Document p2QKQKeNwVvVqD2GXyJbgyGj

CAUSE NO. 4886 * RM9S BONNIE CAMPBELL; THOMAS KARRY HALL; JERRY DEAN HUFFMAN; JOSEPH ARNOLD MULLINS; CHESS WASHINGTON; and ARNOLD WALDREP, VS. OWENS CORNING (a/lc/a OWENS CORNING CORPORATION), ct al., TN THE DISTRICT COURT OF BRAZORIA COUNTY, TEXAS 149TM JUDICIAL DISTRICT DEFENDANT UNION CARBIDE CORPORATION d/b/a UNION CARBIDE CHEMICALS AND PLASTICS, INC, COMPANY'S RESPONSE TO PLAINTIFF. ARNOLD WILEY'S FIRST SET OF INTERROGATORIES. FIRST REQUEST FOR PRODUCTION. AND FIRST REQUEST FOR ADMISSIONS Defendant, Union Carbide Corporation d/b/a Union Carbide Chemicals and Plastics, Inc., files this response to Plaintiffs First Set of Interrogatories, Request for Production, and Request for Admissions. Respectfully submitted, TBN: 07491100 2600 Two Houston Center 909 Fannin Houston, Texas 77010 Telephone: (713)767-1555 Telecopier: (713) 767-1799 ATTORNEYS FOR DEFENDANT, UNION CARBIDE CORPORATION d/b/a UNION CARBIDE CHEMICALS AND PLASTICS, INC. COMPANY DEPENDANT'S RESPONSES TO PLAINTIFF'S FIRST SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION, AND FIRST REQUEST FOR ADMISSIONS- Page I F\F)frndocH\enwcc(M:razonav:amptMi^waiUrap.amold\PlB/iM!f('e i* 5oi o( iriurrogs 4 Rsquesi (or Proflueiion PRINT TIME AUG. 9. CERTIFICATE OF SERVICE 1 certify that a true and correct copy of Defendant Union Carbide Corporation d/b/a Union Carbide Chemicals and Plastics, Inc.'s Responses to Pluintiffs' First Set of Interrogatories, First Request for Production of Documents, and First Request for Admissions was forwarded via facsimile and via certified mail, return receipt requested to Plaintiff's counsel on the ^ *^dav of August, 2000, and that all other counsel of record were forwarded u copy of the cover letter GENERAL OBJECTIONS Union Carbide objects to the entire set of Plaintiffs' Interrogatories, Requests lor Production and Requests for Admissions on the following grounds, which are hereby incorporated by reference in Union Carbide's responses to individual Interrogatories, Requests for Production and Requests for Admissions below: GENERAL OBJECTION NO. 1: Union Carbide slates that trial preparation and factual investigation are ongoing. Union Carbide's answers to these Interrogatories, Request for Production and Request for Admissions are based on information known to Union Carbide at this time. Union Carbide reserves the right, however to make reference at the trial or at any hearing in this action lo facts and documents not identified in these responses, the existence or relevance of which is later discovered by it or its counsel. By this reservation, Union Carbide does not in any way assume a continuing responsibility to update its responses to these Interrogatories, Request for Production and Request for Admissions, and specifically objects to each of these Interrogatories, Request for Production and Request for Admissions to the extent that they seek to impose any such continuing obligation upon Union Carbide. GENERAL OB-TF-CTTON NO. 2: Union Carbide objects to plaintiffs' Interrogatories, Request for Production and Request for Admissions in their entirety on the grounds that they are not reasonably framed in terms of the facts and subject matter of the present action, with the result that Union Curbide is called upon to speculate as to what information relevant to the present case, if any, may be deemed to fall within the scope of the Interrogatories, Request for Production and Request for Admissions as phrased. DEFENDANT'S RESPONSES TO PLAINTIFF'S FIRST SET OF INTERROGATORIES. FIRST REQUEST FOR PRODUCTION, AND FIRST REQUEST FOR ADMISSIONS- Pago 2 F\FlimtiocaV}(wVxW)rflzoi|fl\campMl\wn|clroplamQ!(f\Pla!nilll's 1" Solo! Irfariogs & Requesl lor Producllon PRINT TIMEAUG. 9. 5:05PM GENERAL OBJECTION NO. 3: Union Carbide also objects to all Interrogatories, Request for Production and Request for Admissions insofar as they would require the disclosure of information protected by the auomeyclient privilege or work product doctrines. GENERAL OBJECTION NO. 4: Union Carbide objects to providing information about any asbestos-containing products which it has manufactured, sold or distributed, on the grounds that the asbestos fiber in those products was encapsulated by or embedded in other material and on the grounds that the plaintiff has made no allegation of exposure to those products. According to Union Carbide's best presently available information, these products consist of the following: a tree sprout inhibitor used primarily to inhibit growth on telephone poles; a phenolic molding compound used in electronic parts and products such as switches and radios; a thermoplastic molding material used primarily in camera cases; Preslone radiator products; acetylene cylinder liners; a scarier machine; a heat exchanger; and, possibly, certain polyethylene and polystyrene or other products sold in very limited quantities or on an experimental basis. Union Carbide no longer manufactures any of the above products. Union Carbide acquired its Coalinga mine site in 1958. From 1960-1963, as Union Carbide developed its mining and milling operation, Union Carbide provided fiber samples to potential customers. From 1963 until June 30, 1985, Union Carbide mined and sold short fiber chrysotile asbestos initially as "Union Carbide Asbestos" and then under the trade name Calidria (some distributors marketed Calidria under other trade names). All responses to these Interrogatories, Request for Production und Request for Admissions refer to Calidria asbestos only. GENERAL OBJECTION NO. 5: Union Carbide objects to this entire set of Interrogatories, Request for Production and Request for Admissions to the extent that they call for information about Union Carbide employees or premises, or policies pertuining to Union Carbide employees or premises other than Union Carbide's Texas City, TX location. Inasmuch as the plaintiffs do not allege that they or their decedents were ever employed by Union Carbide or worked at any job site controlled by Union Carbide other than the Texas City, TX location, such information is irrelevant and immaterial to matters at issue in this case. Any pertinent information which the employee or premises information about other locations can be said to reflect can be requested directly without requesting the irrelevant and immaterial information or documentation about employees or premises. DEFENDANT'S RESPONDS TO PLAINTIFF'S FIRST SET OF INTERROGATORIES. FIRST REQUEST FOR PRODUCTION. AND FIRST REQUEST FOR ADMISSIONS- Page 3 FVFIrmdKBtanvteiUrBZOflavevnpbriMdrsp.atnnWPlAIMI's l'1 Sul of mlerroga 1 fleqjssl for Pioaucliun receive: timsavg. . :?5PM PRINT TIMEAUG. PRELIMINARY STATEMENT These responses tire based on facts known to or believed by Union Carbide Corporation d/b/a Union Carbide Chemicals and Plustics, Inc., at the time of answer. Because much of the information is sought from many years ago and is therefore difficult or impossible to reconstruct or retrieve, we reserve the right to amend these responses as, and if, new or better information becomes available or if any error is discovered. These responses are from Union Carbide Corporation d/b/a Union Carbide Chemicals and Plastics, Inc.'s records and knowledge and not those of any former subsidiary or affiliates, predecessors. This statement is incorporated by reference in each of the following responses. DEFENDANT'S RESPONSE TO PLAINTIFF'S INTERROGATORIES, REQUEST FOR PRODUCTION. AND REQUEST FOR ADMISSION INTERROGATORY NO. 1: For each person who has supplied any information used in answering these ^interrogatories, state the name, address, job title, length of time employed by Defendant, and a year-by-year list of all other positions, titles, or jobs held when working for Defendant. RESPONSE: Objection. It is impossible for Union Carbide Corporation d/b/a Union Carbide Chemicals and Plastics, Inc., to answer this interrogatory. Union Carbide Corporation d/b/a Union Carbide Chemicals and Plastics, Inc., has been involved in asbestos litigation for many years. During the course of said litigation, its legal representatives have reviewed voluminous records of itself and olhers, have conferred with many current and former employees and have confcired with legal representatives of others, It has become impossible to distinguish sources of information in an accurate and meaningful way. REQUEST FOR ADMISSION NO. 1: Admit that Defendant ordered, purchased or otherwise acquired asbestos-containing products, asbestos-containing friction products, and/or machinery requiring the use of asbestos or asbestos-containing products, DEFENDANT'S RESPONSES TO PLAINTIFF'S FIRST SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION, AND FIRST REQUEST FOR ADMISSIONS- Page 4 1RFiimcocB'wvwADl6:o(lDtoiinpt)6(l\wn:(iicip,airold'?lairall| : 1" Sal of Imoriojs & Reajosl lor Production RECEIVED TIMEAUG. 9. 4;25PM PRINT TIMEAUG. 9. E J RESPONSE: See Union General Objection #5. Subject to its objections, Union Carbide responds as follows; Admitted. At times during the operation of Union Carbide facilities, Union Carbide acquired products which contained asbestos in accordance with state-of-the-art safety and operation practices for industrial facilities. Union Carbide denies that it necessarily acquired all of the types of products set forth in this Request. REQUEST FOR PRODUCTION NO. 1: If you deny the foregoing request, in whole or in pail, produce a]J documents supporting your denial. RESPONSE: Not applicable. Sec General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) ihc attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement. REQUEST FOR ADMISSION NO. 2: Admit that asbestos-containing products, asbestos-containing friction products, and/or machinery requiring the use of asbestos or asbestos-containing products were utilized on Defendant's Premises during the years at issue. RESPONSE: See Union General Objection #5. Subject to its objections, Union Carbide responds as follows: Admitted. At times during the operation of Union Carbide facilities, UCC acquired products which contained asbestos in accordance with state-of-the-art safety and operation practices for industrial facilities. Union Carbide denies that it necessarily acquired all of the types of products set forth in this Request. DEFENDANT'S RESPONSES TO PLAINTIFF'S FIRST SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION, AND FIRST REQUEST FOR ADMISSIONS- Pnge 5 (I\p|nTUiQwnv\cciMirj^oi|a\can\pti9li\wa!dr6p,8trold'Plalnilll's1 " Sal ol iriionoos & Roquesi lor Pioauciian RECEIVED TIMEAUG. o 4;?5PM PRINT TIMEAUG. 9. 5:05PM INTERROGATORY NO, 2; If you admit the foregoing request, please list all asbestos-containing products used at Defendant's Premises and for each product state the following: a. What these products were used for b. From whom these products were purchased c. Where these products were installed d. Specific persons or contractors who install these products e. The first year each product was no longer purchased and installed on Defendants Premises ANSWER: See General Objections and Preliminary Statement, which are incorporated herein as if fully rewritten. Objection. This interrogatory is overly broad, unduly burdensome, harassing and annoying given the parameters and subject matter of this case. REQUEST FOR PRODUCTION NO. 2: Produce all ordering and sales documents pertaining to the purchase or acquisition of such asbestos-containing products for use at Defendant's Premises, including but not limited to invoices, price quotations, purchase orders, requisitions, bills of lading, and other purchasing and/or shipping documents of the similar nature. RESPONSE: See General Objections and Preliminary Statement, which are incorporated herein as if fully rewritten, Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cuses regarding defense of this case, (cl) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (0 the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or G) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement. DEFENDANT'S RESPONSES TO PLAINTIFF'S FIRST SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION. AND FIRST REQUEST FOR ADMISSIONS- Page 6 I" Em ol Intairoga & Raquasl lor Production RECEIVE:- TiHEAUG. 9. 4:25PM PRINT TIME AUG. 9, REQUEST FOR ADMISSION NO. 3: Admit that during the time Plaintiff was working on Defendant's Premises, it was foreseeable that asbestos-containing products on Defendant's Premises would or could be removed, stripped, replaced or repaired at some time after installation. RESPONSE: See Union General Objection #5, Subject to its objections, Union Carbide responds as follows: Admitted. At times during the operation of Union Carbide facilities, UCC acquired products which contained asbestos in accordance with state-of-the-art safely and operation practices for industrial facilities. Union Carbide denies that it necessarily acquired all of the types of products set forth in this Request. INTERROGATORY NO. 3: Please state whether any asbestos-containing products in place or in use at Defendant's Premises have been abated at any lime. a. ff so, list each person or company that performed .such abatement services (including address and telephone number) b. State the dates and locations of each abatement procedure; c. State which asbestos-containing products were abated. ANSWER: See General Objections and Preliminary Statement, which arc incorporated herein as if fully rewritten. Objection. This interrogatory is overly broad, unduly burdensome, harassing and annoying given the parameters and subject matter of this case. REQUEST FOR PRODUCTION NO. 3: Produce all documents that in any way pertain to abatement of asbestos-containing materials on Defendant's Premises, including but not limited io a removal plan or organized written criteria or schedule for the removal of asbestos at Defendant's Premises, and in operation and maintenance plan. RESPONSE: See General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the requesi seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other coses regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (0 the expert witness DEPENDANTS RESPONSES TO PLAINTIFF'S FIRST SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION, AND FIRST REQUEST FOR ADMISSIONS- Page 7 F\RmiUu\ufivVxiUiioxqiloWampbeliVwnklrep.ornntchPlalnillCn 1" 8nl at Inienogs & Raquosl It* Pradjcllon Li 4:25PM PRINT TIMEAUG. 