Document oe9azQX6k8r5qanBvEeGDdQZw

VIRGINIA: IN THE CIRCUIT COURT OF THE CITY OF CHESAPEAKE WILLIAM S. OVERBY, Plaintiff, Docket No. 20555-M RAYMARK INDUSTRIES, INC., et als. Defendants. 7/31/86 SUPPLEMENTAL RESPONSE OF GARLOCK INC TO PLAINTIFFS INITIAL INTERROGATORIES Comes now the defendant Garlock Inc and submits the following in response to the plaintiff's Interrogatories. All answers given are without waiver of any objection previously filed or stated herein. Any objection stated herein are in addition to, not in lieu of, any objection previously filed. VIRGINIA: IN THE CIRCUIT COURT OF THE CITY OF CHESAPEAKE WILLIAM S. OVERBY, Plaintiff, RAYMARK INDUSTRIES, INC., et als, Defendants. Docket No. 20555-M RESPONSES OF GARLOCK INC TO PLAINTIFF'S INITIAL INTERROGATORIES Comes now the defendant Garlock Inc and submits the following in response to the plaintiff's Interrogatories. All answers given are without waiver of any objection previously filed or stated herein. Any objection stated herein are in addition to, not in lieu of, any objection previously filed. VIRGINIA: IN THE CTRCUIT COURT OF THE CITY OF CHESAPEAKE WILLIAM S. OVERBY, Plaintiff, -vs- Docket No. 20555-M RAYMAKK INDUSTRIES, INC., ET AL, Defendants. PLAINTIFF'S INITIAL INTERROGATORIES PROPOUNDED TO GAKLPCK. INC.. FCTTTfiTOW SEAL DIVISION NOW CCMES the Plaintiff, WILLIAM S. OVERBY, by counsel, and propounds to the Defendant, GARLOCK, INC., PRECISION SEAL DIVISION (hereinafter referred to as GARLOCK), the following interrogatories pursuant to Rule 4:8 of the Rules of the Supreme court of Virginia, sworn answers to which must be served on the Plaintiff cn or before February 18, 1986. I i 1. If GARLOCX or ary predecessor or subsidiary corporation of GARLOCX has, at ary time, been engaged in the mining, manufacturing, I j producing, processing, caipciunding or converting (hereinafter canncnly ii ! referred to as "manufacturing" or "manufactured''), selling, merchandising, ; t ! applying, distribution, anchor otherwise placing in the stream of I ocmaeroe (hereinafter canncnly referred to as "distributing", I "distributed" or "distribution") of asbestos, material containing j ij | asbestos, asbestos products and compounds (hereinafter ocmncnly referred ; ; to as "product(s) containing asbestos"), then: [ji il State the trade name(s) of each product containing :| manufactured and/or distributed by GARLOCX; I i iI .il : * ; i i i I State the dates during which GARLOCX manufactured and/or If 'i distributedsaid products containing asbestos; ;i j I ji 1 I i l; State in detail all of the usesof each product containing ' asbestos manufactured ancyar distributed by GARLOCX; ji i (1) ANSWER: See Supplemental Sheet. I l UMM AMD OUIIIM ATTODMIVD AT LAW 04 AVAS A ONI FOIM. VIOlN> J ) 9 | O I 2 2. Stata In detail the labeling, licensing ancVar product line sales history for each product containing asbestos which GARLDQC manufactured anS/ar distributed. Include identificaticn of all other Btanufacturers, repadcagers cur distributors of each product containing asbestos from whan you bought asbestos products, with whan you traded raw materials or finished products anVar to whan you sold far relabeled reside asbestos-containing products, stating the beginning and ending j I dates that you did so. Your response shall carpietaly detail the history j of each and every asbestos containing product in which your oarpany or ompanies dealt in during its operational history. I (2) OBJECTION. This interrogatory is vague, overly broad, : unduly and unreasonably burdensome and oppressive and is beyond j the scope of permissible discovery in that it requests an | unreasonable and onerous volume of material and information completely unrelated to plaintiff's claim, both in terms of products and time periods. Thus, this interrogatory is not calculated to lead to the discovery of admissible evidence. j 1 . II 7/31/86 SUPPLEMENTAL ANSWER: i J1 Garlock Inc has sold gasket material bearing the Garlock and Belmont Brands. | Garlock Inc has applied customers' brands to compressed asbestos I sheet as follows: Customer: Approximate Years: Anchor Packing, Philadelphia, Pa. 1979 to present Sepco, Birmingham, Ala. 1973 to present Honest George, San Bemudino, Ca. 1979 to 1982 J. A. Sexauer, White Plains, N.Y. 1965 to present Vellumoid, Worcester, Ma. 1960 to 1980 Drew Chemical, Boonton, N.J. 1980 to present Garlock has no knowledge of customers buying unbraided sheet and applying their own brands to it. AND OLAMIH ATTOftMIY* AT CAW M4 ACAZA ONI ''OIN. VINO">4 >9*10 3 3. Describe In detail GARLOCX's complete corporate history, Including any mergers, consolidations, asset purchases, acquisitions or spin-offs having to do with the manufacture or distribution of asbestoscontaining products. In addition: If you have bought or sold any asbestos product line or stock in a ocnpany deeding in asbestos-containing products, state the date of the sale and identify the seller or purchaser; Identify each document related to the history or transaction (s) set forth above. State whether GARIDCK agreed to be or has been held to be legally responsible for the past liabilities of any nature of any other such corporation or entity. 3) ANSWER: See Supplemental Sheet. 4. State in detail and with caplets deecripticna all cxrpcnents (with percentage amounts) for each product containing asbestos manufactured anVor distributed by GARLOCK. Include aU product specifications, formulas, and technical deecripticns for each product. For any product containing asbestos with particular colors and/or designs, provide accurate representations in color of all products, including photographs, if available. A*KR AMD GlAPAKA TTOANSVA AT UW OA PIAZA ON| 'Oix. viiioiNi* duo (4) OBJECTION. This interrogatory is overly broad and is unduly and unreasonably burdensome and oppressive in that it requires an unreasonable investigation on the part of this defendant into information not readily accessible to this defendant and without limit as to time. Furthermore, this interrogatory is not reasonably calculated to lead to the discovery of admissible evidence and seeks information with respect to a great number of products to which plaintiff does not allege to have been exposed. Furthermore, this interroga tory seeks information with respect to a great number of time periods during which plaintiff could not have been exposed. In addition, the records related to the subject matter of this interrogatory are too voluminous and/or inadequate and/or unavailable to answer the interrogatory in its present form. Notwithstanding and without waiving the foregoing objection, this defendant states that it has manufactured and sold several hundred styles of packing and gaskets in one form or the other, many of which have contained asbestos. Many of these have not contained asbestos. These products fall into four general categories: compression packing, expansion joints, gasket and hydraulic components. Garlock gasket products are used to seal the ends of adjacent pieces of pipe. The gaskets and gasket material manufactured by Garlock which have contained asbestos have been approximately 50 percent to 80.