Document pekmbdgKxOEjKZxLedL0XQD16

MKW.'Lh^ r ( IL030a.ASB 05/26/89 K-1950 STATE OF ILLINOIS IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT COUNTY OF MCLEAN RAVALEE WILKERSON, Individually and as Special Administrator for the Estate of FRANK E. WILKERSON, Deceased, Plaintiff, vs. ARMSTRONG WORLD INDUSTRIES, et al., Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) NO. 88 L 236 DEFENDANT, OWENS-ILLINOIS, INC.'S SUPPLEMENTAL RESPONSES TO PLAINTIFFS' FIRST REQUEST FOR DISCOVERY FROM DEFENDANT. OWFNS-TT.T.TNOIS. INC. PRELIMINARY STATEMENT Some of the events which may be relevant to the matters inquired about by Plaintiffs' Request for Production apparently occurred more than thirty-five years ago. In addition, effective April 30, 1958, Owens-Illinois, Inc. disposed of the business involved in this action by way of sale of that business to OwensComing Fiberglas Corporation. Since that time, Owens-Illinois, Inc. has not engaged in any such business. It does not now and it has not: since that sale manufactured, distributed or sold any asbestos-containing products. As a result of the foregoing factors, investigations to date indicate that at least some documents which relate to matters inquired about by these requests may have been transferred to Owens-Coming Fiberglas Corporation with the transfer of the business in question in 1 J'JH 16 89 fr 1958. Owens-Illinois, Inc. is engaged in a continuing investigation in an attempt to locate, confirm the transfer of, or confirm the absence of, such documents and is also engaged in a continuing investigation into the matters inquired about in these requests. Unless otherwise stated in an answer to a specific request, the answers set out hereinafter are limited to the period during which Owens-Illinois, Inc. manufactured asbestos-containing insulation products and to the facilities related to that business. The following is a part of and is incorporated by reference in every answer provided hereinafter: This answer is accurate as of the date made. However, Owens-Illinois, Inc.'s investigation is continuing, and Owens-Illinois, Inc. cannot exclude the possibility that it may be able to obtain more complete information or even information which indicates that the answer being supplied is incorrect. OwensIllinois, Inc. objects to answering this request in regard to any period of time other than the period during which it engaged in the business involved in this case which ended in mid-1958 or concerning any facility not related to that business, on the basis that any such answer would be irrelevant to the subject matter of the pending litigation, would not be reasonably calculated to lead to the discovery of admissible evidence, and would be burdensome and oppressive. Furthermore, Owens-Illinois, Inc. objects to the instructions and definitions supplied by plaintiffs with regard to these requests, on the basis that the definitions are overbroad, vague, and often inconsistent with the normal usage and meaning of such words, and the instructions are overbroad, burdensome and constitute an unreasonable expansion of the requests themselves. Owens-Illinois, Inc. therefore gives notice 2 Ic ( that it does not consider itself bound by the instructions and definitions propounded by plaintiffs, and instead shall answer the requests in a manner consistent with a normal understanding of the language used in the requests and to the extent necessary to fairly and fully answer the requests. REQUEST SO. 1. All witness statements of any sort, whether signed or unsigned (together with all documents purporting to reflect the same), and a list of those statement for which a privilege from disclosure is claimed. RESPONSE NO. 1. This defendant nor its local counsel is in possession of materials referred to in this request. This defendant reserves the right to supplement its response at any time in the future. REQUEST NO. 2. All data as to the physical or mental condition of Frank E. Wilkerson excluding all documents provided you by plaintiffs' counsel and excluding all documents, copies of which have already been provided plaintiffs' counsel through formal discovery. RESPONSE NO. 2. This defendant nor its local counsel is in possession of materials referred to in this request. This defendant reserves the right to supplement its response at any time in the future. REQUEST NO. Wilkerson. 