9. 5:04PM exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same. Defendant will supplement. REQUEST FOR ADMISSION NO. 4: Admit that Plaintiff worked on premises owned by Defendant or by a predecessor-in-imerest of Defendant. RESPONSE: This defendant is unable to either admit or deny this request for admission because the investigation for defendant's responses to discovery is still ongoing. Therefore, denied. REQUEST FOR PRODUCTION NO. 4: If you deny the foregoing request, in whole or in part, produce all documents supporting your denial, RESPONSE: See General Objections, which arc incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for oihcr defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying, Subject to the foregoing objections and without waiving same. Defendant will supplement. REQUEST FOR PRODUCTION NO. 5: If you admit the foregoing request, in whole or in part, produce ail documents supporting your admission that Plaintiff was on Defendant's Premises. RESPONSE: Sec General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client DEFENDANT'S RESPONSES TO PLAINTIFF'S FIRST SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION, AND FIRST REQUEST FOR ADMISSIONS- Page 6 nplfmdocs^rMccAbRzurtukampbolKMaldrQp.amaliM^lainliirs 1" Set of Iniertoga i Rnquosi for Proifucuon Kb1. * 'i 1ifT,.TH7 j<i Ti T: 4:25PM PRINT TIMEAUG. 9. 5:04PM privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expeit witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same. Defendant will supplement. REQUEST FOR PRODUCTION NO. 6: Produce all records identifying contractors and/or the employees of contractors who were on your premises during the years at issue, 'including but not limited to sign-in-logs, gate records, visitor's logs, identification badge logs and procedures, and other documents of a similar nature, RESPONSE: See General Objections, which are incorporated herein as if fully rewritten. Objection to the extent ihe request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence, Objection to the extern the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement. REQUEST FOR PRODUCTION NO. 7: Produce all records pertaining to the methods and manner of identification of individuals entering and/or leaving your facilities, during the years at issue, including but not limited to fingerprinting or other methods of identifying contractor employees at your premises, and specifically including any fingerprinting or other records identifying the Plaintiff DEFENDANT'S RESPONSES TO PLAINTIFFS FIRST SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION, AND FIRST REQUEST FOR ADMISSIONS- Page 9 RRmdacate(TvtorUiraiMlii|fflT'pto(llwiilarflp,oino|[APlBln: 'r 1" Sol of iniorrofis i Boqioai lor Production PRINT TIMEAUG. 9, 5:04PM RESPONSE: See General Objections, which are incorporated herein as if fulJy rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, umbiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same. Defendant will supplement. INTERROGATORY NO. 4: Identify the contractors who worked on your premises during the years at issue, and fore each, state: a. The type of work performed by the contractor b. The dales such work was performed; c. Identify your employee responsible for monitoring, verifying, or instructing concerning these services to be per-formed by such contractors. ANSWER: See General Objections and Preliminary Statement, which are incorporated herein us if fully rewritten. Objection. This interrogatory is overly broad, unduly burdensome, harassing and annoying given the parameters and subject matter of this case. REQUEST FOR PRODUCTION NO. 8: Produce the contract documents pertaining to the contractors who performed services on Defendant's Premises during the years al issue, including but not limited to invitations to bid, requests for proposals, bids, proposals, scope of work, specifications, blueprints, plans, acceptances, contracts, amendments, addenda, change orders, and other contract documents of a similar nature. RESPONSE: See General Objections, which are incorporated herein as if fully rewritten. Objection lo the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this DEFENDANT'S RESPONSES TO PLAINTIFF'S FIRST SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION, AND FIRST REQUEST FOR ADMISSIONS- Page 10 IVlrm(ioo3\flrivV(^iworl8V:amptiul|\(al(irop,amii(<l'Plainii|('B '"Sa o( Morrogi i poquesi tor Production PRINT TIMEAUG. 9. 5:04PM claim or claims of this type, (e) any privilege relating to confidential iradc secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the parly communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence, Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement, INTERROGATORY NO. 5: Identify each employee who was responsible for allowing contractor employees access to Defendant's Premises during the years at issue. ANSWER: See General Objections and Preliminary Statement, which are incorporated herein as if fully rewritten. Objection. This interrogatory is overly broad, unduly burdensome, harassing and annoying given the parameters and subject matter of this case. REQUEST FOR ADMISSION NO. 5: Admit that Plaintiff worked on Defendant's Premises where Defendant used or applied asbestos-containing products. RESPONSE: This defendant is unable to either admit or deny this request for admission because the investigation for defendant's responses to discovery is still ongoing. Therefore, denied, REQUEST FOR PRODUCTION NO. 9: If you deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: See General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attomcy-clieni privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, fi) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks DEPENDANTS RESPONSES TO PLAINTIFF'S FIRST SET OF INTERROGATORIES. FIRST REQUEST FOR PRODUCTION, AND FIRST REQUEST FOR ADMISSIONS- Page 11 (Vlfnxl6\env\cc^^Ql(i\cairipll^3l(K9p,6TioicMJialnlll['s i* Sot ol Inlorraos & Request In Production T y fr i tt * . .ififiAl'U. 9. 4:25PM PRINT TIMEAUG. 9. 5:04PM information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement. INTERROGATORY NO. 6: Do you contend that Plaintiff was not exposed to asbestos while working at the Defendant's Prcmise(s)? If the answer is anything other than "no", identify each and every fact which supports this contention. ANSWER: See General Objections and Preliminary Statement, which arc incojporaled herein as if fully rewritten. Objection. This interrogatory is overly broad, unduly burdensome, harassing and annoying given the parameters and subject matter of this case. Specifically, this Defendant objects to the overly broad and unduly burdensome language, "identify each and every fact which supports this contention." REQUEST FOR ADMISSION NO. 6: Admit that Plaintiff, in the course and scope of his work as an employee of an independent contractor, worked around Defendant's employees who were using and/or applying asbestos-containing products. RESPONSE: This defendant is unable to either admit or deny this request for admission because the investigation for defendant's responses to discovery is still ongoing. Therefore, denied. REQUEST FOR PRODUCTION NO. 10: If you deny the foregoing request, in whole or in part, produce all documents supporting your RESPONSE: See General Objections, which are incorporated herein as if fully rewritten. Objection in the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) DEFENDANT'S RESPONSES TO PI-AINTJFF'S FIRST SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION, AND FIRST REQUEST FOR ADMISSIONS- Page 12 RRmuloM\onvtocAbraJorlo'campCfiltaBlc)t6p,iiriU!(J\Plalnlfl('6 Sul oi Interogs 1 Racussi lor Pradudlon 4:25PM PRINT TIMEAUG. 9, 5:04PM the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broud, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same. Defendant will supplement. REQUEST FOR ADMISSION NO. 7: Admit that Plaintiff worked on and/or around Defendant's Premises in areas where asbestos-containing products were installed, used, prepared for use, replaced or repaired, stored or loaded, unloaded or transported. RESPONSE: This defendant is unable to either admit or deny this request for admission because the investigation for defendant's responses to discovery is still ongoing. Therefore, denied. REQUEST FOR ADMISSION NO. S: Admit that in 1950 Defendant was aware that airborne asbestos dust created a potential health hazard to those who breathed such dust, RESPONSE: Denied. Union Carbide denies that it possessed awareness that dust of any type at sufficiently high levels could cause health hazards. Indeed, Union Carbide employed state-ofthe-art practices and was recognized as an industry leader in efforts, including but limited to, safety practices in efforts to minimize or avoid dust inhalation by its or contract employees, including, but not limited to, safety practices, ventilation measures and information provision. Union Carbide's information about specific asbestos-related hazards, however, developed gradually. Union Curhidc's involvement with asbestos was primarily as that of an industrial consumer. Union Carbide manufactured some products which had an asbestos content, and from 1963-1.985, mined and sold a unique short-fiber chrysotile used for specialized, non-insulation purposes. Union Carbide never manufactured or sold asbestos-containing insulation. Accordingly, Union Carbide lacked any special knowledge or information of the insulation industry. Union Carbide's knowledge concerning potential health hazards possibly associated with excessive asbestos fiber inhalation developed gradually. Sources of information as to possible health concerns of which Union Carbide is presently aware included general and scientific literature on the topic and reports or memoranda by Union Carbide employees. Upon the plaintiffs request, copies of such reports and memoranda, which Union Carbide has located, will be made available at a suitable time and place for review and duplication by the plaintiff. DEFENDANT'S RESPONSES TO Pf.AlNTlFF'S FIRST SET OF INTERROGATORIES. FIRST REQUEST FOR PRODUCTION, AND FIRST REQUEST FOR ADMISSIONS- Page 13 BFlimooc3\6nv'cciM)rMDnaM;smpWihwa!aio[i,amokN1laintifr5I1' Shi u| inmrrofia A Raqoasi lo. Producilun ^ r r n T *' r r\ f \ n A r < r ,i n r r W PRINT TIMEAUG. 9. 5:03PM Union Carbide recognizes lhai ihe excessive inhalation of asbestos fiber may be associated with the development of serious and potentially fatal disease. Union Carbide also understands that the onset and development of such disease in a person may be related to an affected by, umong other factors: the particular type of fiber that is inhaled; cigarette smoking; and environmental conditions, in addition to the person's medical history and condition. REQUEST FOR PRODUCTION NO. 11: Tf you deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: See General Objections, which arc incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) auomey-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement. REQUEST FOR ADMISSION NO. 9: Admit that Defendant was aware of the presence of and/or use of asbestos-containing products on Defendant's Premises during the time period Plaintiff was working on Defendant's Premises. RESPONSE: This defendant is unable to either admit or deny this request for admission because the investigation for defendant's responses to discovery is still ongoing. Therefore, denied. DEFENDANT'S RESPONSES TO PLAINTIFF'S FIRST SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION, AND FIRST REQUEST FOR ADMISSIONS- Page 14 PFIrmaocswnvterUirflfonn'camptwffiwaitfrgpjrnofiW'iSi'rarf/'a i* Sui of fn/aTogs i Requosi lor Praaucitor PRINT TIMEAUG, 9. 5:03PM REQUEST FOR PRODUCTION NO. 12: Produce any and all photographs or videographic depictions or films depicting the use by you or your employees of any safety precautions (such as containment areas, warning signs, etc.) taken to protect bystanders from the hazards of airborne asbestos resulting from the use of asbestos-containing products by your employees at any locations. RESPONSE: See General Objections, which arc incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiffs request. INTERROGATORY NO. 7: Please identify any and all warnings ever given by Defendant, if any, to Plaintiffs regarding the hazards of asbestos and the dangers 'inherent in the inhalation of asbestos fibers. ANSWER: Sec General Objections and Preliminary Statement, which are incorporated herein as if fully rewritten. Objection. This interrogatory is overly broad, unduly burdensome, harassing and annoying given the parameters and subject matter of this case. REQUEST FOR PRODUCTION NO. 13: Produce all such warnings. RESPONSE: See General Objections, which tire incoiporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating lo communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this DEFENDANT'S RESPONSES TO PLAINTIFF'S FIRST SET OF INTERROGATORIES. FIRST REQUEST FOR PRODUCTION. AND FIRST REQUEST FOR ADMISSIONS- Page 15 PFlimdnc6\anv\cciM)(WQrlalKmipm)l|\w!iidrep,BFnoliW5lalriiira i- Sui d Idleness 4 Request for Pinduaion PRINT TIMEAUG. 9. 