Document om9Q7pN1dDqD20Kp84V7Gq6ao

IN RF : IN THE UNITED STATES DISTRICT COURT . FOR THE WESTERN DISTRICT OF NORTH CAROLINA ASBESTOS-RELATED LITIGATION NO. WDCF-03 WESTINCHOUSE ELECTRIC CORPORATION'S RESPONSES TO PLAINTIFFS' STANDARD INTERROGATORIES TO ALL DEFENDANTS ' '-t u- , 'Westi nghouse Electric Corporation ( "Westinghouse" ) , pursuant to Federal Rule of Civil Procedure 33 arid paragraphs 17(d) and 1B (d ) of the Initial Pretrial Order Coordinating Proceedings filed in the Western District of North Carolina styled In Re: Asbestos Related Litigation, No. WDCP-83-1 , responds to plaintiffs' interrogatories as follows: GENERA.L OBJECTION "Westi nghouse is a broadly diversified corporation chat currently employs approximately 112,000 people and manufactures in various countries some 7,500 basic products with approximately 300,000 variations of those products. Although Westinghouse is engaged principally in the manuf act.ure, sale and service of equipment and components for the yenei at:ion, transmission, utilisation and control of electricity, its businesses aLso include a wide ranee of products and services that are unrelated to electrical manufacturing. Many of the products that Westinghouse manufactures and sells are very complex and consist of hundreds or thousands of components.. Many of the components, as v/e I 1 as materials, are supplied to Westinghouse by other ccmpan i es Westinghouse does not lave records to idordify the .-exposition of each product from each of it.- suppLie-rs. Similarly, r.-jliouse does not knew the member of organizations of the asbestos industry, including National Insulation Contractors Association or the Asbestos Information Association. Westinghouse currently is, or has been a member of: (a) National Safety Council (charter member) (b) Industrial Health Foundation (1935-1984) (c) American Industrial Hygiene Foundation (1978-present) Westinghouse objects to reviewing its records to identify organizations to which its employees (past or present) may have belonged over the past years. Furthermore, there is no central repository of such information. Individual Westinghouse health and safety professional employees have belonged to various professional, trade, industrial and safety, hygiene or health organizations and research foundations or organizations such as the American Industrial Hygiene Association, Health Physics Society, and the Society of Safety Engineers. Westinghouse's records do not include the dates individual memberships were commenced or terminated and who, if anyone, attended meetings. 75. Identify all persons attending on your behalf any meetings held by any trade organization listed in the Interrogatory stated above. Answer to Interrogatory 75 See Westinghouse1s response to Interrogatory 74. 37 COMMONWEALTH OF PENNSYLVANIA COUNTY OF ALLEGHENY SS: Before me, the undersigned authority, a Notary Public in and for said Commonwealth and County, personally appeared R. E. Peters, who, being duly sworn, deposes and says that he is ASSISTANT SECRETARY OF WESTINGHOUSE ELECTRIC CORPORATION, and that he signs the foregoing RESPONSES TO PLAINTIFFS' STANDARD INTERROGATORIES TO ALL DEFENDANTS AND SUPPLEMENTAL INTERROGATORIES on behalf of -that defendant and is duly authorized so to do; that the matters stated in the foregoing document are not necessarily within the personal knowledge of deponent and that deponent is informed that there is no officer of WESTINGHOUSE ELECTRIC CORPORATION who has personal knowledge of all such matters; and that the facts stated in the foregoing document have been assembled by authorized employees and counsel of defendant and deponent is informed by those authorized employees that the facts stated in the foregoing document are true. SWORN TO and subscribed before me this R. E. PETERS Assistant Secretary RE6cCCAS TATE. NOTARY PUBLC PlTTSSURGH. ALLEGHENY COUNTY MYCC,',,*'Si`-C'N EXPiRf.SOCT 26. Uj' 62 WESTI1 l < David N. Allen Chris M. Kallianos PARKER, POE, THOMPSON, BERNSTEIN, GAGE & PRESTON 2600 Charlotte Plaza 201 South College Street Charlotte, North Carolina 28244 (704) 372-9000 Robert E. Thackston McGUIRE, WOODS, BATTLE & BOOTHE One James Center Richmond, Virginia 23219 (804) 644-4131 CERTIFICATE OF I hereby certify that a truezc py ' .n was mailed first class, postage pre> ' :n 1989 to the following Mona Lisa Wallace, Esquire WALLACE & POPE 301 North Main Street Salisbury, North Carolina 28144 Attorney for Plaintiff Michael J. Brickman, Esquire NESS, MOTLEY, LOADHOLT, RICHARDSON / Post Office Box 1137 Charleston, South Carolina 29402 Attorney for Plaintiff Gary S. Parsons, Esquire Dorothy V. Kibler, Esquire BAILEY & DIXON P. 0. Box 12865 Raleigh, North Carolina 27605 Attorneys for Virsrco 63