3. All photographs of Frank E. RESPONSE NO. 3. This defendant has found no documents responsive to this request. REQUEST NO. 4. All photographs, models, sketches or diagrams of any of the sites at which Frank E. Wilkerson worked. 3 r RESPONSE NO. 4. This defendant nor its local counsel is in possession of materials referred to in'this request. This defendant reserves the right to supplement its response at any time in the future. REQUEST NO. 5. All photographs, models, sketches or diagrams of any of the products involved in this litigation. RESPONSE NO. 5. Refer to Exhibit I of this defendant's answers to plaintiff's Interrogatories which may contain information relevant to the subject matter of this interrogatory. REQUEST NO. 6. All pamphlets, brochures or other documents prepared, distributed or utilized by defendant to advertise or promote asbestos-containing products during the 1950's or 1960's. RESPONSE NO. 6. This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958. To the extent that this request refers to the period of time during which this defendant engaged in the manufacture, sale and distribution of asbestos-containing products, refer to Exhibit I of this defendant's answers to plaintiff's interrogatories. REQUEST NO. 7. Each document authored by an employee of defendant in the course of his employment, dealing in whole or in part with the consequences of exposure to asbestos. RESPONSE NO. 7. This defendant objects to this interrogatory as being unintelligible, overly broad, burdensome and oppressive, not reasonably calculated to lead to the 4 rc discovery of admissible evidence and not limited to any issue which is the subject of this case. REQUEST NO. 8. All medical records of those present or former employees of defendant who have filed claims for worker's compensation or occupational disease benefits alleging an injury or disease from exposure to asbestos and all personnel and employment records which evidence or reflect the duration, quantity and quality of his or her exposure to asbestos while employed by defendant. RESPONSE NO. 8. This defendant objects to this interrogatory on the basis that it seeks information which is not relevant to the subject matter of this litigation and is not reasonably calculated to lead to the discovery of admissible evidence, except as it relates to the period of time during which this defendant engaged in the manufacture, sale and distribution of its asbestos-containing products. Without waiving the above objection, during the period in which this defendant engaged in the manufacture of its asbestos-containing products, it received no workers' compensation claims for any asbestos-related disease. REQUEST NO. 9. Each written warning, caution or other document which was intended by defendant to reach those persons who would breath or ingest the asbestos from asbestos- containing products manufactured and/or sold by defendant. RESPONSE NO. 9. This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958. This defendant has no documents responsive to this request in its business records. It does not appear that any warning concerning asbestos was given in that it does not appear that this defendant had reason to believe that the use of its products would result in a foreseeable risk of harm. 5 cr REQUEST NO. 10. A transcript (including exhibits), other than those previously produced in this cause, of each instance where an employee of defendant testified at deposition or trial in asbestos disease litigation. RESPONSE NO. 10. This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958. This defendant is aware that the following present or former employees have testified at trial or by deposition in asbestos-related litigation: Edward C. Ames Robert Grim Richard L. Grimmie David Innis William Justice John Pershing John Rhoads June Welser Everett Shuman Willis G. Hazard Richard R. Beck Samuel F. Schillaci 10/8/79, 1/10/80, 2/12/81, 3/26/81 and 10/7/81. 9/6 & 7/84 (trial), 10/11/84 (trial), and 7/1/87 (trial) 7/10/79, 10/24/79 (trial) and 10/29/79 (trial). 9/27/83. 7/11/79 and 5/3/82. 7/26/79. 7/11/79. 7/11/79. 4/26/79, 6/12/79, 7/15/80, 8/19/80, and 3/4/81. 2/11/81, 3/27/81, 12/14/81, 1/27/82. 4/1/81. 