5 claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness .statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiff's request. REQUEST FOR ADMISSION NO. IQ: Admit that Defendant did not distribute any literature or warnings of any kind to its employees during the period of time Plaintiff worked on Defendant's Premises regarding the potential health hazards to those who breathe airborne asbestos dust. RESPONSE: See General Objection #5. Subject to its objection, Union Carbide Corporation d/b/a Uniun Carbide Chemicals and Plastics, Inc. responds as follows; Denied. See Union Carbide Corporation d/b/a Union Carbide Chemicals and Plastics, Inc. 's response to Request Admissions No. 8. REQUEST FOR PRODUCTION NO. 14: If you deny the foregoing, produce all such warnings. RESPONSE: Sec General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or 0) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiff's request. DEFENDANT'S RESPONSES TO PLAINTIFF'S FIRST SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION, AND FIRST REQUEST FOR ADMISSIONS- Page 16 RFIrm[}ocjj\flnv\ccfVbfBzofiaV:amptiel|\waiareplQrrK),C\Pl3lnUf|,D *** Sol X inlorrofls & RoquDGl lor Production p-5t;v"" T'J/FjH" Q 4:25PM PRINT TIMEAUG. 9. 5:03PM INTERROGATORY NO. S' Describe Defendant's safely policy as ii relates to the use of asbestos-containing materials at jobsites where Defendant's employees were performing services. In your answer, please state: a. when, if ever. Defendant's employees were first warned about the hazards of asbestos exposure; and b. what instructions, if any, were given to Defendant's employees on the identification of materials which might or did contain asbestos. ANSWER: See General Objections and Preliminary Statement, which are incorporated herein as if fully rewritten. Objection. This interrogatory is overly broad, unduly burdensome, harassing and annoying given the parameters and subject matter of this case. REQUEST FOR PRODUCTION NO. 15: Produce all such safety policies. RESPONSE See General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (c) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence, Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiff's request. REQUEST FOR ADMISSION NO. 11: Admit that Defendant consciously decided not to warn its employees of the dangers of asbestos. DEPENDANT'S RESPONSES TO PLAINTIFF'S FIRST SET OP INTERROGATORIES, FIRST REQUEST POR PRODUCTION, AND FTRST REQUEST FOR ADMISSIONS- Page 17 BRrmdoca\n/ci;i^razona\C'J[Tipt>|l\w9lil[ap,arn<)ld\PlaliMI(rs 1" Sul ol Inleirags & Roquosl lor Producltan p?t:yrr ^c 4 /c.PM PRINT TIMEAUG. 9. 5:03PM RESPONSE: See General Objection #5. Subject to its objection. Union Carbide Corporation d/b/a Union Carbide Chemicals and Plastics, Inc. responds as follows: Denied. See Union Carbide Corporation d/b/a Union Carbide Chemicals and Plastics, Inc. 's response to Request Admissions No. 8. INTERROGATORY NO. 9: Do you contend that Defendant specifically warned Plaintiff about the hazards of asbestos and asbestos-containing products? Jf the answer is anything other than "no", identify each and every fact which supports this contention. ANSWER: See Genera) Objections and Preliminary Statement, which are incorporated herein as if fully rewritten. Objection. This interrogatory is overly broad, unduly burdensome, harassing and annoying given the parameters and subject matter of this case, This Defendant specifically objects to the overly broad and unduly burdensome language, "identify each and eveiy fact which supports this contention." INTERROGATORY NO. 10: Describe all safety precautions taken by you or your employees (such as containment areas, warning signs, ventilation systems, evacuating the premises, etc,) for the protection of bystanders (including but noi limited to Plaintiffs) from the hazards resulting from the use of asbestos-containing products by your employees at uny locations, ANSWER: See General Objections and Preliminary Statement, which are incorporated herein as if fully rewritten, Objection. This interrogatory is overly broad, unduly burdensome, harassing and annoying given the parameters and subject matter of this case. INTERROGATORY NO. 11: Have you ever provided safety equipment to persons working on Defendant's Premises? If so, please list the safety equipment provided and indicute: a. when the equipment was first provided b. to whom the equipment was provided c. under what circumstances the equipment was provided d. Further, identify the person with the most knowledge of your "safety equipment" policies. DEPENDANT'S RESPONSES TO PLAINTIFF'S FIRS T SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION, AND FIRST REQUEST FOR ADMISSIONS- Page 18 F\Flrmdoc\enw;ci^iazorla\iuim|]Mwel[lrfip,l)iiia|[|V>la|nlllll 1* Sol of Iniarroga 4 Roquosl lor PiocucDor F.EC"T!!'IEAU3. 3. 4:25PM PRINT TIME AUG. 9. 5:03PM ANSWHR: See General Objections and Preliminary Statement, which are incorporated herein as if fully rewritten. Objection. This interrogatory is overly broad, unduly burdensome, harassing and annoying given the parameters and subject matter of this case. REQUEST FOR ADMISSION NO. 12: Admit that Defendant did not continuously provide face masks to contract employees working with or around asbestos from 1945 to the present for the purpose of protecting these employees from inhaling asbestos. RESPONSE: See General Objection #5, Union Carbide further objects to this Request on the grounds that it is overly broad and not phrased to allow a meaningful admission or denial. Subject to its objections, Union Carbide responds as follows: Union Carbide lacks sufficient information to admit or deny insofar as the request has not defined whether, for instance, "employees working with or around asbestos" include all employees entering premises which contained state-of-the-art asbestos insulution. See Union Carbide's response to Request for Admissions No, 8. INTERROGATORY NO. 12: Slate in detail what tests have been conducted with regard to the quantity, quality, or threshold limit values of asbestos dust or particles to which workers were exposed while using, working with or around, or Installing asbestos-containing products in any of your facilities. Please state where and when these tests were conducted, by whom these tests were conducted, and the results of any such test. ANSWER: Sec General Objections and Preliminary Statement, which are incorporated herein as if fully rewritten. Objection. This interrogatory is overly broad, unduly burdensome, harassing and annoying given the parameters and subject matter of this case. INTERROGATORY NO. 13 Do you contend that Defendant's representatives, insurance earners and/or agents performed any measurements and/or studies prior to 1970 to determine the quantity of asbestos fibers in the air at Defendant's facility? If the answer is anything other than "no'1, identify each and every fact which supports this contention. ANSWHR: See General Objections and Preliminary Statement, which are incorporated herein as if fully rewritten. Objection. This interrogatory is overly broad, unduly burdensome, harassing DEFENDANT'S RESPONSES TO PLAINTIFF'S FIRST SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION, AND FIRST REQUEST FOR ADMISSIONS- Page 19 RPIrmdocsVurwVccrUirBzoflaVrnmpbaHXwalilrBp.smaievPIalnllll's 1*' Sul ol Inlerrogs i Aequosl lor Praducilon TM"A!;r c .: / i PM PRINT TIMEAUG. 9. 5:03PM and annoying given the parameters and subject matter of this case. This Defendant specifically objects to the overly broad and unduly burdensome language, "identify each and every fact which supports this contention." INTERROGATORY NO. 14: Please state each time any regulatory agency or other governing body has inspected the Defendant's premises to determine if health and safely regulations governing exposure to asbestos were being followed. Include in your response the date and results of each inspection, and state whether a written report was generated. ANSWER: See General Objections and Preliminary Statement, which are incorporated herein as if fully rewritten. Objection. This interrogatory is overly broad, unduly burdensome, harassing and annoying given the parameters and subject matter of this case. REQUEST FOR ADMISSION NO. 13: Admit that you did not erect containment barriers to prevent emission of asbestos dust at the worksites where your employees were using asbestos-containing, materials, including the worksites where Plaintiff was present. RESPONSE: See General Objection #5. Union Carbide further objects to this Request on the grounds that it is overly broad and not phrased to allow a meaningful admission or denial. Subject to its objections. Union Carbide responds as follows: Union Carbide lacks sufficient information to admit or deny insofar as the request has not defined whether, for instance, "employees working with or around asbestos" include all employees entering premises which contained state-of-the-art asbestos insulation. See Union Carbide's response to Request for Admissions No. 8. REQUEST FOR PRODUCTION NO. 16: If you deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: See General Objections, which arc incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's DEFENDANT'S RESPONSES TO PLAINTIFF'S FIRST SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION, AND FIRST REQUEST FOR ADMISSIONS- Page 20 RFirmoocstanvte/lbriuiirla'caniptioliiwaid'flp.nrnDitM'iairiiirs1 * Sot ol imerroga & Floquost lor Production 15ECEIVE1' TIMEAUG, 9. 4:25PM PRINT TIMEAUG. 9. 5:03PM between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert wimess exemption, (g) the witness statements exemption, (h) the parly communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the cxLent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiffs request. REQUEST FOR ADMISSION NO. 14: Admit that you did not utilize engineering controls such as isolation or enclosure at the worksites where your employees were using asbestos-containing materials, including the worksites where Plaintiff was present. RESPONSE: See General Objection #5. Union Carbide further objects to this Request on the grounds that it is overly broad and not phrased to allow a meaningful admission or denial. Subject to its objections, Union Carbide responds as follows: Union Carbide lacks sufficient information to admit or deny insofar as the request has not defined whether, for instance, "employees working with or around asbestos" include all employees entering premises which contained state-of-the-art asbestos insulation. See Union Carbide's response to Request for Admissions No. 8. REQUEST FOR PRODUCTION NO. 17: If you deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE Sec General Objections, which arc incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks DEFENDANT'S RESPONSES TO PLAINTtFF'S FIRST SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION, AND FIRST REQUEST FOR ADMISSIONS- Page 21 F\f!nTKioca\iinirtci;ft|]iBzoniacaniptxi||\wal0r6p,amold\P|alniill's I11 Sol o' fnlo'iosa t flaqueai lor Produdion FEINT TIMEAUG. 9. information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiff's request. REQUEST FOR ADMISSION NO, 15: Admit that you did not utilize ventilation or exhaust systems to divert dust at the worksites where your employees were using asbestos-containing materials, including the worksites where Plaintiff was present. RESPONSE: See General Objection #5. Union Carbide further objects to this Request on the grounds that it is overly broad and not phrased to allow a meaningful admission or denial. Subject to its objections, Union Carbide responds as follows: Union Carbide lacks sufficient information to admit or deny insofar as the request has not defined whether, for instance, "employees working wjth or around asbestos" include all employees entering premises which contained state-of-the-art asbestos insulation. See Union Carbide's response to Request for Admissions No. S REQUEST FOR PRODUCTION NO. 18: Tf you deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: See General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same. Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiff's request. DEFENDANT'S RESPONSES TO PLAINTIFF'S FIRST SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION, AND FIRST REQUEST FOR ADMISSIONS- Page 22 PinnTiilDCB\env\ccntora20flPteampDeJAwAidra(i,afnDicM>iiiinliirB i" Sal ol Imorroga t, Raqueal lor Production FECEiVED TIMEA'Jj. 9 4'25PM PRINT TIMEAUG. 9. 5:03PM REQUEST FOR ADMISSION NO. 16: Admit that you did not utilize dust collection engineering controls to trap airborne asbestos dust at the worksites where your employees were using ashestos-containing materials, including the worksites where Plaintiff was present. RESPONSE: See General Objection #5. Union Carbide further objects to this Request on the grounds that it is overly broad and not phrased to allow a meaningful admission or denial. Subject to its objections, Union Carbide responds as follows: Union Carbide lacks sufficient information to admit or deny insofar as the request has not defined whether, for instance, "employees working with or around asbestos" include all employees entering premises which contained siale-of-thc-arl asbestos insulation. See Union Carbide's response to Request for Admissions No. 8. REQUEST FOR PRODUCTION NO. 19: If you deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: See General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or G) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiff's request. REQUEST FOR ADMISSION NO. 17: Admit that you did not require your employees to handle, mix, apply, remove, cut or score asbestos-containing products in a wet state to prevent emission of airborne asbestos fibers at the worksites where your employees were using asbestos-containing materials, including the worksites where Plaintiff was present. DEFENDANT'S RESPONSES TO PLAINTIFF'S FIRST SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION. AND FIRST REQUEST FOR ADMISSIONS- Page 23 pRimaatomtoAbfazar).tempbeiA^(ffe|)li!rni)(iWtolnill!'s i S ol intoropa & Rbcussi to PrtuXcilon 4:25PM PRINT TIMEAUG, 9. 