^ percent asbestos by weight. Furthermore, more than 95 percent of the asbestos used in these products has been the chrysotile type. The remainder was crocidolite. Defendant Garlock Inc states that it has been marketing asbestos-contain ing gaskets and gasket material since at least 1907, and thus, various styles have been added and deleted over time. The records needed to prepare a complete answer to this interroga tory do not exist. Introduction, distribution and discontinu ance of styles has been a continuing process at Garlock for many years. Over the years, Garlock has discontinued the manufacture and sale of numerous styles of asbestos gasket . products. Also, as new and better products have been intro- 1 duced, older products have Tiecone obsolete and unprofitable. i / Continuation of answer to No. 4. Garlock Styles 900 and 7021 are compressed asbestos sheet. For Style 900, the percentage of asbestos fiber has ranged from about 75% to 85%, and for Style 7021 from approximately 72% to 83%. The basic formulation has not changed substan tially since at least the 1940's. When these styles were originally developed, they were made with natural rubber. During World War II, SBR elastomer (synthetic rubber) was developed as natural rubber was in very short supply. At some point which Garlock cannot specifically identify, but probably during World War II, the SBR elastomer was substituted for natural rubber. These styles have always contained only chrysotile asbestos fiber. Style G100 packing contains no asbestos fiber and never has contained any such fiber. Samples of Garlock Inc's gasket products have previously been provided to plaintiff's counsel in prior litigation, specifi cally, but not limited to Peggy E. Lawrence, Admx. of the Estate of Edward Delaware Lawrence v. Raymark Industries. Inc., et al. 5. Please state the name and address of each entity feta when GARIOCX has ever bought or received raw asbestos fiber, and as to each such transaction please state the following: fiber; The date and amount of each purchase or receipt of asbestos The seller or provider of the asbestos fiber; 3he type of asbestos fiber sold or provided (e.g., amosite, chrysotile or crocidolite); i j The use (Including the type of product the asbestos fiber was I used In) made of each sale or supply of asbestos fiber. j (5) OBJECTION: This interrogatory is beyond the scope of i permissible discovery, irrelevant and not calculated to lead to j the discovery of admissible evidence. Without waiving the foregoing objection, answering defendant, by way of further answer, states that the principal suppliers of raw asbestos were Johns-Manvi11e, Bell Asbestos Corporation, and Lake Asbestos Corporation. 7/31/86 SUPPLEMENTAL ANSWER: Prior to 1965, J-M, Bell Asbestos Mines Ltd. and Lake Asbestos of Quebec were principal suppliers of raw fiber to Garlock. Garlock no longer has records of its specific purchases prior to 1965. Since 1965 Garlock has purchased raw asbestos fiber from the following companies: (See attached sheet entitled "Garlock Purchases of Asbestos Fiber".) GARLOCK PURCHASES OP ASBESTOS FIBER 1965 to Present Fiber type Company 1. AA-Asbestos Fibre BL-TR H. K. Porter 2. AB-Blue Fibre No. American Asbestos Corp Lake Asbestos of Quebec 3. AC-Grade 3K Bell Asbestos Mines Ltd. Lake Asbestos of Quebec 4. AD-Grade 3R Bell Asbestos Mines Ltd. Asbestos Corp. Ltd. Lake Asbestos of Quebec National Gypsum Co. 5. AE-Grade 3T Bell Asbestos Mines Ltd. Asbestos Corp. Ltd. Lake Asbestos of Quebec National Gypsum Co. Jaquay Mining Corp. 6. AF-Cassier AC-45 Bell Asbestos Mines Ltd. 7. AG-Grade 4T The Rubberoid Co. Lake Asbestos of Quebec Johns-Manville Sales Corp. Westwood Chemical Co., Inc. National Gypsum Co. Jaquay Mining Corp. 7. AH-Grade 4A until 1974 then 5R Asbestos Corp. Ltd. Lake Asbestos of Quebec Westwood Chemical Co., Inc. Carey Canadian Mines Ltd. 8. AI-Grade 4D Lake Asbestos of Quebec Bell Asbestos Mines Ltd. 9. AJ-Grade 4K Lake Asbestos of Quebec Carey Canadian Bell Asbestos Mines Ltd. 10. AK-Grade 5D Lake Asbestos of Quebec Bell Asbestos Mines Ltd. The Rubberoid Co. National Gypsum Co. Johns-Manville Sales Corp. 11. AL-Grade 7D Lake Asbestos of Quebec GARLOCK PURCHASES OP ASBESTOS FIBER 1965 to Present Fiber type 12. AM-Plastibest 20 Company Lake Asbestos of Quebec Canadian Johns-Manville Johns-Manville Sales Corp. 13. AN-Plastibest 20 Pressure Packed 14. AO-Grade 7R 15. AP-Cassiar A 16. AR-Grade 7M 17. Miscellaneous & Experimental Lake Asbestos of Quebec Lake Asbestos of Quebec Westwood Chemical Co., Inc Bell Asbestos Mines Ltd. Lake Asbestos of Quebec Bell Asbestos Mines Ltd. Lake Asbestos of Quebec Canadian Johns-Manville Johns-Manville Sales Corp. The Rubberoid Co. 6. If GAKLOCK has, at any tine, been a member of any "trade organization" or "association" canpoGed of other miners, manufacturers, producers, processors, ccnpounders, ocnverters, sellers, merchandisers, suppliers, distributors and/or anyone otherwise placing in the stream of ocumerce products containing asbestos, state: The name and address of each such association or organization; The dates during which time you were a member; The names of any publications published by or written by such association or organization; The names and dates of membership of all other members of such association or organization. (6) A. ANSWER: Answering defendant has been a member of the following associations: Asbestos Textile Institute, P. 0. Box 471, 131 North York Road, Willow Grove, Pennsylvania, from approximately 1966 to 1979; Asbestos Information Association, from approximately 1974 to 1980; Fluid Sealing Association (formerly Mechanical Packing Association), 2017 Walnut Street, Philadelphia, Pennsylvania, from 1933 up to the present; American Society of Testing Materials, 1960 Race Street, Philadelphia, Pennsylvania, from 1945 to the present time. B. ANSWER: See No. (6)A. C. OBJECTION. This interrogatory is overly broad, unduly and unreasonably burdensome and oppressive and not calculated to lead to the discovery of admissible evidence in that this interrogatory requests information readily accessible to plaintiff from sources other than this answering defendant. D. OBJECTION. This interrogatory is overly broad, unduly and unreasonably burdensome and oppressive, and not calculated to lead to the discovery of admissible evidence in that this interrogatory requests information readily accessible to the plaintiff from sources other than this answering defendant. Furthermore, this interrogatory is beyond the scope of permiss ible discovery in that i-} requests information completely unrelated to plaintiff's claim against this defendant. Continuation of answer to no. 6 7/31/86 SUPPLEMENTAL ANSWER: Although its own records do not confirm membership in the ATI other than as stated above, Garlock is aware that ATI's records do reflect other periods of its membership. 