4/7/81, 7/31/81 (trial), 11/9/81 (trial), 11/17/81, 4/26-27/82, 6/4/84, 8/28/84, 9/6/84, 11/14/84, 2/5/85, 3/4/85 (trial), 4/30/85, 12/19/85 (trial), 10/8/86, 4/10/87 (trial), 6/25/87 (trial), 11/4/87 (trial), 1/20/88 (trial), 10/15/88 (trial), 11/22/88 (trial), 11/29/88 6 c( George N. Bates, M.D. Thomas A. Meehan, Esq. (trial), 12/8/88 (trial), and 12/15/88 (trial). 4/6/81. 8/3/81 (trial), 11/9/81 (trial), 12/15/83, 1/16/84, 8/28/84, 6/4/84, and 11/13/84. Effective April 30, 1958, this defendant sold its asbestos-containing product manufacturing division to OwensComing Fiberglas Corporation. At that time certain employees who worked in the division, some of whom are mentioned above, transferred to Owens-Coming Fiberglas Corporation. These individuals have been deposed with regard to asbestos-related litigation involving Owens-Corning Fiberglas Corporation. This defendant objects to the production of copies of the transcripts of these depositions on the basis that said transcripts are filed with various courts around the country, they are therefore matters of public record, and therefore plaintiffs have equal access to such documents. Defendant reserves the right to advance additional arguments against the production of such documents if and when plaintiffs file a request for production. REQUEST NO. 11. A transcript (including exhibits), other than those previously produced in this cause, of each instance where an individual whom defendant listed, retained or called as an expert witness, testified at deposition or trial in asbestos disease litigation. RESPONSE NO. 11. To the extent that this defendant is in possession of copies of such documents, it possesses copies of documents collected only in preparation for litigation. This defendant objects to producing it. The document is available from its proper source. 7 cr REQUEST HO. 12. All documents which record or reflect the asbestos exposure of those present or past employees of defendant who have contracted asbestosis, "lung cancer or mesothelioma; this is a request for the documents which reveal the name or address of the employee, the disease and date of diagnosis, the present or last known condition of the employee, the death certificate, the dates and location of each employment and a description of the jobs performed, and the analysis of each air sample taken from the employee's breathing zone or any air reported to be similar thereto. RESPONSE NO. 12. This defendant objects to this request as being vague, ambiguous, irrelevant, overly broad, burdensome and oppressive, not reasonably calculated to lead to the discovery of admissible evidence and not limited to any issue which is the subject of this case. Without waiving the above objection, during the period in which this defendant engaged in the manufacture of its asbestos-containing products, it received no workers' compensation claims for any asbestos-related disease. reports. REQUEST NO. 13. Defendant's last three annual RESPONSE NO. 13. This defendant objects to this request on the basis that it seeks information which is not relevant to the subject matter of this litigation and is not reasonably calculated to lead to the discovery of admissible evidence, except as it relates to the period of time during which this defendant engaged in the manufacture, sale and distribution of its asbestos-containing products. REQUEST NO. 14. All documents reflecting or evidencing the sale of asbestos or asbestos-containing products to the companies and/or sites listed on Exhibit A, from 19661988, including, but not limited to, purchase orders, invoices, 8 r( and bills of lading depicting sales of asbestos or asbestoscontaining products to those companies and or jobsites. RESPONSE NO. 14. This defendant ceased the manufacture, sale and distribution of asbestos-containing products in 1958. This defendant has found no documents responsive to this request. REQUEST NO. 15. A list of the names, addresses, and employers of each person involved or consulted in the preparation of your response to this request. RESPONSE NO. 15. This defendant states that it has referred to the relevant business records of the Owens-Illinois Glass Company, which are still in the possession of OwensIllinois, Inc., in connection with the preparation of answers to these interrogatories unless otherwise indicated. Further, this defendant objects to this interrogatory as being irrelevant and not reasonably calculated to lead to the discovery of admissible evidence and not limited to any issue which is the subject