5:02FM RESPONSE: See General Objection #5. Union Carbide further objects to this Request on the grounds that it is overly broad and not phrased to allow a meaningful admission or denial. Subject to its objections, Union Carbide responds as follows: Union Carbide lucks sufficient information to admit or deny insofar as the request has not defined whether, for instance, "employees working with or around asbestos" include all employees entering premises which contained state-of-the-art asbestos insulation. Sec Union Carbide's response to Request for Admissions No. 8. REQUEST FOR PRODUCTION NO. 20: If you deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: Sec General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiff's request. REQUEST FOR ADMISSION NO. 18: Admit that you did not evacuate the premises prior to the utilization of asbestoscontaining materials at the worksites where your employees were using asbestos-containing materials, including the worksites where Plaintiff was present. RESPONSE: See General Objection #5, Union Carbide further objects to this Request on the grounds that it is overly broad and not phrased to allow a meaningful admission or denial. Subject to its objections, Union Carbide responds as follows: Union Carbide lacks sufficient information to admit or deny insofar as the request has not defined whether, for instance, "employees working with or around asbestos" include all employees entering premises which contained state-of-the-art asbestos insulation. See Union Carbide's response to Request for Admissions No. 8. DEFENDANT'S RESPONSES TO PLAINTIFFS FIRST SE T OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION, AND FIRST REQUEST FOR ADMISSIONS- Page 24 F\Timi<lur-ii\nrtccrHifiuo(iB\ca(!ipDii|i\>*a|(lrop1amo[itP[sinP!(,s n Sut ol Imorrout & Request for Prattuciion FEINT TIMEAUG, 9. 5:02PM REQUEST FOR PRODUCTION NO. 21: If you deny the foregoing request, in whole or In part, produce all documents supporting your denial. RESPONSE: See General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the parly communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiffs request. INTERROGATORY NO. 15: Have you ever warned workers on Defendant's Premises of the hazards of asbestos and asbestos-containing products? Tf so, describe in detail the methods of such warnings, who you warned and when. Please include in your response a description of any written warnings relating to the hazards of asbestos in place at Defendant's Premises and state when the written warnings were installed, how many were installed, and whether they have been removed. ANSWER. See General Objections and Preliminary Statement, which are incorporated herein as if fully rewritten. Objection. This interrogatory is overly broad, unduly burdensome, duplicative, harassing and annoying given the parameters and subject matter of this case. INTERROGATORY NO 16: Have you ever had a policy requiring workers on Defendant's premises to use respirators? If so, please: a. state when this policy was implemented, b. describe this policy in detail; c. state to whom it applied (i,e. Defendant employees and contractor employees); d. and describe what types and brand names of respirators were required by you. DEFENDANT'S RESPONSES TO PLAINTIFF'S FIRST SET OF INTERROGATORIES. FIRST REQUEST FOR PRODUCTION. AND FIRST REQUEST FOR ADMISSIONS- Page 25 p\FlrmUucstonv\afil5r(Uoila\umptiell\wfil()f6[)irimiiltM1le|nl!ir31" So: ol Inionoga & Rsquetl lor Produdion FEINT TIMEAUG. 9. 5:02PM ANSWER: See General Objections and Preliminary Statement, which are incorporated herein as if fully rewritten. Objection. This interrogatory is overly broad, unduly burdensome, harassing and annoying given the parameters and subject matter of this case. REQUEST FOR ADMISSION NO. 19: Admit that you did not post wanting, caution or hazard signs prior to the utilization of asbestos-containing materials by your employees at the worksites where your employees were using asbestos-containing materials, including the worksites where Plaintiff wus present. RESPONSE: See General Objection #5. Subject to ils objections, Union Carbide responds us follows: Denied. See Union Carbide's response to Requests for Admissions Nos. 8 and 13. REQUEST FOR PRODUCTION NO. 22: If you deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: See Genera) Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel und defendant's insurer's regarding the defense of this claim or claims of this type, (c) any privilege relating to confidential trade secrets, proprietary information or confidential communications with uny government agency, (f) the expert witness exemption, (g) the witness statements exemption, (b) the party communications exemption, (i) the right of privacy, or 0) any other privilege, Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence, Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiff's request. DEFENDANT'S RESPONSES TO PLAINTIFF'S FIRST SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION, AND FIRST REQUEST FOR ADMISSIONS- Pafie 26 F\RrmdM8\pnv\rcrtliiiiuflu'cii!7!ptei|\niaiup^fnolC\Plfllnllir I" Sel til InlorrogB & Requesl lor ProCucllcn FEINT TIMEAUG. 9. 5 REQUEST FOR ADMISSION NO. 2Q: Admit Unit you did not issue any warnings to others at the worksites where your employees were using asbestos-containing materials, 'including the worksites where Plaintiff was present. RESPONSE: See General Objection #5, Subject to its objections, Union Carbide responds as follows: Denied. Sec Union Carbide's response to Requests for Admissions Nos. 8 and 13. REQUEST FOR PRODUCTION NO. 33: If you deny the foregoing request, in whole or in part, produce all documents supporting your denial, RESPONSE: See General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (c) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence, Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiff's request. REQUEST FOR PRODUCTION NO. 24: Produce all documents reflecting payments made to contractors during the years at issue, including Plaintiffs employer, including but not limited to invoices, bills, check requests, requisitions, canceled checks, or other documents of a similar nature reflecting payment for services rendered by Plaintiffs employer. RESPONSE: See General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other DEFENDANT'S RESPONSES TO PLAINTIFF'S FIRST SET OF INTERROGATORIES. FIRST REQUEST FOR PRODUCTION, AND FIRST REQUEST FOR ADMISSIONS- Page 27 r\FliTncm\enu^c[^o2oibV:ampt>ef|\waldrap.crnold\p|3inilll'ii t" Set oi inlurrogt & Raauosi mi Prsduciinn PRINT 11 MEAUG, 9. 5 cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege, Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiff's request. REQUEST FOR ADMISSION NO. 2 1: Admit that the use of asbestos-containing materials on Defendant's Premises created a substantial risk of Injury. RESPONSE: See General Objection #5. Union Carbide further objects to this Request on the grounds that it is overly broad and not phrased to allow a meaningful admission or denial. Subject to its objections, Union Carbide responds as follows: Union Carbide lacks sufficient information to admit or deny insofar as the request has not defined whether, for instance, "employees working with or around usbestos1' include all employees entering premises which contained staic-of-rhe-url asbestos insulation, See Union Carbide's response to Request for Admissions No. 8. REQUEST FOR ADMISSION NO. 22: Admit that during the years at issue, Defendant had to power to control Defendant's Premises. RESPONSE: See General Objection #5. Subject to its objections, Union Carbide responds as follows: Admitted. REQUEST FOR PRODUCTION NO. 25: If you deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: See General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to DEPENDANTS RESPONSES TO PLAINTIFF'S FIRST SET OF INTERROGATORIES. FIRST REQUEST FOR PRODUCTION. AND FIRST REQUEST FOR ADMISSIONS- Page 28 F^imidoc\flnvte|\brH0rta\6ampiKillviral(jnip,arnii((N1laini!(ra1,1 Sei of inlwiOQO & Ropuusi l piopocilon 4; 25 PM FEINT TIMEAUG. 9. 5:02PM communications between counsel Tot defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (c) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or Q) any other privilege. Objection to the extent the request seeks information not feasibly calculated to Jead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiff's request. REQUEST FOR ADMISSION NO. 23: Admit that, during the years at issue, Defendant had the power to manage the use or condition ofDefendant's Premises. RESPONSE: This defendant is unable to cither admit or deny this request for admission because the investigation for defendant's responses to discovery is still ongoing. Therefore, denied. REQUEST FOR PRODUCTION NO. 26: Tf you deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: See General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant und counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving DEFENDANT'S RESPONSES TO PLAINTIFF'S FIRST SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION, AND FIRST REQUEST FOR ADMISSIONS- Page 29 WmKfccsVin/tortbrwwiBViiifnpliojawaWrup.aiTioliJPtainllll's t" Sal ol In'iirroos i Rajiesl for Produclion PRINT TIMEAUG. 9, 5:02PM same. Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiff's request. REQUEST FOR ADMISSION NO. 24: Admit that, during the years at issue, Defendant had the power to direct the use or condition of Defendant's Premises. RESPONSE: This defendant is unable to either admit or deny this request for admission because the investigation for defendant's responses to discovery is still ongoing. Therefore, denied. REQUEST FOR PRODUCTION NO. 27: If you deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: See General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without wuiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiffs request. REQUEST FOR ADMISSION NO. 25: Admit that, during the years at issue, Defendant had the power to superintend the use or conditions of Defendant's Premises. DEFENDANT'S RESPONSES TO PLAINTIFF'S FIRST SET OF INTERROGATORIES. FIRST REQUEST FOR PRODUCTION. AND FIRST REQUEST FOR ADMISSIONS- Page 30 RRrm^^^rtDra^iatempMNiiiOTMmo!a\P!a!Mlirs 1' Sal o( Intsrrags & Requeai (or Pradxlion FEINT TIMEAUG. 9, 5:02PM RESPONSE; See General Objection #5. Subject to its objections. Union Carbide responds as follows; Admitted, REQUEST FOR PRODUCTION NO. 28: If you deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE; Sec General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by Che (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel und defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege, Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence, Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same. Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiff's request. REQUEST FOR ADMISSION NO. 36: Admit that, during the years at issue, Defendant had the power to restrict the use or condition of Defendant's Premises. RESPONSE: See General Objection #5. Subject to its objections, Union Carbide responds as follows: Admitted. REQUEST FOR PRODUCTION NO, 29; Tf you deny the foregoing request, in whole or in part, produce all documents supporting your denial. PEFF.NPANT'S RESPOND TO PLAINTIFF'S FIRST SET OF INTERROGATORIES. FIRST REQUEST FOR PRODUCTION. AND FIRST REQUEST FOR ADMISSIONS- Page 31 F^FIfTndoonNanvVcotNix^ariaVcamptiulKwalQtup.iirncHdXPIainlUCii V1 Sei ol Imaifoga 4 PbqhmI Id? Proouclion PRINT TIMEAUG, 9, 5:02PM RESPONSE: Sec General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or 0) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiff's request. REQUEST FOR ADMISSION NO. 27: Admit that, during the years at issue. Defendant had the power to regulate the use or condition of Defendant's Premises. RESPONSE: Sec General Objection #5. Subject to its objections, Union Carbide responds as follows: Admitted. REQUEST FOR PRODUCTION NO. 30: If you deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: See General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the parly communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily DEFENDANT'S RESPONSES TO PLAINTIFF'S FIRST SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION, AND FIRST REQUEST FOR ADMISSIONS- Page 32 F\Firmrtoca\anvVcciMjra2ona\ctmpbuiivfa)arap,ernine\piainiiff c Sol cl iniorrop & Roquosi lor Pradjciion RECEIVED TIMEAUG. 3. 4:25PM PRINT TIMEAUG, 9. 5:02PM expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiff's request. REQUEST FOR ADMISSION NO. 28; Admit that, during the years at issue, Defendant had the power to govern the use or condition of Defendant's Premises. RESPONSE: See General Objection #5. Subject to its objections, Union Carbide responds as follows: Admitted. REQUEST FOR PRODUCTION NO. 31: If you deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: See General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (c) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expen witness exemption, (g) the witness statements exemption, (b) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendunt will supplement if Defendant has any documents in its possession pertaining to plaintiff's request. REQUEST FOR ADMISSION NO. 29 Admit that, during the years at issue, Defendant had the power to oversee the use or condition of Defendant's Premises. RESPONSE: See General Objection #5 Subject to its objections. Union Carbide responds us follows: Admitted. DEFENDANT'S RESPONSES TO PLAINTIFF'S FIRST SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION, AND FIRST REQUEST FOR ADMISSIONS- Page 33 FWffltfKstomter^fKoriaiiamplialKwidmp.smcWsInilirs i" Seiol Wertop & Rbi^csi lor PraMon PRINT TIMEAUG. 9. 