7. If GARLOCX has ever nods any changes in tha work practices / anchor equipment used by GARLOCX's enployees to Unit their exposure to asbestos, state: The specific nature of each such change; The date(s) said changes ware put into effect; The reason the changes ware made; I I | (hat, if anything, was ocmounicated to your esployees concerning < i I these changes. i i . (7) OBJECTION: This interrogatory is not reasonably calcu lated to lead to the discovery of admissible evidence. The manufacturing methods of this defendant are not equivalent to the methods employed by end users or installers. . ; ' Howeiver, without waiver of the Obj ection, answering defendant says with regard to Garlock's text ile operation in Palmyra, New York, the fol lowing alterations have been documenited : Pre- 1928 Installed hoods over carding mi a c h i n e s ; installed exhaust f ans. 1928 Piping connected t o exhaust hoods. 1939 Further improvemen t to carding dust control. UtM* AMO OtA*Mft ATTOMCr AT LAW 8 j i Continuation of answer to No. 7 1956 Altered pneumafil system (vacuum system) installed on spinning frames to bring dust levels down from 5 or 6 mppcf to 1 to 1.5 mppcf; dust hoods designed for looms. 1957 Collecting cyclones with outdoor exhaust installed. 1970-1973 Studies regarding alterations to Palmyra plant to meet newest standards resulted in the decision that it was impractical to make the existing equipment meet the new stand ards. Garlock decided to build a new plant in Canada, equipped with all new machinery especially designed to meet the new stand ards. With regard to the compressed asbestos sheet operation in Palmyra, New York, Garlock purchased equipment consisting generally of an enclosed automatic bag opener and emptier, an enclosed fluffing device, an enclosed bag handling apparatus, an enclosed conveyer apparatus for transferring asbestos to appropriate mixers and blenders, and associated dust collection equipment. This equipment was purchased in 1977. 7/31/86 SUPPLEMENTAL ANSWER: A grinder, removed from the Garlock premises in 1977 was returned to the plant in 1981, but has since been used solely for grinding non asbestos containing materials. Garlock is unable to provide further information in response to this inquiry because any records which might pertain to changes in procedures or equipment have been discarded in the normal course of business. Garlock does refer this plaintiff to the records regarding the removal of the textile operation to Canada, which records were provided to plaintiff's attorney in September, 1985. 8. If GARLOOC has ever given any information to GARLOCX' employees oonoeming any potential hazards of exposure to asbestos, state The specific information given; J i II I The date(s) on which said information was given; 'i The manner in which said information was given; ij By when was said information given (give names and current t' [j addresses); - i ij To when was said information given (give names and current addresses); The name and current address of the custodian of any records oonoeming the information given. I (8) ANSWER; Such information has been produced to plaintiff's ' I counsel pursuant to Requests for Production in the case of | j Peggy E. Lawrence. Admx. of the Estate of Edward Delaware , Lawrence v. Raymark Industries. Inc., et al. Circuit Court of I I the City of Chesapeake, At Law No. 19513-M. I OUMI* AM OlAtM* ATT/ LAW 9 Continuation of answer to No. 8 In addition, since Garlock has used raw asbestos in various manufacturing processes since the early 1900's, upon informa tion and belief, oral warnings and instructions regarding housekeeping, have been given to employees for many years. Respirators have been available and their use encouraged in dusty areas since the 1930's. Respirators became mandatory for all in dusty areas by the early 1970's, as did the wearing of disposable, then cloth coveralls. Warning signs advising workers of the hazard of inhaling asbestos fibers were placed at plant entrances in the early 1970's and per the OSHA requirement. 7/31/86 SUPPLEMENTAL ANSWER: Garlock is unable to provide further information in response to this inquiry because any records which might pertain to changes in procedures or equipment have been discarded in the normal course of business. Garlock does refer this plaintiff to the records regarding the removal of the textile operation to Canada, which records were provided to plaintiff's attorney in September, 1985. 9 . Has GAKLOCX ever given medical examinations to GAKLDCX's employees who were exposed to asbestos? If so, state: When said examinations were given; Whether chest x-rays were included in the examination; The names and current addresses of the persons who conducted these examinations; Whether any employees who were found to have any abnormality were so advised. (9) ANSWER: A and B. For many years, Garlock's practice has been to get a pre-employment physical. Since the late 1940's, employees who worked with asbestos fibers have received regular x-rays. From approximately 1948 to approximately 1970, such x-rays were biannual, becoming annual thereafter. In approxi mately 1980, vital capacity tests were administered as well. The x-rays are read by an independent "B" reader. C. Garlock's retained part-time physicians have been: C. C. Nesbitt, 1920-1956 (deceased) J. D. Bramer, 8/1/56-7/24/72 (deceased) AMO OlAMIK ATTOAHir* AT UW IOA ALAIA ON| >orow. viaoinu mto 10 Continuation of answer to No. 9. Kapur, 10/23/72-8/14/79, 1269 Pittsford-PaImyra Road, Hacedon, New York 14502 William G Fallon, 10/31/79-present, 1666 Division Street, Palmyra, New York 14522 The p r e - em p l o y men t physicals have generally been done by the retained physician although certain portions of the examination and/or tests may have been administered by other than those physicians including nurses and/or personal at hospitals in the Palmyra, New York area. Until approximately 1979, x-rays were taken at the Clifton Hospital in Clifton Springs, New York, the Meyers Community Hospital in Scidus, New York, and/or the Newark Hospital in Newark, New York. In 1979, x-ray equipment was purchased for use in Garlock's in firmary. D. Yes. 10. Identify with particularity each lawsuit (including actions in which appeals are or may be pending, actions in which appeals are concluded, and actions which were subsequently settled) wherein the finder of fact, either Judge or jury, has found that GARLOCK is liable for punitive damages due to an asbestos-induced injury (including death) or disease that was alleged to have been caused, in whole or in part, by asbestos-ocntaining products that were alleged to have been manufactured, sold or distributed by GARLOCK. (10) OBJECTION. This interrogatory is overly broad and unduly and unreasonably burdensome and oppressive and is not reason ably calculated to lead to the discovery of admissible evi dence. In addition, this interrogatory requests information that is readily accessible to the plaintiff in this matter as to answering defendant. I Without waiver of its Objection, this defendant states that the answer is none. . 