of this case. This defendant further objects to this interrogatory on the grounds that it seeks information within the work-product privilege and on the ground that it is oppressive and burdensome in that it would have to review all of the files and all of the records of all of its attorneys all over the country to respond to this interrogatory. REQUEST NO. 16. An affidavit stating whether production is complete according to the knowledge of defendant and defendant's insurance carriers, attorneys, agents and employees. RESPONSE NO. 16. This defendant states that it has referred to the relevant business records of the Owens-Illinois Glass Company, which are still in the possession of Owens- 9 c Illinois, Inc., in connection with the preparation of answers to these requests unless otherwise indicated. 10 ( AFFIDAVIT ( STATE OF OHIO COUNTY OF LUCAS ) )SS: ) A. H. SMITH, being duly sworn according to law, deposes and says that he is an Assistant Secretary of Owens- Illinois, Inc., a defendant herein; that as such he is authorized to make an Affidavit on its behalf; and that the facts set forth in the foregoing DEFENDANT, OWENS-ILLINOIS, INC.'S RESPONSES TO REQUEST FOR PRODUCTION, are true and correct to the best of his knowledge, information and belief. /?, tj, A. H. SMITH SWORN TO before me and subscribed /^ this day of . /1989. Notary Public My Commission Expires: SNIftlEY j. S20CZYNSKI Notory Public, State of Ohio My Commission Expires Oct. 15, 1992 rc EXHIBIT I A NEW HEAT INSULATION WITH A REMARKABLE COMBINATION OF ADVANTAGES.... Kaylo Heat Insulating Bloc a new type of lightweight miners suiadon that is ejficitnt enough tc used at ordinary room temperatt and ruistant enough to perform e: lively up to 1200 F. Few new products of any kind 1 been so thoroughly researched be: being placed on the market. K; Heat Insulating Block is the achi mem of many years' work by Owi Illinois Glass Company engine physicists and chemists. No other material, new or old effectively combines the most de able characteristics of the ideal ; insolation. For instance ... tow DENSITY Kaylo Seat Insulating B1 weighs only 11 pounds per cubic t This light weight (less than one po to the board foot) simplifies handl shipping and application. It grt reauces weight --an important ad tage on ships, for an example. Notice the clean, straight e on these insulated precipitator pers. Applicators find it easy to do kind of work with Kaylo Heat Ins ing Block because they are so eat cut and yet they have a - ithely flexural strength. The - .s abo' t hoppers are also insulated with K Heat Insulating Block. OW THERMAL CONDUCTIVITY The coefficient of conductivity, or K", '.iylo Heat Insulating Block, t ,l-<. . on the chart on page four. it among the most, efficient in flations for medium high temperaires. Its insulation value comes prin.pally from its fine, interlaced cellular :rucrure. These cells are so tiny and 3 numerous that they pres'ent a matrial surface of approximately 140 ares per cubic foot of insulation. Experience shows that the insulaon value of Kaylo insulation imroves when the material is put into ervice. FFECTIVE OVER WIDE EMPERATURE RANGE Kaylo Heat Insulating Block perorms efficiently not only on temperaures in the low pressure steam ana hot vater range but on temperatures in he superheated steam range as well. This is shown by the flatness of the onductivity curve. One-material cov-rage with Kaylo insulation handles tpplications which often require two hicknesses of different materials. rllG^ COMPRESSIVE STRENGTH compressive strength is uniSL .y high for a mineral product of uch light weight. Kaylo Heat Insu- i liting Block withstands compression values equivalent to those of a man's walking on it or even to those of a heel's being ground into it. HIGH FLEXURAL STRENGTH Its flexural strength is higher than the normal requirement for heat insulacion of this type. This strength makes for easy handling and applica tion, and contributes to long service with low maintenance. NO ADDED BINDER Kaylo insulation is an inorganic compound, containing no added binder. Its performance characteris tics, therefore, are not affected by additives, which often reduce insulat ing value, modify effective tempera ture range or otherwise limit per formance. EASY TO APPLY WELL Kaylo Heat Insulating Blocks are clean-cut and trim. They are easy to fit into