Document omwOyGZ240XKQMgpnaY5DJ5gg

IN THE CIRCUIT COURT OF JACKSON COUNTY. MISSISSIPPI PHILIP SCORDIHO, ET AL VERSUS OWENS-CORNINC EBERGLAS r^RPORATTON, ST AL PLAINTIFFS NO. >9-5139(3) DEFENDANTS DWIGHT COPELAND, ET AL VERSUS JOE W. MARTIN, JR. KIRK a METROPOLITAN LIFE INSURANCE COMPANY, ET AL PLAINTIFFS NO. 89-5142(3) DEFENDANTS WESTINGHOUSE ELECTRIC CORPORATION * S SUPPLEMENTAL RESPONSE TO PUINIXfJS 'IWSRRPSAIPBIES..AND.BEQUEST.. MR PRQPUCIION TO DEFENDANTS IN PHASE I PROCEEDINGS INTRCPVCIIPI* Defendant, Westinghouse Electric Corporation ("Westinghouse"), by and through counsel, provides the following supplemental response to ita Juna 15, 1990 Raaponsa to Plaintiffs' Intarrogatoriaa and Raguast for Production to Defendants in Phase I Proceedings. tfESIIWfiHQUSElS. .CEWERAIi OBJECTION Westinghouse is a broadly diversified corporation that currently employs approximately 119,000 people and manufactures in various countries sons 7,500 basic products with approxisately 100,000 variations of those products. Although westinghouse is engaged principally in the manufacture, sale and service of equipment and components for the generation, transmission, utilization and control of electricity, its businesses also include a wide range 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 well as materials, are supplied to Westinghouse by other companies. Hoc applicable. 45. Old your company or ita pradacaaaor(a) avar place any warnings directly on any of its asbestos containing products Itself, as oppo^ ;. - narkagei Answer westinghouse placed a warning on fire retardant micarta. 4S. Did your company ever place in any form of the name of the company, its initials, or any identifying logo on any of its asbestos containing products itself, as opposed to the package? Answer Yes. See response to Interrogatory 17. 47. Did the warning inquired about Interrogatory Nos. 45 and 46, or similar warning, ever appear in any of your sales literature? If so, attach copies of such sales literature, showing the date such literature was printed. iaazaz No. 48. On what date was the sales literature inquired about in Interrogatory No. 47 first provided to distributors or sellers of your company's products, or your predecessor(s)' products? Not applicable. 49. Has your company, or your predecessors(s), ever devised a high temperature heat insulation which does not contain asbestos? If so, state the date that such insulation was first placed on the market. Answer Not applicable. 30. Here any material safety data sheets ever prepared by your company or its predecessor)s)? If so, attach copies. 18 1 1 CERTIFICATE OP SERVICE I, ROY C. WILLIAMS. do hereby certify that I have this day taelled, by United 5tef r.zi.' ooataar prepaid. ,,.,u correct copy of the abova and foregoing document to all counsel of record. THIS the day of February, 1991. ROY'C. WILLIAfls"