11 I 11. State when GARUXX received notice of any claim for illness, disease or death to ary of GARDOCK's employees or members of ' their immediate families as a result of their exposure to asbestos. I i i As to each claim state: The date said notice was received; The name and current address for each claimant; The specific disease or illness ocnplained of; i i The disposition of said claim, including benefits paid, if any; iI il i:J! j The name and current address of the custodian of any and all : documents concerning any such claim. !| I (11) ANSWER: The following Worker's Compensation claims have : been made by Garlock employees which appear to involve exposure . to asbestos fibers: I i i i iLAICM AMO OLA**f* ATTOftNCYS AT LAW ft* PIAXA ONI 12 I o ii L 1 n it ;i t i o i) of answer to No . 11. Name Dace of Claim Diagnosis Payment/ benefit total Job or Ubrk Place Dates Baylord. Grace Bacon. Clara Bohner, Elsie 11/14/57 1/20/71 6/7/73 Pulmonary Fibrosis; Pulmonary Asbestosis $ 2.400 Asbestosis $18,000 Secondary No Payment Asbestosis Textile Dept. 1923-1957 (Bqployment intermittent Total 22 years) Textile Dept. 1943-1970 Braiding Dept. 1951-1973 Honore, Martin D. 3/13/80 Thickened Pleura Case Pending Nb records - 1959-1960 Probably disc. duties in San Francisco Ware house and Gasket Shop Bills. Arthur 6/4/82 Asbestosis, Case Pending Textile Dept. 1950-1970 Pulmonary CUt Gasket Dept. 1970-1982 Fibrosis In addition, the following employees have made claims for conditions apparently relating to respiratory problems, but not documented or diagnosed to be related to exposure to asbestos fibers: Beadle. Harold 9/22/75 Metastatic tto Payment - Sundries Dept. 1938-1961 Carcinoma- non work re- Qual. Control coals laced illness Dept. 1962-1965 Textile Dept. 1965-1974 Gross. William 5/22/79 Ihknoun Case Pending Plastics Div.- 1956-1977 hblkilng Dept. Broun, Harold 2/26/80 DiStefano,Angelo 4/11/80 First - No Payment Bronchitis due to asbes tos inhala tion. Later- no evidence of aebestoeie High Pressure 1979-1980 Sheet Finisher Unknown $25,000 Plastics ftLv.- 1947-1979 Spiral Wbund Gasket Dept. Continuation of no. 11 7/31/86 SUPPLEMENTAL ANSWER: Attached please find Garlock's files on the claims of Vera Clemons and Clara Bacon. ll 12. State in detail the following concerning the first occurrence wherein GARIOCK was named as a defendant in an action to recover for disease or death as a result of exposure to asbestos. The date you were notified of the claim; The name and current address of the claimant; The name and location of the oourt in which the action was filed and the number of the action; The specific disease or illness ccnplalned of; The name and address of the attorney fear the claimant; I The disposition of such action, whether settled, verdict or appeal; if funds paid, the total amount thereof and the amount contributed ! by each co-defendant; ; The name and current address of the custodian of the files ' involving the above actions. , (12) ANSWER: Plaintiff State Featherstone Tx. Court U.S.Dist. Cour t, Eastern District Number Date of Service M-74-44-CA (Marshall) B-76-167-CA (Beaumont) 7/28/75 >LABn ANO OUIII* ATT**!** AT 1AW OA riAZA ONI *rOCA. V0'***4 **T0 13 1 j 13. Please state whether GARIOCK at any time ever or . considered the possible irpact that warning users about asbestos hazards 1 wculd or oould have on sales as well as what iapact greater public i knowledge of asbestos hazards would or oould have on sales. If so, please identify and produce all documents pertaining to each such discussion or consideration. (13) ANSWER: Defendant is not aware of any such discussions or considerations. l 1 I j I i i i CAISIA AND OLAAASA ATtOMNIVI AT LAW IM PLA2A ONI *'olm. vmomi* ao 14 t 14. As to each product containing asbestos manufactured and/or distributed by GARLDCK, state whether any of said products were shipped by GARIOCX with any cautionary language cn the product itself. (14) ANSWER: See No. 15 below. 15. If any cautionary language over appeared on the package of ary product containing asbestos manufactured ancyar distributed by GARLOCK, state the specific dates during which said cautionary language appeared and state In detail the specific language that was used giving its size and location cn the package. (15) ANSWER : All Garlock asbestos-containing products have carried a warning label since late 1977. The warning label states as follows: "CAUTION: contains asbestos fibers. Avoid creating dust. Breathing asbestos dust may cause serious bodily harm." The aforesaid warning comes in a variety of sizes depending on the size and style of the product to which it is attached. The aforesaid warning has a white background with black lettering. Usually, a warning has been displayed by way of an oval, stick-on label, appended to the product or package. In addition, compressed asbestos sheet material which carries the Garlock brand has the aforesaid warning statement printed on the face of the sheet at regular intervals. i 16 I liI i 1 16. With regard to any product containing asbestos manufactured and/or distributed by GARLOCK without cautionary language on the package i or on the product itself, has GARLDCK ever recalled the product for the I purP06 of affixing cautionary language describing the health hazards of : exposure of human beings to asbestos and/or hew the product could be ! safely used. (16) ANSWER: No. Since the asbestos-containing products of ! Garlock Inc are bonded and/or coated and/or encapsulated in < elastomers and/or treated in such other manner as to prevent ; the emission of meaningful levels, if any, of asbestos dust and i fiber when used in the manner for which they are intended, no such recall would be necessary. I I 1 'I ;i1jI Claim* ano Claim* ATTOANIft Af LAW *04 ONI 17 i \ | 17. State in detail the instructions on safe use, warnings and ; cautionary notes supplied to the end user by GARLOCK with each product J ocntaining asbestos manufactured and/or distributed by GARLOCK, including ,j the date(s) supplied and how supplied. i i (17) ANSWER : Since Garlock Inc's products are bonded, . encapsulated or otherwise treated and thus do not emit meaning ful levels, if any, of asbestos dust and fiber, they fall within the exception to OSHA regulations otherwise requiring warnings on asbestos products and materials. Nevertheless, Garlock places the warning otherwise required by 1910.1001, paragraph 2 (ii) of OSHA regulations on its produ-cts. The ' warning reads as follows: "CAUTION: contains asbestos fibers. Avoid creating dust. Breathing asbestos dust may cause serious bodily harm." The above warning has been applied to all Garlock asbestoscontaining products since late 1977. In addition, answering defendant has issued advertising flyers and brochures for some of its asbestos-containing products. See No. 15 above. *No Gl>ihh ATTOMNIVI AT IAW PIA1A OMC >**014. VtAQINlA 1)9(0 l> 18 18. Does GARLDCK contend that Plaintiff or any employer of the Plaintiff improperly used products containing asbestos manufactured and/or distributed by GARIOCK? If so, please set out in detail in which respect each said product containing asbestos was improperly used. (18) ANSWER: Investigation is continuing; further information | will be provided. : l 19. When did GARLOCK first receive any informsticn that exposure to asbestos might cause ary illness or disease. (19) OBJECTION. This