place to make a good-looking installation. Their "feei" is pieeeet end WB-irritiriag. They can be cut. scored and sawed with ordinary wood working tools. Finishes that go over the block, whether cement, cloth or other types, can be applied smoothly and with a minimum of effort. No special tools are needed. loCT moisture absorption Moisture absorption is no prob lem with Kaylo insulation. Even when subjected to an atmosphere of 90 9c relative humidity and a temperature of 120 F., in standard tests, speci mens absorb less than 1 % moisture bjl volume. RETAINS EFFECTIVENESS AFTER LONG SERVICE Kaylo Heat Insulating Block re mains strong, free from excessive powdering, and shows little loss in weight or shrinkage after long appli cation to temperatures up to 1200 F. Even conventional tumbling tests, run after prolonged heating, produce relatively little crumbling or break down of the material. STANDARD SIZES Lengths Widths (inches) (inches) 36 6 36 6 _____36 6 _____J6__ 36 6 6 36 12 36 12 36 12 36 12 36 12 Thicknesses (inches) 1 l'A 2 2>/4 3 l IVi 2 2 V4 3 Other sizes are available on special order. I- A REMARKABLE VERSATILITY On large or small equipment, in side or out, Kaylo Heat Insulating Block performs efficiently and with a mil im of maintenance. Here it is be< applied to the walls of a large p' -iutor. Workmen are laying block over 6" x 6" wire mesh welded to the stiffeners. The block are ihen covered with finishing cement and asphalt mastic w earherproofing. Kaylo Heat Insulating Block cov ers both flat and curved surfaces on the power house equipment pictured here. At the right are fresh air intakes; the center compartments house in duced drafr fans; and at the left are conduits leading to a precipitator. Kayio insulation means continuous fuel savings to this power plant. Hot water is always ready when needed in the office building where this hot water storage tank is installed, thanks to Kaylo Heat Insulating Block. This permanent insulation holds water temperature constant with a minimum of power consumption. Other zpplications for Kaylo Heat Insulat ing block are listed on the hack page PRINCIPAL FEATURES OF KAYLO A EAT INSULATING BLOCK PHYSICAL CHARACTERISTICS AT A G LANCE ^ Aiter^boilir.g for 2. hourf(wiiii. wrQ ib pr4q|jAig^ -lfcgr~ - %%,/ v After headng for 24 houra.-.-'Y.,-''; *- ^^ *t 750* F.Y.;..... ..\i........... 5^..'...:.... .-IT............ 5.5 at 1000* F............ - ...................... . -4. ..r.. 7_.9 % " at 1200* F.. (/^'.. .^(iii^'"#.;.'......"...'f' i..-t-....*i *..-........-.9*,,5% After boiling for 24 bourses...Y.......... -r.. 0.2% -. ;I*,. ID ypfo c\Sa3^~* (Coaveotioaal Tumbling Test--Lots in weight after 10 miantes)'. -: .* . Before hftony'v><<&*4.tv*.**-* ;**** I 4, ______ ____ Linear Shrinkage after heating for 24 h{ji * -- '- - ; * # a***' arJ50 F fir^a i m 'V* ~ ^ v ^ " n* *st^*,**^.*.*<'.** j *.* * * 0*8% at 1000* E..'r.Yi TTWwwPfc. .^VTrf. r.:?...... '..'.....'.'. `6.9 % - a* 1200*f.............;.`::'h*.`::.-.-...'..':v.v................ i.* Eloogadon after saturation (max.)................. ............................ 0.4% 3DF?7iC? ^32-Fvr^' (volum*) After 6 hours exposure io atmosphere of 120 F. and 90% Relative Humidity.............................................. 0.9% < i .r, 11 *j} .< i At 300 F. raeao temperature........................................................ 0.474 CQSzuv GKISSkZSarOCS Heat Loss, Surface Temperatures and Efficiencies i ix ~s a u HO C4T (NSUurtMG'ttOCX . coNOucrrviTT "***.' ^ ; * -J3T KAXIO HtAT MjUUtMG HOOT mut toss fkm rur suwacu And suw*a ^lAWAomis or hsuwtion SWB A# f rWf *r Vt Vm^dtinn - a da--a--a--m--a--a wr Ditmum lorn m Ar. T 1* Inside or ouuide, for large or'fcxnall, eat-Insalarin Bmdas^^T Hot AirDora v^Tiu*' r-' Au ____ i*nfa; Tower*'".' 'j:,f-"Fara*CM^e^- Dryer* ^ ---. Turbines Evaporators /. . vJL'f Chilling Pits" Heat Exchanger* Boilers 5*f & Condensers^,'- -V '^.v-. Precipitxtorsj. SOURCES /OF^ST DATA ^ :j3jHgfifeT_b:r**:a/aawreJshqwason these p a.g*4e0*-*-u' ^ arosuppaned-by^Best* run at various-, labor*tories,^*H^w*ll- known -to the-! injulanoo industry. ' They are further supported by. the performance of the - product in service. ' >.t` ' '/ ?.