Document oDqGxR3bvxqg0Lk688oEL01oE
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1 HrPUTCHEN, DOYLE, BROWN fc ENERSEN WILLIAM H. ARMSTRONG
2 Three Embarcadero Center San Francisco, California 94111
3 Telephone: (415) 393-2000
41 Attorneys for Defendant GAF Corporation
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IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE CITY AND COUNTY OF SAN FRANCISCO 10
I! IN RE: STERNS, BROWN t FINNEY CONSOLIDATED FOR DISCOVERY
12 RELATED SHIPYARD AND APPLICATOR ASBESTOS CASES.
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) NO. B05555
) ) GAF CORPORATION'S RESPONSE
) TO PLAINTIFF'SREQUEST ) FOR ADMISSION
14 PROPOUNDING: Plaintiffs
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RESPONDING:
Defendant, GAF Corporation
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SET:
One (1)
17 GAF Corporation (GAF) responds and objects to
18 Plaintiffs' First Set of Admissions as follows:
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REQUEST FOR ADMISSION NO. 14; Do you admit that the harmful effects of asbestos
dust and fibers extends not only to workers actually handlinq
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A~ your asbestos products but also tot 5 (a) Other workers in the area where your asbestos 6 products are being used; and to 7 (b) Kerabers\of the families of workers, who dusted 6 and laundered the work clothes of such workers whose work 9 clothes contained your asbestos products dust? 10 RESPONSE TO REQUEST TOR ADMISSION WO. 14; 11 GAF admits that if a person, either directly 112 or indirectly exposed, inhales a sufficient quantity of 13 asbestos dust, he could contract asbestosis, however the 14 precise quantity of asbestos dust necessary to cause such 15 disease is unknown. Apparently not everyone who inhales 16 asbestos dust contracts asbestosis.j Ex^efct as expressly
17 admitte^T^AE^e^e^-fcbis^R^quest fo% Admissiopf;
18 REQUEST FOR ADMISSION NO. IS: 19 Do you admit that from 1940 to the present you
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20 have not formulated any rules, written or oral, for the
21 handling of your asbestos products by your own employees?
22 RESPONSE TO REQUEST FOR ADMISSION WO. 15:
23 Admitted.
24 REQUEST FOR ADMISSION NO. 16:
25 Do you admit that you do not maintain a .library
26 dealing with industrial hygiene, medicine, safety or engineering'
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RESPONSE TO REQUEST FOR ADMISSION NO. 27;
* Denied. 3 REQUEST FOR ADMISSION NO. 2S; * - Do you admit that, after the initial placement 3 of warning labels regarding the hazards of exposure to asbestos 6 on your asbestos containing products, you did not recall 2 or make any attempt to recall those asbestos products and/or asbestos materials which had been sold in containers without 9 such labels? 10 RESPONSE TO REQUEST TOR ADMISSION WO. 28: 11 Admitted. 12 REQUEST FOR ADMISSION WO. 29: 13 Do you admit that you have not conducted, participated 14 or directly contributed any funds to studies to determine 15 the effects of your asbestos containing products on workers 16 working with such products? 17 RESPONSE TO REQUEST FOR ADMISSION NO. 29: 18 Admitted. 19 REQUEST FOR ADMISSION NO. 30; 20 Do you admit that you have not conducted, participated 21 or directly financed or had conducted for you, any studies 22 to determine the effects of inhalation of asbestos dust 23 or fibers by one using or being exposed to your asbestos 24 insulation products? 25 RESPONSE TO REQUEST FOR ADMISSION NO. 30: 26 Admitted.
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