interrogatory is vague, overly broad and unduly and unreasonably burdensome and oppressive and is not reasonably calculated to lead to the discovery of admissible vv i d e n re. Notwithstanding and without waiving the foregoing Objection, this defendant answers that although individual employees of Garlock Inc through membership in various trade organizations, such as the Asbestos Textile Institute, may have been aware of the alleged dangers of exposure to asbestos dust, this defen dant states that its knowledge of the alleged hazards of asbestos inhalation cannot be equated with any knowledge of an existence of a hazardous potential asbestos from the use of its products, since there has never been any evidence that its products have caused or contributed to any hazardous condition. Furthermore, since the asbestos fibers in Garlock*s products are encapsulated and/or bonded and/or treated in such a manner as not to emit meaningful levels, if any, of asbestos fibers, the receipt of any such information of Garlock Inc would be 'irrelevant. . Garlock has contacted its pertinent management and sales executives to determine if information beyond that documented in Garlock's files is available. No such individual contacted has any personal recollection of the receipt of such informa tion to exposure hazards in the minutes of the ATI. 7/31/86 SUPPLEMENTAL ANSWER: See attached page for typographical correction to 4/28/86 answer and 7/31/86 supplemental answer. I AM OLUMI9 PIAU I 20 19. ttwn did GAKLXK first naive anv infannaticn that exposure to asbestos might cause ary illness or disease. (19) OBJECTION. This interrogatory is vague, overly broad and unduly and unreasonably burdensome and oppressive and is not reasonably calculated to lead to the discovery of admissible ev idence. Notwithstanding and without waiving the foregoing Objection, this defendant answers that although individual employees of Garlock Inc through membership in various trade organizations, such as the Asbestos Textile Institute, may have been aware of the alleged dangers of exposure to asbestos dust, this defen dant states that its knowledge of the alleged hazards of asbestos inhalation cannot be equated with any knowledge of an existence of a hazardous potential asbestos from the use of its products, since there has never been any evidence that its products have caused or contributed to any hazardous condition. Furthermore, since the asbestos fibers in Garlock's products are encapsulated and/or bonded and/or treated in such a manner as not to emit meaningful levels, if any, of asbestos fibers, the receipt of any such information of Garlock Inc would be inapplicable. Garlock has attempted to contact its pertinent management and sales executives to determine if information beyond that documented in Garlock's files and disclosed in earlier answers to these Interrogatories is available. No such individual contacted to date has any personal recollection of the receipt of such information prior to the early reference to exposure hazards in the minutes of the ATI. See attached page for 7/31/86 supplemental answer. Continuation of no. 19 7/31/86 SUPPLEMENTAL ANSWER: Garlock Inc has no records or any other way of establishing when it first knew that asbestos might cause any illness or disease. However, Garlock Inc has used raw asbestos and other fibers in its manufacturing processes and Garlock Inc employees knew by at least the mid to late 40's that exposure to dust through the use of such fibers in its manufacturing processes could possibly be harmful to its employees. The quantity of dust to which the employee was exposed was of prime importance as evidenced by the various hygiene standards which set limits for exposure. Evidently, the focus among industrial hygienists at that time was to reduce the levels of dust to which the workers were exposed in the manufacturing processes. As a responsible employer, Garlock Inc has always attempted to provide its employees with safe working conditions and to abide by applicable local, state and federal rules and standards. Since the products manufactured by Garlock Inc, which contained asbestos were encapsulated in various binders or were otherwise treated so as to virtually preclude emissions of asbestos fibers, Garlock Inc did not then and does not now have any knowledge, evidence or reason to believe that exposure to its asbestos-containing products could result in any asbestos-related disorders. 20. As to each asbestos associated disease (asbestceis, lung cancer, mesothelioma, etc.) of which GARLOCK is presently aware, state the date that GARLOCK first received any information that said disease prrv^q might be caused by exposure to asbestos. (20) ANSWER: See No. 19 above. In addition, no such individual contacted can recall when he first learned which particular diseases have been related to excessive exposure to asbestos fibers. 7/31/86 SUPPLEMENTAL ANSWER: See attached sheet. Continuation of no. 20 7/31/86 SUPPLEMENTAL ANSWER: Garlock Inc has no records or any other way of establishing when it first knew that asbestos might cause any illness or disease. However, Garlock Inc has used raw asbestos and other fibers in its manufacturing processes and Garlock Inc employees knew by at least the mid to late 40's that exposure to dust through the use of such fibers in its manufacturing processes could possibly be harmful to its employees. The quantity of dust to which the employee was exposed was of prime importance as evidenced by the various hygiene standards which set limits for exposure. Evidently, the focus among industrial hygienists at that time was to reduce the levels of dust to which the workers were exposed in the manufacturing processes. As a responsible employer, Garlock Inc has always attempted to provide its employees with safe working conditions and to abide by applicable local, state and federal rules and standards. Since the products manufactured by Garlock Inc, which contained asbestos were encapsulated in various binders or were otherwise treated so as to virtually preclude emissions of asbestos fibers, Garlock Inc did not then and does not now have any knowledge, evidence or reason to believe that exposure to its asbestos-containing products could result in any asbestos-related disorders. j! i i / j 21. Has GARLOCK ever consulted with any entity or i ; experts in order to determine the existence of any potential hazard of i| exposure to asbestos. If so, state: The date(s) of the consultation (s); Hie names and current addresses of said entities or medical experts; What was learned from said consultation; What was done as a result of said consultation; Hie name and current address of the custodian of the information received; (21) ANSWER: No. Since the asbestos-containing products of Garlock Inc are bonded and/or coated and/or encapsulated in elastomers and/or treated in such other manner as to prevent the emission of meaningful levels, if any, of asbestos dust and fiber when used in the manner for which they were intended, no such consultation has been necessary with regard to Garlock prod uc t s. ID Gl< ONI |il 22 22. State whether or not any research car tests were ever conducted by GARIDCX, or at GARLOCK's request, to determine the health hazards associated with the exposure of human beings to asbestos. If so, state the date(s) of the research; the name and current address of anyone connected with conducting said research; and the results of said research. (22) OBJECTION. This interrogatory requests att-orney work product and information prepared in anticipation of litigation; contains a presumption of health hazards associated with this defendant's products. Subject to the foregoing objection, defendant Garlock Inc, by way of further answer, states that because the defendant's asbestos products are bonded and/or encapsulated, and do not, therefore, emit harmful levels of asbestos dust, if any, no such tests, other than those performed in preparation for asbestos litigation, were necessary, and no tests were con ducted. 