5:01PM REQUEST FOR PRODUCTION NO. 32: If you deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: See General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying, Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has uny documents in its possession pertaining to plaintiff's request. REQUEST FOR ADMISSION NO. 30: Admit that, during the years at issue, Defendant had the power to administer the use or condition of Defendant's Premises. RESPONSE: See General Objection #5. Subject to its objections. Union Carbide responds as follows; Admitted. REQUEST FOR PRODUCTION NO. 33; If you deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE; See General Objections, which are incorporated herein as if Tully rewritten, Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) uny applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness DEFENDANT'S RESPONSES TO PLAINTIFF'S FIRST SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION, AND FJRST REQUEST FOR ADMISSIONS- Page 34 RRnndocfiNonv>ccrUirazaria\canipt>e(t\wB<drep,9rno)(AP!aint(trB 1" Set ol Inlerrofie 4 Request lot Prouucllan RECEIVED TIMEAUG. 5. 4:25PM PRINT TIMEAUG. 9. 5: exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request, seeks information not feasibly calculated to lead to the discovery of admissible evidence, Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiffs request. REQUEST FOR ADMISSION NO. 31: Admit that during the years at issue, Defendant controlled Defendant's Premises. RESPONSE: See General Objection #5. Subject to its objections. Union Carbide responds as follows: Admitted. REQUEST FOR PRODUCTION NO. 34: Tf you deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: See General Objections, which ure incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (0 the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiff's request, REQUEST FOR ADMISSION NO. 32: Admit that, during the years at issue, Defendant managed the use or condition of Defendant's Premises. DEFENDANT'S RESPONSES TO PI-AINTIFF'S FIRST SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION, AND FIRST REQUEST FOR ADMISSIONS- Page 35 pNRrmdociiVirvto^rViiriuartaWampbuiTkwifldruQ.amohAPlalniifr's I" 6ol al Inwogs & Roquoct lor Proflucilon PRINT T1MEAUG, 9. 5:01PM RESPONSE: See General Objection #5. Subject to its objections, Union Carbide responds as follows: Admitted. REQUEST FOR PRODUCTION NO. 35: If you deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: See General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this cluim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (0 the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not. feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiff's request. REQUEST FOR ADMISSION NO. 33: Admit that, during the years at issue, Defendant directed the use or condition of Defendant's Premises. RESPONSE: See General Objection #5. Subject to its objections, Union Carbide responds as follows: Admitted. REQUEST FOR PRODUCTION NO. 36: If you deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: See General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other DEFENDANT'S RESPONSES TO PLAINTIFF'S FIRST SET OF INTERROGATORIES. FTRST REQUEST FOR PRODUCTION, AND FIRST REQUEST FOR ADMISSIONS- Page 36 F\ftrmiloca\fin\cc|MirBzoilBV:ampb8lftwa|ilrBp,armii((\Plalnli|!'B l" Sat o( hierugs l Raquael lai Producllan PRINT TIMEAUG. 9. 5:01PM cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (0 the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiff's request. REQUEST FOR ADMISSION NO. 34: Admit that, during the years at issue, Defendant superintended the use or conditions of Defendant's Premises. RESPONSE: See General Objection #5. Subject to its objections, Union Carbide responds as follows: Admitted. REQUEST FOR PRODUCTION NO. 37: if you deny the foregoing request, in whole or in part, produce all documents supporting your denial, RESPONSE: Sec General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (0 the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privucy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertuining to plaintiff s request. DEFENDANT'S RESPONSES TO PLAINTIFF'S FIRST SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCT ION, AND FIRST REQUEST FOR ADMISSIONS- Page 37 (I\Flniwocstaiv\ccr\tirazufla\caniptill\woitlfip,ainoicM1iSin[|(l'61" Sei at Iniecrogs & Requusi for Praductiofi 4:25PM PRINT TIMEAUG. 9. 5:01 PM REQUEST FOR ADMISSION NO. 35: Admit that, during the years at issue. Defendant restricted the use or condition of Defendant's Premises. RESPONSE1 See General Objection #5. Subject to its objections, Union Carbide responds as follows: Admitted. REQUEST FOR PRODUCTION NO. 38: If you deny the foregoing request, in whole or in pan, produce all documents supporting your denial, RESPONSE: See General Objections, which are incorporated herein as if fully rewritten, Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections und without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiff's request. REQUEST FOR ADMTSSTON NO. 36: Admit that, during the years at issue, Defendant regulated the use or condition of Defendant's Premises. RESPONSE: See General Objection #5. Subject to its objections, Union Carbide responds as follows: Admitted. DEFENDANT'S RESPONSES TO PLAINTIFF'S FIRST' SET OF INTERROGATORIES. FIRST REQUEST FOR PRODUCTION. AND FIRST REQUEST FOR ADMISSIONS- Page 38 F\Flrmiloc<>\Bnvta:r\bfiaQrialcomplidHwal(Jrop,atno(tfPlalnlWh- r Sri 0/ inlumgE 1 RocumI larPraducllon PRINT TIMEAUG. 9. CJ REQUEST FOR PRODUCTION NO. 39: If you deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: See General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same. Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiff's request. REQUEST FOR ADMISSION NO. 37 Admit that, during the years at issue. Defendant governed the use or condition of Defendant's Premises. RESPONSE: See General Objection #5. Subject to its objections, Union Carbide responds as follows: Admitted. REQUEST FOR PRODUCTION NO. 40: Tf you deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: Sec General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary defendants responses TO PLAINTIFFS FIRST SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION, AND FIRST REQUEST FOR ADMISSIONS- Page 39 F\HriTidn(;9WTv\ccr^ta2oriiteaniphu(l(wa[dr(in,riinQ:(l\PiainWr5 Sa; of ln/srrags & RWfooal loi PrMellon :CPM FEINT TIMEAUG, 9. 5:01PM information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying, Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiff's request. REQUEST FOR ADMISSION NO. 38: Admit that, during the years at issue, Defendant oversaw the use or condition of Defendant's Premises. RESPONSE: See General Objection #5. Subject to its objections, Union Carbide responds as follows: Admitted. REQUEST FOR PRODUCTION NO. 41: Tf you deny the foregoing request, in whole or in part, produce all documents supporting your denial. RF.SPQNSE: See General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (cl) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) uny privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (0 the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiff's request. DEPENDANT'S RESPONSES TO PLAINTIFF'S FIRST SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION. AND FIRST REQUEST FOR ADMISSIONS- Page 40 WtmUocoiorMcertOra/orlattampboMwHidrop.amoidip.'ainllll's 1" So. a| Inlufiags 4 Raqouul lor Production S. 4:25 PM FEINT TIMEAUG. 9. 5:00PM REQUEST FOR ADMISSION NO. 39: Admit that, during the years at issue, Defendant administered the use or condition of Defendant's Premises, RESPONSE: Sec General Objection #5. Subject to its objections, Union Carbide responds as follows: Admitted. REQUEST FOR PRODUCTION NO. 42: If you deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: Sec General Objections, which arc incojporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) ihe attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying, Subject to the foregoing objections und without waiving same. Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiff's request. REQUEST FOR ADMISSION NO. 40: Admit that Defendant retained some control over the manner in which Plaintiffs work was performed. RESPONSE: Union Curbide lacks direct information as to whether the Plaintiff worked on its premises and thus lacks sufficient information to admit or deny. Union Carbide's investigation remain on-going, however, and Union Carbide reserves its right to supplement its response as information becomes available. DEPENDANT'S RESPONSES TO PLAINTIFF'S FIRST SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION, AND FIRST REQUEST FOR ADMISSIONS- Page 41 F\Rrtniioc3\o(w\cciM)iiuori8\!:ampliell\wa,arep,Bincicl\Piaii'i'Ts i" So, ol Iniorrogs & floqoasi lor Production PRINT TIMEAUG. 9. 5:00PM REQUEST FOR PRODUCTION NO. 43: Tf you deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE. See General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any upplicuble privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiff's request. INTERROGATORY NO. 17: Do you contend that at no time during the years at issue, Defendant did not have the righi to advise or, if necessary, control the activities of employees of contractors, working on Defendant's Premises, who were engaged in activities which could he potentially hazardous to either themselves or to the employees of Defendant? If the answer is anything other than "no", identify each and every fact which supports this contention. ANSWER: See General Objections and Preliminary Statement, which arc incorporated herein as if fully rewritten. Objection. This interrogatory is overly broad, unduly burdensome, harassing and annoying given the parameters and subject matter of this case. REQUEST FOR ADMISSION NO. 41: Admit that Defendant retained some control over the manner in which Plaintiffs employer performed the work requested by the Defendant. RESPONSE: Union Carbide lacks direct information as to whether the Plaintiff worked on its premises and thus lacks sufficient information to admit or deny, Union Carbide's investigation DEFENDANT'S RESPONSES TO PLAINTIFF'S FIRST SET OF INTERROGATORIES. FIRST REQUEST FOR PRODUCTION, AND FIRST REQUEST FOR ADMISSIONS- Page 42 F\Brm<toM\Bnv\K:i\tirBinf(a\ciniptif'ilwairre(>1afmid\Plaiiil!il's I"' sol ol intorrofis a Roqiwsi lor Prooucilon ?.EGE;''EE OEaUG, 5. 4: /5FM FEINT TIMEAUG. 9. 5:00PM remain on-going, however, and Union Carbide reserves its right to supplement its response as information becomes available. REQUEST FOR PRODUCTION NO. 44: If you deny the foregoing request, in whole or in part, produce all documents supporting your denial, RESPONSE: See General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiff's request. REQUEST FOR ADMISSION NO. 42: Admit that Plaintiff was not entirely free to do the work on Defendant's Premises in bis own way. RESPONSE: Union Carbide lacks direct information as to whether the Plaintiff worked on its premises and thus lacks sufficient information to admit or deny. Union Carbide's investigation remain on-going, however, and Union Carbide reserves its right to supplement its response as information becomes available. EOUEST FOR PRODUCTION NO. 45: if you deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: See General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other DEFENDANT'S RESPONSES TO PLAINTIFF'S FIRST SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION, AND FIRST REQUEST FOR ADMISSIONS- Page 43 RPnniiucsM!nv\iVjraj(irl0ta(nBiiell\waltlfflp;arnfl:APloinil|i's "* So) o| inlorroof, & Roqucai lor produciion ?;ECH:"E: ?:MEAUG. 9. 4:25PM PRINT TIMEAUG. 9. 5:00PM cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary `information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege, Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence, Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining Co plaintiff's request, REQUEST FOR ADMISSION NO. 43: Admit that Plaintiffs employer was not entirely free to do the work requested by Defendant on Defendant's Premises in its own way, RESPONSE: See General Objection #5. Subject to its objections, Union Carbide responds as follows: Admitted. See Union Carbide's response to Request No. 1. REQUEST FOR PRODUCTION NO. 46: If you deny the foregoing request, in whole or in pari, produce all documents supporting your denial. RESPONSE: See General Objections, which are incorporated herein as if fully rewritten, Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, ft) the expert witness exemption, (g) Che witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, und annoying. Subject to the foregoing objections and without waiving same, Defendum will supplement if Defendant lias any documents in its possession pertaining to plaintiff's request. DEFENDANT'S RESPONSES TO PLAINTIFF'S FIRST SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION. AND FIRST REQUEST FOR ADMISSIONS- Page 44 F\prmdoca\flr)v\cci^razorla\cDirio()!iWdfep,amo((APIO(nii[ra wSd ul Inwraac & fioquasi lor Produeiion FEINT TIMEAUG, 9. 5:00PM REQUEST FOR ADMISSION NO, 44: Admit that asbestos-containing gaskets were installed at Defendant's Premises. RESPONSE: See General Objection #5. Subject to its objections, Union Carbide responds as follows: Admitted. See Union Carbide's response to Request No. 1. REQUEST FOR PRODUCTION NO, 47: It'you deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: See Genera) Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiffs request. REQUEST FOR ADMISSION NO. 45: Admit that asbestos-containing pipe covering was installed at Defendant's Premises. RESPONSE: See General Objection #5. Subject to its objections, Union Carbide responds as follows: Admitted. See Union Carbide's response to Request No. 1. REQUEST FOR PRODUCTION NO. 48: If you deny the foregoing request, in whole or in part, produce all documents supporting your denial. DEFENDANT'S RESPONSES TO PLAINTIFF'S FIRST SET OF INTERROGATORIES, FIRST REQUEST I OR PRODUCTION, AND FIRST REQUEST FOR ADMISSIONS- Page 4S F\Flidli)a:9\env\(!nrMilKiiFlo\cnmnbe(l\ya!arDp,a!nil!iW,i3irl|ll's Sot d! InlurrajB 1 Roquesl In Producllon FEINT TIMEAUG. 