*- - i-` % ^ ,-v ... '- ' \' ' ' '~ ' -V S* ^ More detailed information on Kaylo Heat Insulating Block is avail able on request. American Structural Products Company, Toledo 1, Ohio. Subsidiary of Owens-Illinois Glass Company. ^53 A new hea% ins WITH A REMARKABLE COMBINATION OF KAYLO HUT INSULATING BLOCK is a new type of lightweight mineral insulation that is efficient enough to be used at ordinary room temperatures and resistant enough to perform effectively up to 1200 F. Few new products of any kind have been so thor oughly researched before being placed on the market. Kay lo Heat Insulating Block is the achievement of many years' work by Owens-Illinois Glass Company engi neers, physicists and chemists. It combines the most desirable characteristics of the ideal heat insulation. LOW DENSITY. Kaylo Heat Insulating Block weighs only 11 pounds per cubic foot. This light weight (less than one pound to the board foot) simplifies handling, shipping and application. LOW THERMAL CONDUCTIVITY. The coefficient of conductivity, or k, of Kaylo Heat Insulating Block places it among the most efficient insulations for medium high temperatures. Its insulation value comes principally from its fine, cellular structure. These cells are so tiny and so numerous that they present a material surface of approximately 140 acres per cubic foot of insulation. Experience shows that the efficiency of Kaylo insula tion improves after exposure to service temperatures. EFFECTIVE OVER WIDE TEMPERATURE RANGE. Kaylo Heat Insulating Block performs efficiently not only on temperatures in the low pressure seeam and hot water range but on temperatures in the super heated steam range as well. One-material coverage with Kaylo insulation handles applications which often require two thicknesses of different materials. HIGH COMPRESSIVE STRENGTH. Its compressive strength is unusually high for a mineral product of such light weight. HIGH FLEXURAL STRENGTH. Its flexural strength is higher than the normal requirements for heat insula tion of this type. This strength makes for easy hand ling and application, and contributes to long service with low maintenance. NO ADDED BINDER. Kaylo insulation is an inorganic compound, containing no added binder. Its per formance characteristics, therefore, are not affected by additives, which often reduce insulating value, modify effective temperature range or otherwise limn per formance. EASY TO APPLY. Kaylo Heat Insulating Blocks are clean-cut and trim. They are easy to fit into place to Notice the dean, straight edges on these insulated pre cipitator hoppers. Applicators find it easy to work with Kaylo Heat Insalating Block because they are so easy to cut and yet bare a high flexural strength. On large or small equipment, inside or out, Ktylo Heat Insulating Block performs efficiently and with a minimum of maintenance. Here it is being applied to the walls of a Urge precipitator. I s ation {VANTAGES... iake a good-looking installation. Tlnii ' leasent and rwm-irnranny They can be cut, scored nd sawed with ordinary woodworking tools. Finishes sat go over the block, whether cement, cloth or other 'pes, can be applied smoothly and with a minimum 1 effort. No special tools are needed. OW MOISTURE ABSORPTION. Kaylo Heat Insulat. ng Block absorbs little moisture from surrounding tumid air. FFECT1VE AFTER LONG SERVICE. Kaylo Heat Insulat- ng Block remains strong, free from excessive powderng, and shows little loss in weight or shrinkage after ong application to temperatures up to 1200a F. liven conventional tumbling tests, run after prolonged Seating, produce relatively little crumbling or break down f the material. TYh.-AL APPLICATIONS: r . or outside, for large installations or small, up to . 2oo F.. use Kaylo Heat Insulating Block to insulate: -irloetecAhiirn'"AD1gsu1 Tanks Towers dryers evaporators Heat Exchangers Condensers Lehrs Autoclaves Ovens Furnaces Turbines Chilling Pits Boilers Precipitators Locomotives <aylo Heat Insulating Meek covers both Sat and curved urfaces on the power house equipment pictured here. By ninimizing heat Iota, it saves fuel tad keeps temperatures vithin the room at comfortable levels. \ 4. . V_ r PHYSICAL CHARACTERISTICS DINSItt......................................... " ,b- ** " H' ...JO lb. vf Motinl...... .................I JO lb. per After heotl"9 *ot 7* bow* at 750* .......................................... el 1000 ............................... `|____ A^Vb^V^Va'^'^***'- .U4 lb. ,.m lb- pr 4* ,117 1b r tR. .. 