7/31/86 SUPPLEMENTAL ANSWER: Pursuant to the Court's Order that Garlock supplement its response to this interrogatory in light of the alleged "Hemeon Report" and without waiver of any objection it may have to any reference to the said report: at trial, Garlock states that it did not ccnmission the said report, nor did it conduct any of the research referenced therein. Accordingly, its answer to this interrogatory remains unchanged. laisc* and Gcassia attomniti at caw 004 PCAZA ONI rou. viao'ni* nn ii 23 23. List all literature or medical articles of which GARLOCK is aware which deal with illness, sickness or ^ to exposure to asbestos. Specify the date, month and year of each such article and hew long after publication GARLOCK became aware of the existence of the article. (23) OBJECTION. This interrogatory is overly broad, unduly and unreasonably oppressive and is not reasonably calculated to lead to the discovery of admissible evidence in that it seeks information with respect to literature and research, much of which is, as to the products manufactured by Garlock Inc, irrelevant, since the asbestos products of the answering defendant are bonded and/or encapsulated and/or treated in such a manner as not to emit meaningful levels, if any, of asbestos fibers. 7/31/86 SUPPLEMENTAL ANSWER: Garlock does not, and never has, maintained a medical library. It is unaware of what articles its contract physicians may have read or become aware of. While various employees may have from time to time become aware of such articles, it knows of no Garlock records which document the same. Garlock has become aware of certain articles and list of articles through pleadings filed by various parties in various jurisdictions in other asbestos litigation, but understands that such information is not sought or required to be produced. 24 I 24. If any enplcyee car agent of GARLOCK has ever testified I | before any governmental agency or body regarding the health hazards j associated with the exposure of human beings to asbestos? j (24) ANSWER: Yes. State: ij The name(s) and current address(es) of the person(s) giving such ! testimony; j (24) A. ANSWER : Alexander Kuzmuk, 31 Selborne Chase, FairI port. New York 14450, presented a prepared statement setting i forth the position of ATI. At the time, he was an employee of j' Garlock. j) The governmental agency or body before whan such testimony was : given and the date(s) of such testimony; (24) B. ANSWER: United States Department of Labor, Office of i the Secretary, Washington, D. C. Whether the person (s) testifying prepared a written statement of GARLOCK's position; (24) C. See Attachment. The present location of such prepared statement, including the name and current address of the custodian of such statement; (24) D. See Attachment. Whether a transcript was made of the testimony given; (24) E. ANSWER: Unknown. If a transcript of such testimony was made, attach ocpies of all such transcripts. 25 25. Has GAKLOCX manufactured for and/or distributed to RAYMAKK INDUSTRIES, INC., GWENS-OORNING FTPffTGIAS CCRPCRATICN, OWENS-IUINOIS GIASS CCMEANY, PITTSBURGH COINING CCRPCRATICN, GAF CCFPCRATICK, THE CELDTEX OOHPCRAIICN, H. K. PCKEER CCMPANY, INC., SOUTHERN TEXTILE CX3RFGRAITGN, EAGLE-PTCHER INDUSTRIES, INC., KEENE OCKFCRATICN, C. E. THURSTCN & SONS, INC., WRIGHP-YCRK OCRPORATION, BAKER AND OCMPANY, and/or any other business or entity selling asbestos-ccrrtaining products to heating and air conditioning contractors in Norfolk, Portsmouth, Virginia Beach, Chesapeake, Suffolk, Hampton and/or Newport News, Virginia, any products containing asbestos. If your answer to the preceding interrogatory is in the j affirmative, state: The name of the ocnpany to which products containing asbestos were distributed; Whether said product (s) was manufactured and/or distributed by GAKLOCK directly or through an agent, subsidiary, or other ocnpany; The date(s) said product containing asbestos was manufactured and/or distributed; The trade name of said product (s) manufactured and/or distributed; The quantity of said product(s) distributed; 26 The manufacturer(s) of said products containing asbestos; The narne(s) and current address(es) of any individual (s) employed by you or formerly employed by you who have knowledge of such distribution. (25) OBJECTION. This interrogatory is overly broad, unduly and unreasonably burdensome and oppressive, beyond the scope of permissible discovery and is not reasonably calculated to lead to the discovery of admissible evidence in that it requests Information with respect to a great number of products and time periods to which, and during which, plaintiff could not have been exposed. Further, the terms "and/or any other business or entity, etc." is vague and does not give sufficient informa tion to allow an intelligent answer. . Without waiver of the foregoing Objection, answering defendant states that C. E. Thurston & Sons, Inc., Wright York Corpora tion and Baker & Company were not distributors of Garlock Inc products. There may have been sales to the other named corporate entities but such sales would have been for in-house use and not for resale or distribution. 