9. 5 RESPONSE: See General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiff's request. REQUEST FOR ADMISSION NO. 46: Admit that asbestos-containing boilers were installed at Defendant's Premises.. RESPONSE: See General Objection #5. Subject to its objections, Union Carbide responds as follows: Union Carbide lacks sufficient information to admit or deny this Request, Union Carbide's investigation remain on-going and Union Carbide reserves its right to supplement this response as information becomes available. REQUEST FOR PRODUCTION NO. 49: If you deny the foregoing request, m whole or in part, produce all documents supporting your denial. RESPONSE: Sec General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily DEFENDANT'S RESPONSES TO PLAINTIFF'S FIRST SET OF INTERROGATORIES. FIRST REQUEST FOR PRODUCTION. .AND FIRST REQUEST FOR ADMISSIONS- Page 46 p\F|r(nclactj\anv\ocr\t]iazorl^>campt>e l\WBiarBp,3inuiavPlDtn,;irti 1' Sal al mleirafls & Bsquaal lor Producllon RECEIVED T1MEAUS. 9. 4:25PM PRINT TIMEAUG. 9. 5:00PM expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiff's request. REQUEST FOR ADMISSION NO. 47 Admit that asbestos-containing fireproofing was installed at Defendant's Premises. RESPONSE: See General Objection #5. Subject to its objections, Union Carbide responds as follows: Union Carbide lacks sufficient information to admit or deny this Request. Union Carbide's investigation remain on-going and Union Carbide reserves its right to supplement this response as information becomes available. Union Carbide admits that pipe covering containing asbestos may have performed a fire proofing role. REQUEST FOR PRODUCTION NO. 50: If you deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: Sec General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying- Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiff's request. REQUEST FOR ADMISSION NO. 48: Admit that asbestos-containing joint compound was installed ut Defendant's Premises. RESPONSE: See Genera] Objection #5. Subject to its objections, Union Carbide responds as follows: Union Carbide lacks sufficient information to admit or deny this Request. Union DEFENDANT'S RESPONSES TO PLAINTIFF'S FIRST SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION, AND FIRST REQUEST FOR ADMISSIONS- Page 47 RHmiaQcaiervtocrtuia/wlflfeampBail'wsWrflP.sfnDliUPtoi'Cirs I" Sui oi inuifrogs 4 Roque (or pioducuon FEINT TIMEAUG. 9. 5:00PM Carbide's investigation remain on-going and Union Carbide reserves its right to supplement this response as information becomes available. REQUEST FOR PRODUCTION NO. 51: If you deny the foregoing request, in whole or in pan, produce all documents supporting your denial. RESPONSE: See Genera] Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiffs request. REQUEST FOR ADMISSION NO. 49: Admit that asbestos-containing insulation was installed at Defendant's Premises. RESPONSE: Sec General Objection #5. Subject to its objections, Union Carbide responds as follows: Admitted. Pipe covering constitutes thermal insulation. See Union Carbide's response to Request No. 40. REQUEST FOR PRODUCTION NO. 52: If you deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: See General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other DEFENDANT'S RESPONSES TO PLAINTIFF'S FIRST SET OF INTERROGATORIES. FIRST REQUEST FOR PRODUCTION. AND FIRST REQUEST FOR ADMISSIONS- Poge 46 F\Rrm4acB\anvVr\bmmiaVrT>ptieli\wBlcfr6|),arr,oia\Platri:`ira 1" Gal al tmorraos & Roquet lor Production PRINT TIMEAUG, 9. 5:00PM cases regarding defense nf this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiff's request. REQUEST FOR ADMISSION NO. 50: Admit that such installation was done under your direction, supervision, and/or control. RESPONSE: See General Objection #5, Subject to its objections. Union Carbide responds as follows: Admitted. REQUEST FOR PRODUCTION NO. 53: Tf you deny the foregoing request, in whole or in part, produce all documents supporting your denial, including but not limited to all documents identifying the entities or individuals who directed, supervised, and/or controlled such *instal)ation activities. RESPONSE1 See General Objections, which are incorporated herein us if Tully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (0 the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiff's request. DEPENDANT'S RESPONSES TO PLAINTIFF'S FIRST SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION, AND FIRST REQUEST FOR ADMISSIONS- Page 49 fVlrirKtoc9Wita:iy)zo(iata(Tipi)flWwiai'op,urrioia>Pi.iin)llis t>'Sdi of inwroos 4 Rooumi lot Produciion 4:25PM FEINT TIMEAUG, 9. 5:00PM INTERROGATORY NO. 18: Please state the first year yon learned that persons could suffer physical injury through the inhalation of asbestos fibers and how Defendant became aware of the existence of asbestos hazards. ANSWER: See General Objections and Preliminary Statement, which are incorporated herein us if fully rewritten, Objection. This interrogatory is overly broad, unduly burdensome, harassing and annoying given the parameters and subject matter of this case. REQUEST FOR PRODUCTION NO. 54: Produce all documents that indicate that asbestos fibers, when inhaled, can be hazardous to the health of human beings. RESPONSE: See General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other eases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this cluim or claims of this type, (c) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiff's request. REQUEST FOR ADMTSSTON NO. S 1: Admit that you supervised the health and safety procedures implemented by contractors working on Defendant's Premises. RESPONSE: See General Objection #5. Subject to its objections, Union Carbide responds as follows: Union Carbide lacks information as to whether or to what extent it directly supervised the health and safety procedures implemented by contractors working on Defendant's Premises. Union Carbide's investigation remain on-going. Union Carbide did, however, inform and require contractors to implement health and safety practices required by all employees on its facilities. DEFENDANT'S RESPONSES TO PLAINTIFF'S FIRST SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION, AND FIRST REQUEST FOR ADMISSIONS- Page 50 FVF<rmdac9\on<AcciMxazonaV:BmpbofiVwalai6p,amoia\Pta!n,`j< & t` S<?t ol inlatrogs i Bequest far Production 4:25PM PRINT TIMEAUG. 9. 5:00PM REQUEST FOR ADMISSION NO. 52: Admit that you supervised the health and safety practices implemented by Plaintiffs employer. RESPONSE: See General Objection #5. Subject to its objections, Union Carbide responds as follows: Union Carbide lacks information as to whether or to what extent it directly supervised the health and safety procedures implemented by contractors working on Defendant's Premises. Union Carbide's investigation remain on-going. Union Carbide did, however, inform and require contractors it) implement health and safety practices required by all employees on its facilities. REQUEST FOR ADMISSION NO, 53: Admit that you did not protect the Plaintiff from exposure to asbestos on Defendant's Premises. RESPONSE: See General Objection #5. Subject to its objections, Union Curbide responds us follows: Denied. See Union Carbide's response to Request No. 8. REQUEST FOR PRODUCTION NO. 55: Produce all documents supporting the legal theories and factual bases of your defenses set forth in your response to Plaintiffs Request for Disclosure under Texas Rules of Civil Procedure 194.2, subparagraph (c). RESPONSE: See General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the patty communications exemption, (i) the right of privacy, or (j) any other privilege, Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence, Objection to the extent the requesi is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same. Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiffs request. DEFENDANT'S RESPONSES TO PLAINTIFF'S FIRST SFT OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION. AND FIRST REQUEST FOR ADMISSIONS- Page 51 fVirm(loea\onvy;cWiraiofla\cOTpNi\w3laiep,Brralil\PlBln: 1511 Sei ol i.norrogs & Roquooi (or Producilon PRINT TIMEAUG. 9. 4:59PM INTERROGATORY NO. 19: Do you contend that Plaintiffs exposure to asbestos at Defendant's Premises was not a substantial contributing factor in causing his asbestos-reJated injury? Tf the answer is anything other than "no", identify each and every fact which supports this contention. ANSWER: See General Objections and Preliminary Statement, which are incorporated herein as if fully rewritten. Objection. This interrogatory is overly broad, unduly burdensome, harassing and annoying given the parameters and subject matter of this case. REQUEST FOR ADMISSION NO. 54: Admit that Plaintiffs exposure to asbestos at Defendant's Premises was a substantial contributing factor in causing his asbestos-related injury. RESPONSE: Sec General Objection #5. Subject to its objections, Union Carbide responds as follows: Denied. See Union Carbide's response to Request No. 8. REQUEST FOR PRODUCTION NO. 56: If you deny the foregoing request, in whole or In part, produce all documents supporting your denial, RESPONSE: See General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiffs request, DEFENDANT'S RESPONSES TO PLAINTIFF'S FIRST SET OF INTERROGATORIES. FIRST REQUEST FOR PRODUCTION, AND FIRST REQUEST FOR ADMISSIONS-Page 52 RHrfntiacaViniartl(a2oilo\cain/)MNoi(irBl'),8no4P,6.rii:i'51" 9i o: irin'togs i Hoquoct iw prwiiiciion 4:25PM PRINT TIMEAUG, 9. 4:53PM REQUEST FOR ADMISSION NO. 55: Admit that Defendant did not exercise reasonable cure to reduce or eliminate the risk of asbestos-related injury. RESPONSE: See General Objection #5. Subject to its objections, Union Carbide responds as follows: Denied. See Union Carbide's response to Request No. 8. REQUEST FOR ADMISSION NO. 56: Admit that Defendant did not reduce or eliminate the unreasonable risk of harm posed by the use of asbestos-containing products at Defendant's Premises. RESPONSE: See General Objection #5. Subject to its objections, Union Carbide responds as follows: Denied. See Union Carbide's response to Request No. 8. REQUEST FOR PRODUCTION NO. 57: If you deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: See General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (c) any privilege relating to confidential trade secrets, proprietary in formation or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege, Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiff s request. DEFENDANTS RESPONSES TO PLAINTIFF'S FIRST SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION, AND FIRST REQUEST FOR ADMISSIONS- Page 53 fsVFlrmdoca\envVccrttHHZor(aVBsmpto6f:VwBirtB|itafnolt?Pieiofjf,'Hsa at Iniaroja & Roquusi tor Production llll'/'ll T!!iEAUG. 5. 4:25FM PRINT TIMEAUG. 9. 4:59PM REQUEST FOR ADMLSSJON NO. 57: Admit that Defendant's failure in reduce or eliminate the risk of harm, to Plaintiff was a substantial factor in bringing about Plaintiffs asbestos-related injury. RESPONSE: Sec General Objection #5. Subject to its objections, Union Carbide responds as follows: Denied. See Union Carbide's response to Request No. 8. REQUEST FOR PRODUCTION NO. 58: Tf you deny the foregoing request, in whole or in part, produce all documents supporting your denial. RESPONSE: See General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (c) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government ugency, (0 the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiffs request. REQUEST FOR PRODUCTION NO. 59: If you contend that while at the premises on which you or your employees were working with asbestos-containing materials. Plaintiff was not exposed to sufficient quantities of asbestos dust to produce the discase(s) complained of, produce all documents supporting your contention. RESPONSE: Sec General Objections, which arc incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary DEFENDANT'S RESPONSES TO PLAINTIFF'S FIRST SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION, AND FIRST REQUEST FOR ADMISSIONS- Page 54 PRimHaciiWnvVxfVirsiotla^pMjllwiiaras.BinoldlPlir.i.Ts l> St of Inerroos 4 Roquoal lor Production FEINT TIMEAUG. 9. 4:59PM information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the parly communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying, Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiff's request. REQUEST FOR PRODUCTION NO. 60: If you contend that Plaintiff is suffering from an asbestos disease as a result of exposures other than asbestos dust at the premises on which you or your employees were working with asbestos-containing materials, produce all documents supporting your contention. RESPONSE: See General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privucy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertuining to plaintiff's request. REQUEST FOR PRODUCTION NO. 61: If you contend that Plaintiff does not suffer from the asbestos-related disease(s) complained of, produce all documents supporting your contention. RESPONSE: See General Objections, which are incorporated herein as if fully rewritten, Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's berween defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) uny privilege relating to confidential trade secrets, proprietary DEFENDANT'S RESPONSES TO PLAINTIFF'S FIRST SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION. AND FIRST REQUEST FOR ADMISSIONS- Page 55 p\f|tiadacn(env\cciMiriuurlii^anipbalKw'j<d'U3,srnal^P^I't Ta 1* Sel o' inerroGi & Requesl [or Prococlion PRINT TIMEAUG. 9. 