohio, 44124 (e) H. R. Pletch - Unable to identify. (f) Maurice N. Johnson, M.D. - B.F. Goodrich Company, Director of Toxicology, 500 South Main Street, Akron, Ohio (g) Aton Vittone - Deceased OGDEN, ROBERTSON & MARSHALL 1200 One Riverfront Plaza Louisville, Kentucky 40202 (502) 582-1601 CERTIFICATE OF SERVICE It is hereby certified that a true copy of the foregoing was served upon Fredrick Radolovich, Attorney for Plaintiff, Suite 200, 440 South Seventh Street, Louisville, Kentucky 40203, and Mr. Kenneth Sales, Attorney for the Defendant Union, 300 Marion E. Taylor Bldg. Louisville, Kentucky 40202 by hand delivery this day of December 1982. Attorney for Defendants BFG02289 20198003 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF KENTUCKY AT LOUISVILLE .BETTY peerenboom, ET AL., ) PLAINTIFFS ) ) VS. i | B. F. GOODRICH, ) ) ) CIVIL ACTION NO. ! ) |! DEFENDANT i* ) ) NOTICE TO TAKE DEPOSITION 81 C 0698L(A) !; TO: HON. STEPHEN F. SCHUSTER, 1200 One Riverfront Plaza, Louisville ' Kentucky 40202, Attorney for Defendant Please take notice that the Plaintiffs will take the depositicr ] of MAURICE JOHNSON, M.D., for the purpose of discovery, beginning I on Tuesday, the Bth day of February, 1983, at the hour of 10:00 i 1 A.M., or as soon thereafter as Counsel can be heard, in the || offices of Dr. Johnson at the B. F. Goodrich Comple-in Akron, i| :: Ohio, and will continue taking said deposition every day there after, Sundays excepted, until completed. RADOLOVICH, HARRINGTON 6c LEVY, PSC t OJ.OV1CIL -UN'GTOV & -fiVY. P.S.C. ArtoBHtrj *r Law 40 south scvcnth sr LOUItVII.L(. KV 40203 , C(/' Suite 200, 440 South Seventh Street Louisville, Kentucky 40203 585-1168 The undersigned certifies that a copy hereof was mailed to the person and address listed above on.^fcb.is ^~J/ &C day-of January, 1983. RAD0L0 INGT0N 6c LEVY, PSC N O h* (6 GoO o BFG02290