1I I II [I II |i klUMIII AND OLAASCR dSeLattounkyr at law R*T- MM PLA1A ONI plMOCK. VIAOINIA 1*510 27 j 26. As to the products containing asbestos manufactured and/or distributed by GARXOCX, has GAKLDCX ever advised WRIGHT-YORK (X&PCRATICN, BAKER AND OCMPANY, and/or any other business or entity selling asbestosoontainlng products to heating and air conditioning contractors in Norfolk, Portsmouth, Virginia Beach, Chesapeake, Suffolk, Hampton and/or Newport News, Virginia, or the employees of the above ocnpanies, businesses or entities of any potential hazards of exposure of human beings to asbestos or hew to safely use products manufactured and/or distributed by GARLOCX containing asbestos? If so, please summarize the advice given and state the name(s) and address (es) of all persons enplcyed or formerly employed by GARIDCK who have knowledge of said advice; the name(s) and address (es) of all persons enplcyed or formerly enplcyed by the above ocnpanies, businesses or entities who have knowledge of said advice; and the date(s) said advice was first given. ! i (26) OBJECTION. This interrogatory is so unduly vague as to the meaning of "safely use" that the answering defendant is without knowledge or information sufficient to answer this interrogatory. . ' > Subject to and without waiving the foregoing Objection, answering defendant states, that over the years, it has always provided its customers with instructions as to the proper handling "installation and use of its products. Such instruc tions have been in various forms, including instruction sheets, advertising literature. Also see Nos. 15 and 17 above. i 27. tihat infaaaticn, if ary, \ma ever given by FAYMARK INDUSTRIES, INC., OWEN9-OCRONG FIBERGIAS OCRFCRATICW, OWENS-IIIINOIS GLASS GCMPANY, PITTSBURGH OWNING CCRFCRKTZCN, GAP OCRFCRMTCN, THE CEC0ZHX CCRFCRATICN, H. X. FCRHR OCMPANY, INC., SCUIHEPN TEXTILE OCRPCRATICK, EA3LE-P1CHER INDUSTRIES, INC., KEENE CCRFCRATICN, CR C. E. THDRSTCN & SCNS, INC., to GARDDCX regarding the potential health hazards of exposure to asbestos? (27) ANSWER: None. Since the asbestos products of answering defendant are bonded and/or encapsulated and/or treated in such a manner as to prevent the emission of meaningful level, if any, of asbestos dust and fiber when used in the manner for which they were intended, no such communication would be relevant or applicable. AND OUMM *'--AT LAW rj**PlASA OM VMDINIA ISttO 29 II I 28. that infconation, if any, was ever given by GAKLOCK to RAXMAHK INDUSTRIES, INC., CWEN5-CCRNING FTEERGIAS CCRFCRA1TCN, CWENS- nUNOIS GLASS COMPANY, PITTSBURGH CCRNING CERFCRAITCN, GAP OCFFCRATICN, THE CELOTEX CERPCRATICN, H. K. PORTER CCMPANY, INC., SCUIHERN TEXTILE CCRPCRA1TCN, EAGLE-PXCHER INDUSTRIES, INC., KEENE CERPCRATICN, CR C. E. THURSTON & SCNS, INC., regarding the potential health hazards of exposure to asbestos? (28) OBJECTION. This interrogatory is overly broad and unduly and unreasonably burdensome and oppressive and is not reason ably calculated to lead to the discovery of admissible evi dence. Furthermore, this interrogatory is unreasonably and excessively vague as to the meaning of the terminology "poten tial health hazards of exposure to asbestos". Subject to and without waiving the foregoing Objection, answering defendant states that since the asbestos products of answering defendant are bonded and/or encapsulated and/or treated in such a manner as to not emit meaningful levels, if any, of asbestos fibers, when used in the manner for which they were intended any and all communications regarding potential health hazards of exposure to asbestos are not applicable to answering defendant. I LAaftKM AND GLAftftCA ATTOANCY* AT LAW 904 PLAZA ONI >*FOLK. VI AO I NIA 29910 30 Respectfully submitted, WILLIAM S. OVERBY Richard S. Glasser Ronald F. Schmidt H. Seward Lawlor Glasser and Glasser Suite 504 - Plaza One Norfolk, Virginia 23510 CERTIFICATION I hereby certify that a true copy of the foregoing pleading was mailed or hand-delivered to counsel of record this ______ day of January, 1986. SUPPLEMENTAL SHEET 1. OBJECTION. This interrogatory is overly broad, unduly and unreasonably burdensome and oppressive and not calculated to lead to the discovery of admissible evidence in that it seeks information with respect to numerous products many of which the plaintiff does not allege to and could not have been exposed. Subject to and without waiving the foregoing Objection, Garlock Inc answers as follows: Answering defendant has manufactured and sold asbestos-containing packing and gasket materials. The asbestos contained in these products is bonded and/or encapsu lated in elastomers and/or coated and/or treated in such other manner as to the prevent the emission of meaningful levels, if any, of asbestos dust and fiber when used in the manner for which they are intended. Furthermore, Garlock Inc has never been engaged in the mining of asbestos or any material containing asbestos. A. ANSWER: All asbestos-containing products or packages of answering defendant have borne the name Garlock. Secondary trademarks used include Belmont, Paperpak, Lattice Braid, Chevron and Guardian. B. ANSWER: Although the exact dates of manufacture of each product are unknown, Garlock Inc has been marketing asbestoscontaining gaskets and gasket materials since at least 1907. Any records pertaining thereto would have been destroyed in accord ance with Garlock's record retention and destruction policy. C. ANSWER : Garlock gaskets are and have been used primarily for sealing the ends of adjacent pieces of pipe and/or other equipment in fluid lines. 3. OBJECTION. This interrogatory is overly broad, unduly and unreasonably burdensome and oppressive and is beyond the scope of permissible discovery in that it requests an unreasonable and onerous volume of material and information completely unrelated to plaintiff's claim, both in terms of products and time periods. Thus, this interrogatory is not calculated to lead to the discovery of admissible evidence. Notwithstanding and without waiving the foregoing Objection, this defendant states that The Garlock Packing Company was originally incorporated in New York on March 27, 1905. Prior to 1955, The Garlock Packing Company acquired the following four companies each of which made and/or sold some asbestos-containing sealing products substantially similar to those made and/or sold by Garlock: The Belmont Packing and Rubber Company, Crandall Page 2 - Supplemental Sheet Packing Company, Dealers Steam Packing Company and U. S. Gasket Company. Ultimately, each of these subsidiaries was merged or otherwise absorbed into Garlock, including all assets and liabilities. On April 25, 1960, the name The Garlock Packing Company was changed to Garlock Inc. On March 3, 1975, a Delaware corporation of the same name was incorporated and on May 12, 1 975 , the New York corporation was merged into the Delaware corporation. On November 25, 1975, Colt Industries of Ohio was incorporated in the State of Ohio and on January 28, 1976, Garlock Inc was merged into Colt Industries of Ohio, which immediately changed its name to Garlock Inc. March 13 1972 iNTLKKOGATOK > i\U. 2U A'J i'AUiMt.N J Mr. Arthur M. Goldberg Hearing Examiner u. S. Deoartnent of Labor Office of the Under Secretary v.'a shi ng ton , D. C. 20210 . Re: Hearing on Proposed Standard For Exposure To Asbestos Dust Beginning on March 10, 1972 Dear Mr. Goldberg: My name is Alex Kuzmuk. I am a member of the Board of Governors of the Asbestos Textile Institute. I am here today to officially represent and state the position of the Asbestos Textile Institute and its member companies. . Wc are in opoosition to the proposed asbestos dust standards as published in the FEDERAL REGISTER, January 12, 1972. Wc are also oDoosed to recommendstions proposed in the NIOGH criteria package, and by the Asbestos Advisory Committee. The asbestos textile industry, which this association represents, includes over `1000 job opportuni ties in manufacturing, plus, approximately 35,000 job opportuni ti es in related product fabri cation and sales. The gross business volume for manufacturing alone is over $}0 million per year. The gross volume for related