4:59PM information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or ()) any other privilege, Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaint) IT a request, REQUEST FOR PRODUCTION NO. 62: If you contend that Plaintiff was not exposed to asbestos dust at the premises on which you or your employees were working with asbestos-containing materials, produce all documents supporting your contention. RESPONSE: See General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the parly communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the requesi seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to (he extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiffs request. REQUEST FOR PRODUCTION NO. 63: Produce all documents used, referred to or relied upon in answering any Interrogatories. RESPONSE: See General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other ca-ses regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) DEFENDANTS RESPONSES TO PLAINTIFF'S FIRST SET OF INTERROGATORIES. FIRST REQUEST FOR PRODUCTION, AND FIRST REQUEST FOR ADMISSIONS- Page 56 F\flrmi1nes\en'(eiV>fazoflB\esmpbe(twa4'()p,arnoid',P a .-nil's i" Set ol Interrogs i Raquast lor Prodjcilon :j 4. ?CD)/ FEINT TIMEAUG. 9. 4:59PM the right of privacy, or (j) any other privilege, Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiff s request. REQUEST FOR PRODUCTION NO. 64: Produce any and all documents and other tangible things which refer to the document retention (und/or destruction) policy of Defendant, including the following: a, Any document retention and/or destruction policies for Defendant that pertain to documents and records, including but not limited to supplements, addenda, memoranda, operating bulletins, revisions, or any other superseding 'instructions that referred to the stopping, suspending or resuming of such retention or destruction policies. b. Any record retention and/or destruction, dumping, or purging policies for Defendant that pertain to documents and records created, maintained or stored by electronic and/or magnetic means, including but not limited to records that have been microfilmed, microfiched, imaged, scanned, or stored on tapes, disks, diskettes, CD-ROM, databases, etc. or on or within any computer hardware, backup system, download system, file dumping or other system of information management, whether on-site or off-site, including but not limited to supplements, addenda, memoranda, operating bulletins, revisions, or any other superseding instructions that referred to the stopping, suspending or resuming of such retention or destruction policies. RESPONSE: Sec General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same. Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiff's request. DEPENDANT'S RESPONSES TO PLAINTIFF'S FOIST SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION, AND FIRST REQUEST FOR ADMISSIONS- Page 57 RRrnidacMflnvtotorKoriaMmpDamwaiclTJo.umDltfP a n'-ife set 0/ irie'ioy & flatfjMi lor Pronucilan 4:25PM PRINT TIMEAUG. 9. 4:59PM REQUEST FOR PRODUCTION NO. 65: Produce any and all documentation, including but not limited to lists, inventories, indices, databases or print-outs thereof archives, storage inventories, logs, or other search aids that refer or relate to the existence, extent, type, organization, filing system, method of access; or retrieval, and/or location of Defendant's documents (maintained or stored on-site or off-site) described in the preceding paragraphs. RESPONSE: See General Objections, which arc incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating io communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (c) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiff's request, INTERROGATORY NO. 20: Does Defendant have in its possession any books, pamphlets, memoranda, or written materials of any kind or character that would indicate that asbestos fibers, when inhaled, can be hazardous to the health of human beings? If so, identify the individuals who received, maintained, reviewed, or disseminated the information contained in such written materials. ANSWER: See General Objections and Preliminary Statement, which are incorporated herein as if fully rewritten. Objection. This interrogatory is overly broad, unduly burdensome, harassing and annoying given the parameters and subject matter of this case. REQUEST FOR PRODUCTION NO. 66: Produce the written materials referred to in the interrogatory above. RESPONSE: See General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other DEFENDANT'S RESPONSES TO PLAINTIFF'S FIRST SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION. AND FIRST REQUEST FOR ADMISSIONS- Page 58 nF1mu)Da>\unvtccrVfir!]ziirla\campbull\wa!d'up,iimu cf'Pla n Ts, 1" Sul o' in'urrogs t Roqjosi (of Production 4:25PM PRINT TIMEAUG. 9, 4:59PM cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with uny government agency, (0 the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiff's request. REQUEST FOR ADMISSION NO, 58: Admit that Plaintiff filed suit against Defendant within two (2) years of the date of discovering his asbestos-related condition or the existence of uny asbestos -related causes of action. RESPONSE: This defendant is unable to either admit or deny this request for admission because the investigation for defendant's responses to discovery is still ongoing. Therefore, denied. I REQUEST FOR ADMISSION NO. 59: Admit that Defendant is liable for Plaintiffs asbestos related illness. RESPONSE: SeeGeneral Objection #5. Subject to its objections, Union Carbide responds as follows: Denied. See Union Carbide's response to Request No, 8. REQUEST FOR ADMISSION NO. 60: Admit that asbestos is still in use and/or in place on Defendant's Premises. RESPONSE: See General Objection #5. Subject to its objections, Union Carbide responds as follows: Denied. See Union Carbide's response to Request No. 8. DEFENDANT'S RESPONSES TO PLAINTIFF'S FIRST SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION, AND FIRST REQUEST FOR ADMISSIONS- Page 59 flnimaocotoflvtartBfitfailataairpD&l'waWrflS.arnol.'Miv'/ a l* 6ul c( .rnrogs 1 Raqaaal loi Pfwkcllcn 9. 4:25PM PRINT TIMEAUG. 9. 4:59PM REQUEST FOR ADMISSION NO. 61: Admit thai Defendant no longer uses asbestos on its Premises. RESPONSE: Sec General Objection #5. Subject to its objections, Union Carbide responds as follows: Denied. Sec Union Carbide's response to Request No. 8. REQUEST FOR PRODUCTION NO. 67: Produce all documents that reflect, indicate or in anyway relute to communications between you and any manufacturer of asbestos-containing products concerning or related to the asbestos contained in such products. RESPONSE: See General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (c) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same. Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiff's request, REQUEST FOR PRODUCTION NO. 6B: Produce all documents disseminated or published by any trade association that contain information relating to the hazards of asbestos and all documents which refer lo such documents. RESPONSE: See General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel lor defendant and counsel for other defendants in this or other cases regarding defense of this case, (cl) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (c) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness DEFENDANT'S RESPONSES TO PLAINTIFF'S FIRST SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION, AND FIRST REQUEST FOR ADMISSIONS- Page 60 PFlrmdoc\flnv\cci^ra2Dria\cBmjlll\watdriip smcW.P; r:i{i's i* So: o' Imu-ioes i Reqoaal lor Proajciion 9. :?5FM FEINT TIMEAUG. 9. 4:59PM exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to `the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will .supplement if Defendant has any documents in its possession pertaining to plaintiff's request. REQUEST FOR PRODUCTION NO. 69: Produce all documents, that relate to any inspections by any regulatory agency for the purpose of ascertaining whether health or safety regulations were being followed or adhered to at any of your plants. This request specifically seeks any and all such documentation referring to dust hazards, including but not limited to asbestos in your plants. RESPONSE: See General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege, Objection to the exient the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without wuiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiff's request. REQUEST FOR PRODUCTION NO. 7Q: Produce all safety meeting minutes or other documents, that refer to the dangers of asbestos safety measures to be used in the vicinity of asbestos at Defendant's Premises. RESPONSE: See General Objections, which are incoiporated herein as if fuJIy rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (0 the expert witness DEFENDANT'S RESPONSES TO PLAINTIFF'S FIRST SET OF INTERROGATORIES. FIRST REQUEST FOR PRODUCTION, AND FIRST REQUEST FOR ADMISSIONS- Page 6] BFtmdncs\flriv\arthraio(lli\C3ripDQHwalarop,arrcH(/'Plalnilira Set c( hierrugs & Raquesl ror Produslion PRINT TIMEAUG. 9. 4:58PM exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiff's request. REQUEST FOR PRODUCTION NO. 71: Produce all contracts, or other documents that relate to abatement of asbestos at Defendant's Premises. RESPONSE: See General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiffs request. REQUEST FOR PRODUCTION NO. 72: Produce all contracts, or other documents thul relate to the installation of asbestos products at Defendant's Premises. RESPONSE: See General Objections, which arc incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, fc) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) DEFENDANT'S RESPONSES TO PLAINTIFF'S FIRST SET OF INTERROGATORIES. FIRST REQUEST FOR PRODUCTION, AND FIRST REQUEST FOR ADMISSIONS- Page 62 PRrmflocatonvtotoraartatfampoatoa.a'eiJ.flinalJMsn.Ti i-1 Soi oi iriuiioss t Requa6i foe Profljcilon FEINT TIMEAUG. 9. 4:58PM the light of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiff's request, REQUEST FOR PRODUCTION NO. 73: Produce nil documents that in any way reflect a removal plan organized written criteria or schedule for the removal of asbestos at Defendant's Premises. RESPONSE: See General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets,.proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiffs request. REQUEST FOR PRODUCTION NO. 74: Produce all documents related to the medical condition of Plaintiff at anytime during his work at Defendant's Premises. This request specifically includes any and all x-rays, x-ray reports, medical notes and/or medical records of any kind, annual physical forms, and employment records relating to Plaintiffs health. RESPONSE: See General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (cl) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (c) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (0 the expert witness DEFENDANT'S RESPONSES TO PLAINTIFF'S FIRST SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION, AND FIRST REQUEST FOR ADMISSIONS- Page 63 Rflimi(sW[MccrtbrazonotoinpDaii\wi tCap.stnolJP s nn'"s f Ss, o( nie'ioqs 4 Heqt,ooi lor Pronjcikm PRINT TIMEAUG. 9. 4:58PM exemption, (g) the witness statements exemption, (h) the paity communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence, Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, ancl annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiff's request. REQUEST FOR PRODUCTION NO. 75: Produce PIainLi ITs entire personnel file from Defendant's Premises, RESPONSE: See General Objections, which arc incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or 0) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, ancl annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiffs request. REQUEST FOR PRODUCTION NO. 76: Produce all documents that reflect the layout of Defendant's Premises, including the location and dimensions of all buildings and the location and placement of asbestos-containing products. RESPONSE: See General Objections, which are incorporated herein as if fully rewritten. Objection to the extern the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks DEFENDANT'S RESPONSES TO PLAINTIFF'S FIRST SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION, AND FIRST REQUEST FOR ADMISSIONS- Page 64 rmooc3\env\cc(M>razor: ampi>of iwsiiwp Fiaimv s Sc-i o< iniorrofls S flsquesi tor P'oducw)n PRINT TIMEAUG, 9. 4:58PM information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiff's request. REQUEST FOR PRODUCTION NO. 77. Produce all documents containing any warnings concerning the possibility of injury resulting from the use of asbestos-containing products or exposure to asbestos. RESPONSE: See General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel Cor defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiffs request. REQUEST FOR PRODUCTION NO. 78: Produce all photographs of asbestos products in place or asbestos-containing products being fabricated or utilized at Defendant's Premises. RESPONSE: See General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relaiing to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks DEFENDANT'S RESPONSES TO PLAINTIFF'S FIRST SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION, AND FIRST REQUEST FOR ADMISSIONS- Page 65 PFIfmdonslanvtccMrMaflolcflmpiiflWivii d'ep.a'na jAN phI'h f" Sai o' inomcs Rsqaasi loi Piaticilon FEINT TIMEAUG. 9. 4:58PM information not feasibly calculated to lead to the discovery of admissible evidence, Objection to the extent Lire request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiff's request, REQUEST FOR PRODUCTION NO, 79: Produce all photographs of warning signs or warning statements which are or have been in place at Defendant's Premises in the vicinity of asbestos-containing products. RESPONSE: See General Objections, which arc incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (0 the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege, Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same. Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiffs request. REQUEST FOR PRODUCTION NO. 80: Produce all documents relating to any individuals claimed injury as a result of exposure to asbestos at Defendant's Premises, including, buL not limited to, workers compensation claims. RESPONSE: See General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, fh) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to DEFENDANT'S RESPONSES TO PLAINTIFF'S FIRST SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION, AND FIRST REQUEST FOR ADMISSIONS- Page G6 F\F|rrpduts\nnyVM:r\tii2U!i!'caT(iDel'velC(S[),s-0!i?Plaln!!!,= tSai aItnl&rngj a Request'or Production FEINT TIMEAUG. 9. 4:58PM the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiffs request. REQUEST FOR PRODUCTION NQ. S J: Produce all documents, including but not limited to, corporate minutes, which mention the hazards or potential hazards of asbestos. RESPONSE: See General Objections, which are incorporated herein as if fully rewritten, Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communicaiions with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated lo leud to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections und without waiving same. Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiffs request. REQUEST FOR PRODUCTION NO, 82: Produce all documents, including invoices, shipping receipts, bills of lading and purchase orders, related to the purchase of asbestos-containing products for use at Defendant's Premises. RESPONSE: See General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily DEFENDANT'S RESPONSES TO PLAINTIFF'S FIRST SF.T OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION. AND FIRST REQUEST FOR ADMISSIONS- Page 67 BFIrmdoDswnvtectoiaiafiMarnaiiai'ws d-op.a-nfl:^P a ni.fl'j i" So\ oi irtu'icoi 4 Roquosi lor Prcajciloo FEINT TIMEAUG. 9. 4:58PM expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has uny documents in its possession pertaining to plaintiff s request. REQUEST FOR PRODUCTION NO, AT Produce ail documents relating to inspections by labor inspectors, insurance company inspectors or anyone from your company or lured by your company, that included the taking or measuring of "dust counts''. RESPONSE: See General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the aiioniey work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of ibis case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiff's request. REQUEST FOR PRODUCTION NO. 84 In the event that Defendant performed or had performed any dust level counts or measurements of any of its plants or industrial facilities with respect to asbestos dust, produce uny documents, memoranda, or other writings that in any way reflect the results of such studies or counts and actions taken as a result of such counts or studies, RESPONSE: See General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or G) any other privilege, Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to DEFENDANT'S RESPONSES TO PLAINTIFF'S FIRST SET OF INTERROGATORIES. FIRST REQUEST FOR PRODUCTION. AND FIRST REQUEST FOR ADMISSIONS- Page 68 F\F|rmdoca\flrnit:f\brw(i-i8,c6n;3t)6il'.'.`.a (Kep flUWUP i nllil's 1" So: c1 iPiu-wgs i Roquuni lor PmUjclloi PRINT TIMEAUG, 9. 4:58PM the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiff's request. REQUEST FOR PRODUCTION SO. 85: Produce all reports, writings (whether published or unpublished) and/or other documentation written, created and/edited by any of your experts that in anyway pertain to asbestos and the hazards and/or diseases that may result therefrom. r RESPONSE: See Genera) Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same. Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiff's request. REQUEST FOR PRODUCTION NO. 86: Produce all documents which will be used at the time of trial, including all potential exhibits and those documents which maybe used to cross-examine other witnesses or in rebuttal, and which you contend are relevant to any of Defendant's enumerated defenses in Defendant's most recently filed Answer. RESPONSE: See General Objections, which are incorporated herein as if fully rewritten. Objection to the extern the request seeks information protected by the (a) attorney-client privilege, (b) Lhe attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the purly communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks DEFENDANT'S RESPONSES TO PLAINTIFF'S FIRST SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION, AND FIRST REQUEST FOR ADMISSIONS- Pagu 69 iF\Rfrnt)flC5t8nutcciA6f5Jur6teaT,p5e!l'*'aWrflp,6T'acfiPlaln(ll's <* Se; o! |r,idfttjs fieqyesi 'arPmoo!1 TIMEAUG. 9. 4:53PM information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extern the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiff's request. REQUEST FOR PRODUCTION NO 87: Produce documents between Defendant and any of its worker's compensation carriers regarding the hazards of asbestos and asbestos-containing products. RESPONSE: See General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-cJient privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant und counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to leud to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiff's request. REQUEST FOR PRODUCTION NO. SB: Produce a copy of all regulations, orders, rules and/or policies which have been used relating to the safely of the Defendant's Premises. RESPONSE: See General Objections, which are incorporated herein as if fully rewritten. Objection to the extent ihe request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defens:* of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (c) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government ugency, (0 the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to DEFENDANTS RESPONSES TO PLAIN flTE'S FIRST SET OF INTERROGATORIES. FIRST REQUEST FOR PRODUCTION, ANP FIRST REQUEST FOR ADMISSIONS- Page 70 RPnraocs\arv\o:rttiiazons-fia,"pi!e!fB!ilfp,8fnolil'l,lainiiif s K Sei of nioi t.js & Rocuosl fur P'ca.ei,cn NT IIMEAUG. 4:58PM the extern the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement il Defendant has any documents in its possession pertaining to plaintiff's request. REQUEST FOR PRODUCTION NO. 89- Produce all documents which contain complaints by employees of the Defendant's Premises regarding safety conditions and work place conditions at the Defendant's Premises. RESPONSE' See General Objections, which are incorporated herein as if fully rewritten, Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel lor defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (0 the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiff's request. REQUEST FOR PRODUCTION NO. 90: Produce ail documents which contain complaints by Union representatives of Defendant's Premises regarding safety conditions and work place conditions at the Defendant's Premises. RESPONSE: See General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (t) the expert witness exemption, (g) the witness statements exemption, (11) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information nor feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily DEFENDANT'S RESPONSES TO Pl.AlNTIFF'S FIRST SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION. AND FIRST REQUEST FOR ADMISSIONS- Page 71 F\Finrflwto'iver!X)rs;>v elrompw'iwfldrflp.S'nfl^ anliC's111 spi n! Ir'ermsa 6 flequesi !or Pracxwn PRINT TIMEAUG. 9. 4:57PM expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same. Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiff's request. REQUEST FOR PRODUCTION NO, 91: Produce all documents, organizational charts or rosters which identify the members of the management at the Defendant's Premises and their areas of responsibility during the time period of Plaintiffs work at Defendant's Premises. RESPONSE: See General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expen witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiff's request. REQUEST FOR PRODUCTION NO. 92: Produce all documents which evidence Defendant's, net worth, including but not limited to all "lO-K1' forms filed for the last five (5) years. RESPONSE: See General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (0 the expert witness exemption, (gj the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lend to the discovery of admissible evidence. Objection to die extent the requesi is overly broad, vague, ambiguous, unduly burdensome, unnecessarily DEFENDANT'S RESPONSES TO PLAINTIFF'S FIRST SET OF INTERROGATORIES. FIRST REQUEST FOR PRODUCTION, AND FIRST REQUEST FOR ADMISSIONS- Pnge 72 l:\Hi"noc3''.Bnv\cc!M)r:zof.5\caTipDc! toilarop.i'ia evPiair>)H"1,1 So; 0/ |nia-rtigs i Roods' lor P'oaus.'on 1MEAUG. 9. 4:57PM expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiff's request. REQUEST FOR PRODUCTION NO. 93: Produce all documents which evidence Defendant's purchase, acquisition, sale, or transfer of ownership of Defendant's Premises. RESPONSE: See General Objections, which are incorporated herein as if fully rewritten. Objeciion to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's beiwccn defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the patty communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiffs request. REQUEST FOR PRODUCTION NO. V4: Produce all indemnity agreements, assignments of liability, subrogation agreements and other similar documents relating to Defendant's Premises and liabilities arising from said ownership. RESPONSE: See General Objections, which are incorporated herein as if fully rewritten. Objeciion to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (t) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to DEFENDANT'S RESPONSES TO PLAINTIFF'S FIRST SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION. AND FIRST REQUEST FOR ADMISSIONS- Page 73 Fvr ~cc;s'-anv\ccr\tireio-awomoDel ivv^iclfop ii-ntHcf'.i1 31,1 Sei ol imo'fLOi & floqutu lor P'cajclm IIMEAUG. 9. 4:57PM the extent the request is ovcriy broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiff's request. REQUEST FOR PRODUCTION' NO. 95. Produce all contracts pertaining m work done by contractors at Defendant's facility, RESPONSE: See General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this c|mm or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiff's request, REQUEST FOR PRODUCTION NO. 96. Please produce any printed material produced or published by Defendant containing any warnings concerning the possibility of injury resulting from the use of asbestos-containing products or exposure to asbestos? RESPONSE: See General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating to confidential trade secrets, proprietary information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving DEFENDANT'S RESPONSES TO PLAINTIFF'S FIRST SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION, AND FIRST REQUEST FOR ADMISSIONS- Page 74 r:'"i;r':a.:s'sr/sci'Dii!JO(ir,'ioa"|:bei\wilcie!;,CH'iQl^Fia:n!!tf s of inloi & fiequasl (or Pmc or iAUG. 9. 4 57PM same, Defendant will supplement if Defendant has any documents in its possession pettaming to plaintiff's request. REQUEST FOR PRODUCTION NO. 07: Produce all documents and other tangible things relating to the Plaintiff. RESPONSE: See General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (cl) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (e) any privilege relating lo confidential trade secrets, proprietary information or confidential communications with any government agency, (0 the expen witness exemption, (g) the witness statements exemption, (h) the party communications exemption, (i) the right of privacy, or 0) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to Hie extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiff's request. REQUEST FOR PRODUCTION NO. 98: If you contend that you did not own or control the facility(ies) during anytime period that Plaintiff worked (or believes he worked) at the facility(ie.s), please produce a documentation that supports your contention, 'including but not limited to documentation pertaining to the purchase, sale, acquisition, merger, or divestment of corporations, subsidiaries, divisions, or other corporate entities or assets that included the purchase, sale, acquisition, merger, or divestment of the fncility(ies); such documentation to 11 include, by way of example and not limitation, purchase or sale agreements, minutes, resolutions, annual reports, 10K reports or other state or federal agency Tilings, or deposition, trial testimony or affidavits of your corporate representatives who arc the most knowledgeable individuals with respect to such mutters, RESPONSE: See General Objections, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding the defense of this claim or claims of this type, (c) any privilege relating to confidential trade secrets, proprietary DEFENDANT'S RESPONSES TO PLAINTIFF'S FIRST SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION. AND FIRST REQUEST FOR ADMISSIONS- Page 75 nfiim<la:i\envvcH>W0rti'j:3lT)atiBtlWlawp,Brrii)WPIa n! 'I's 11 Sul ill Iriuiiligi ft Rcquosl lor Prodiclion 4:57PM information or confidential communications with any government agency, (f) the expert witness exemption, (g) the witness statements exemption, (h) the parly communications exemption, (i) the right of privacy, or (j) any other privilege. Objection to the extent the request seeks information not feasibly calculated to lead to the discovery of admissible evidence. Objection to the extent the request is overly broad, vague, ambiguous, unduly burdensome, unnecessarily expensive, harassing, and annoying. Subject to the foregoing objections and without waiving same, Defendant will supplement if Defendant has any documents in its possession pertaining to plaintiff's request. DEFENDANT'S RESPONSES' TO Pf-AINTir-'FS FIRST SET OF INTERROGATORIES, FIRST REQUEST FOR PRODUCTION, AND FIRST REQUEST FOR ADMISSIONS- Page 76 Ff r"0fl:B\u-vx:cn!)rc2oiliV:flmnt)fll'\wB'ae3I9rnii;iW1 alrli'l's l- Sel oi i.iiaiojs & fitscuitff tofProduCKon 4:57PM