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FILE NAME Corning OC DATE 1990 DOC OC297 DOCUMENT DESCRIPTION Legal - Amended Answers of Corning to Interrogatories with Product Chart IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF SOUTH CAROLINA COLUMBIA DIVISION RE Asbestos Litigation Amended Answers to Interrogatories Defendant Corning Fiberglas amends any and all previously filed answers to Interrogatories in asbestos litigation in the District of South Carolina as follows 1. OCF states that it was named as a party in Workmen's Compensation actions filed by persons believed to have been employees of its Contracting and alleging injury from exposure to asbestos Supply Division These claimants were apparently insulation workers who filed actions against numerous past and present employers and alleged injury from exposure to a variety of asbestos and nonasbestos materials over a period of many years OCF response does to not have records to this interrogatory provide a _ complete because Worker's Compensation claims historically have been processed by OCF's insurance carriers and OCF's corporate headquarters would not always have received contemporaneous notification of individual claims -Page 1- OCF has had in its possession certain claims materials from these kinds of Worker's Compensation actions These materials were located for the most part in the Law Department of the company's Santa Clara California manufacturing plant However all of these files originally located at Santa Clara have not been located in company files during a recent review of documents A diligent search continues The following table sets forth the factual information which is presently known about these claims Based on a preliminary review of these materials conducted in 1980 it appears that the injuries claimed were asbestosis and in some instances lung cancer Name 1. Harold Bronson Approx date of claim filed against OCF 1964 2. Leonard Brookenshire 1968 3 Allan Everitt 1963 4. Minnie Louise & Bruce Frederick 1967 5 Steve Gillovich 6. Robert O. Goans 7 Robert E. Goodwin 8 Paul Gratishire 1963 1969 1962 9 Allen Hamberg -Page 2- Location Los Angeles CA Los Angeles CA Fresno CA Oakland CA California Oakland CA Seattle WA 10. Roy B. Harris 11. Gerald Herrick 12. Harold Hilstrom eed 13. Burton Kramer 14. Marvin Lindholm 15. William Lee Mabry 16. W.L. Menzies 17. Fred Moffett 18. Willis E. Moore 19. Edward Meyers 20. George Nelson 21. Henry Puetz 22. John Stanley 23. M.E. Sutton 24. David Swindell 25. William E. Tudor 26. Charles Vincent 27. James Whitcomb Riley 28. Leroy C. Winters 29. John Wyss 1973 1970 1973 1960 1973 1967 1968 1966 1962 1968 1966-1967 1969 1975 1967 1970 1959 1959 1962 Phoenix AZ Anchorage AK Washington Washington Seattle WA Oregon Los Angeles CA Oregon Seattle WA San Francisco CA Phoenix AZ Los Angeles CA Sacramento CA Seattle WA Anchorage AK Albuquerque NM In addition a review of the OCF Toledo Medical Department files indicates the following information relating to these kinds of Workmen's Compensation claims -Page 3- Name 1. Wayne E. Boyer Approx date claim pending against OCF 1969-70 Alleged Injury Asbestosis Location Los Angeles CA 2. Lawrence F. Brimmer 1969 Unknown Grand Rapids MI Maurine Clark 1969-70 Unknown Los Angeles CA James E. Clark 1969-70 Unknown San Francisco CA James Clark 1970 Bruce Frederick Minnie Louise 1967-70 Charles F. Funkhouser 1970 Robert E. Goodwin 1969-70 9. Gerald D. Herrick 1970 10. Robert J. Horsman 1969-70 11. Roy B. Merrill 1969-70 12. Fred Moffet 1967-68 Asbestosis Asbestosis Seattle WA Fresno CA Asbestosis Los Angeles CA Pneumoconiosis Asbestos exposure Asbestosis Los Angeles CA AnchoragAeK Asbestosis Pneumoconiosis Asbestos exposure Disability Exposure to asbestos Los Angeles CA Los Angeles CA 13. Willis W. Moore 1969-70 14. Frances E. Owens 1969-70 15. Edward L. Pfleghar 1968-70 Asbestosis Seattle WA Unknown Los Angeles CA Asbestosis San Francisco CA -Page 4- 16. Henry C. Puetz 1966-70 17. John Stanley 1968-70 18. Vernon F. Tucker 19. William E. Tudor 20. Charles L. Vincent 1969-70 1967-70 1969-70 Asbestosis San Francisco CA Asbestosis Los Angeles CA Asbestosis Los Angeles CA Asbestosis Seattle WA Asbestosis Anchorage AK Additional information relating to that which is discussed herein would be located in OCF's document library OCF states that it has collected numerous records and documents relating to asbestos generally These documents are stored in OCF's document library located in Richmond Virginia The document library contains existing documents generated and received at the OCF corporate headquarters in Toledo Ohio its technical center in Granville Ohio and from manufacturing facilities in Berlin New Jersey Bloomington California Illinois Newark Ohio and Santa Clara The library also contains certain files obtained from Fiberglas Engineering and Supply Company in San Francisco and Seattle Washington Other documents relating to Fiberglas Engineering and Supply Co. of San Francisco are maintained by the law firm of Popelka Allard McCowan & Jones in San Jose California pursuant to an -Page 5- agreement contained in Defendant's response to plaintiffs request for production in Heley et al v Fibreboard et al June 10 1989 The library contains responsive privileged materials generated before and during the time that OCF manufactured containing Kaylo insulation At a mutually convenient time OCF will make available for inspection by plaintiffs counsel the privileged documents stored in its document library Counsel for OCF will provide an index which sets forth the file titles of those files contained in each box and personnel to assist plaintiffs counsel in locating documents responsive to the discovery requests in this matter OCF will also make arrangements for copying documents which plaintiffs counsel may select Copying and shipping costs will be borne by plaintiff unless otherwise ordered by the Court OCF's library includes documents that contain information which is considered to be proprietary and trade secret Therefore they will be produced after the entry of an appropriate protective order OCF has removed from the library any existing materials which it contends are protected from discovery as privileged attorney communications attorney work product materials materials within the physician privilege or those otherwise beyond the scope of permissible discovery Each document removed as privileged has been -Page 6- substituted with an easily identifiable marker which describes the privileged document by document type e.g. memo letter note date author recipient subject matter and basis for objection These markers may be designated for copying in the same manner as privileged documents Visits to the library may be scheduled through OCF's local counsel Certain other Worker's Compensation claims files may have been furnished to OCF by plaintiffs counsel in the course of litigation It is believed that these files were originally obtained from defendants or from public records Copies of these files were not found among OCF's historical documents but some of these files relate to the same claimants whose names appear in the tables above These files number in excess of 2,300 pages and will be made available upon request for inspection and copying at a reasonable cost 2. Attached is Exhibit A to these Answers to Interrogatories is a product chart regarding Corning Fiberglas products This Defendant would state that this product chart includes products which contains less than % asbestos and also which contain asbestine which is not an asbestiform mineral -Page 7- Respectfully submitted LOVE THORNTON ARNOLD & THOMASON William A. Coates 183 V. Clark Price 3155 410 E. Washington Street P.O. Box 10045 Greenville S.C. 803 242-6360 29603 Greenville South Carolina March 13 13 , 1990 -Page 8-