fabrication and sales is, therefore, many times this amount. Although this is not the largest segment of the asbestos industry, it is a very important one. Our product lines include the manu- ^-e of safety garments, insulations, clutch facings, brake ^'inin<_s' paper dryer felts, mechanical packings and gaskets, laminsbed plastics, and many other commodities essential to today technological progress. in many instances, there are no kncnwn substitutes for asbestos textile materials. Subsecnuent to the enactment of the Occupational Safety and Health Act, the threshold limit value for asbestos dust was reduced from 5 million particles per cubic foot of air to 12 fibres per milliliter, 5 microns or greater in length. We, in the asbestos textile industry, made every possible effort to meet the 12 fibre threshold limit value by re-engineering dust hoods and dust collection equipment on cards, spinners, loo/ns, and ma/w other types of equipment. In addition, many of us initiated wet weaving and made extensive additional changes in orocesses and materials. When the further reduction to the threshold limit value for asbestos dust was published on December 7, 1971, we began all over again to study plans for revising equipment, processes, and materials, for which we had just spent thousands of dollars to install to meet the 12 fibre level. y.any of us have not, and cannot, reduce our dust levels to the emergency and proposed 5 fibre threshold limit value. If engineering to a 5 fibre level were feasible on the complex types of machinery and equipment used in the textile industry, the cost of implementation would make it extremely doubtful that this industry could survive economically. We are presently being pressed to the wall by our competitors. The cost of a United States Public Health Service to conduct an epi demi ologi ca 1 study of our asbestos textile industry. We recognised then that a potential health problem existed and. therefore. we wanted expert advice and assistance to help us solve it. We have neither received the advice nor the assistance which we had booed for. We oDcned our plants to the United States Public Health Service Dorsonnel for environmental studies, review of our records, and physical examinations of our people. Our member companies urged emoloyee on r t: i ci pa t i on in the study, and a substantial represent ative group of workers were involved. We continually requested the United States Publ i c Health Service to increase their efforts and Drovide interim progress reports. The Public Health Service Asbestos Study of which I speak has not been completed. A recent report, which is a primary factor in the rccommendations by NIOSH and the Advisory Committee, was based on this incomplete study. The information provided in the renort was based on opinion and speculation, rather than fact. Had the Uni ted States Public Health Service Asbestos Epidemiological Study been completed as continually requested by the Asbestos Textile Institute, we might now be in a position of having factual information as to what the safe threshold limit for asbestos dust really should be. One factor is pertinent to this point. The asbestos related .yjseasc- involvement in the asbestos textile industry is being related to asbestos dust exposure levels as they presently exist rather than at the time the disease was incurred 25-30 years ago. Such a comparison is invalid. All of the past monitoring for asbestos dust in American textile plants has been clone using the impinger method for sampling. Today's proposed standards are based on a fibre level using the Milaporc filter method for sampling. 'There is no accurate correlation of impinen counts versus Milaporc filter counts established to date. There has been so me- work done by the United States Public Lea 1 Mi bervi,; but the results are incomplete. This is but one a re* a that dem onstrates the need for further health research studies and eval uations before unnecessary ly creating an unrealistic standard that can be the demise of this industry and its related job oppor tunitios. We respectfully urge the Secretary of Labor to: ('ll Per :<>ns i dur the establishment of asbestos standards.- (2) reinstate the thres hold limit value for asbestos dust at 12 fibres per mi Mil iter, 5 microns or greater in length for an interim period pending a compr ehuns i ve epidemiological study of the entire asbestos in dustry in the United States. I would like to point cant th.it: many comparisons have been made between the Hritish and United States asbestos textile industry concerning health problems. The vast differences in materials, equipment and processes make such comparisons imrc.ili Jtic, (3) Provide for represen ta t i on of the Asbestos Textile Institute on future advisory and study / LtteczZ I would als.no like to point out that , ,. rr ny etai1^ reouire- rncnts are included in" `he proposed, standard, it is ,* ' ^ as absolutelv mute on the- veryy imPDonrrti-emnft ,, ^U. ca, l,ly substantiated problem ,,*3 cigarette o,,s as associated with exposure to ,sb , ` co asbestos fibre. wc' of the /''7h'--"os Textile Industry havo ^ Y- avc -hc greatest desire to prevent tannery to our emoloyees We k i *y - We be * a eve this Can be accomplished ^xthont destroying the lsh,ef 9 C <1Sbcstos textile industry. Thank -vou fro r the .nrr.'wviic1 x.e of appearinc at thi- h . " hcarnfj today. Very truly yours. Trees^r/ anrsi Member of Booird of r.ovee r no r s for the Asbestos Textile Institute ik :jC VERIFICATION HAROLD RETTING, hereby states that he is the General Counsel to the within defendant. Garlock Inc, and verifies that the statements made in the foregoing Responses of Garlock Inc to Plaintiff's Initial Interrogatories are true and correct to the best of his knowledge, information and belief. The undersigned understands that the Statements therein are made subject to the penalties of law relating to unsworn falsification to authorities. date: <A\a.e>\p^ CERTIFICATE This is to certify that a true copy of the foregoing Responses of Garlock Inc to Plaintiff's Initial Interrogatories was mailed to all counsel of record this day of isx'v\ 1986. <fC, ? James C. Snannon Frederick G. Rockwell, III DUANE AND SHANNON, P.C. The Joynes House 209 West Franklin Street Richmond, Virginia 23220 VERIFICATION HAROLD RETTING, hereby states that he is General Counsel to the within defendant, Garlock Inc, and verifies that the statements made in the foregoing 7/31/86 Supplemental Responses of Garlock Inc to Plaintiff's Initial Interrogatories are true and correct to the best of his knowledge, information and belief. The undersigned understands that the statements therein are made subject to the penalties of law relating to unsworn falsification to authorities. DATE: HAROLD RETTING CERTIFICATE This is to certify that a true copy of the foregoing 7/31/86 Supplemental Response of Garlock Inc to Plaintiff's Initial Interrogatories was mailed to counsel of record this day of __________ ., 1986. James C. Shannon Harley W. Duane, III B. Craig Dunkum DUANE AND SHANNON, P.C. The Joynes House 209 West Franklin Street Richmond, Virginia 23220