74 lb., ft tR. loss in WHO** After haoitne tor 22 boor, ............................... et 750 .............................................. ................................. et ................................................ ............................................. .............. assistaMCt to *,t****' * w,, h, o(,,, to **> (Cb"-*"'*"01 *""bl,"S lelore haot-e-. After boot** lor 22 boon .................... .......................... et 750 ............................................ ............................. et 1000' ......................................... at 1200 ......................................... ............................ 'Tri"".:"-...... ............ et 7 JO* ......................................... .............................. at 1000| *....................... ................................. eiwt'eoboo offer .................... ............................................. .3.3% .7.9% ..% .0.2% 2.2% .2.7% ,S7% .e.t% .0.8% .0.9% .1.2% J. ,,.J`0%.NV. *--**....................... --..... At J00' f. *" LENGTH (inchev) ______ JL:___ -er^nrrrar 1 ____,L_ ____t____-- ;" ':r^rrz:L~'" -------- ret,------- *1-----------res-------- r '"zen" SOURCES OP TEST DATA: The data shown on these pages are supported by tests run at various laboratories, ail well known to the insu lation industry. They are further supported by the performance of the product in sendee. Mere detailed Information on Kaylo Heat Insulating Block is available on request. American Structural Products Company, Tnl*rln 1 flhw (oyla.Structural Insulating Block;--is a near-white, rigid mineral insulating j^pS^Tuaterial weighing approximately 20 pounds per cubic foot. It is composed prip^pelly f calcium.silicate. Except for density and for those characteris' 1 ; tics that are changed by density it is similar to Kaylo Heat Insulating Block, a lightweight insulation used to insulate against heat loss from hot surfaces. Kaylo Structural Insulating Block (20-lb. density) is designed to develop marimum strength and fire resistance without sacrificing its advantages of light weight and low thermal conductivity. In fact the practical combination of these four properties--strength, weight, insulating value and fire resist ance--makes it almost unique as a building material. It weighs nominally 20 pounds to the cubic foot (actually on an oven dry basis from 19.5 to 22 lb.), has a compressive strength of approximately 500 lb. per sq. in., a "k" of 0.66 at 100 mean and outstanding resistance to the travel of heat and flame at building fire temperatures. I STRUCT!! For use in fabrications that are to be Underwriters' Labor atories inspected, Kaylo Structural Insulating Block is furnished bearing the Underwriters' label for fire hazard classification for building material. Kaylo Structural Insulating Block is not a finished build ing material in itself and is not made for exposure to the weather. Its principal uses are as a structural roof tile, or roof deck unit, in which a steel reinforcing mat is inserted at the time of forming, and as a core material. In this latter use it serves as the core of laminated structures where the faces or laminates are applied with adhesives, and also as the core of structural shells or envelopes where the Kaylo core material is simply inserted in the open spaces and held by its own contact or by such conven tional methods as clips or other attachments. any of these applications it adds rigidity to the structure \nd vastly increases insulation value and fire resistance. PHYSICAL PROPERTIES Light Weight--Nominal 20-lb. density Kaylo Block is about a third lighter than yellow pine. On an oven-dry basis it weighs from 19.5 to 22 pounds per cubic foot. High strength--Its compressive strength is approximately 500 lb. per sq. in. with a deformation of 5 per cent. Flexural strength is approximately 175 lb. per sq. in. Fireproof--Kaylo 20-lb. density Structural Insulating Block has been tested at the Underwriters' Laboratories in Chicago and given the following rating, based on com parison with untreated Red Oak as 100. Flame spread........................ 0.0 Fuel contributed.................. negligible Smoke produced................... 0.0 [___ cofjBUMrr^ir 129 190 Ttmpcrotv't, *F. Good Insulation Value--At low mean temperatures Kay! Structural Insulating Block is one of the most efficien structural mineral insulations. At high mean temperature it still compares favorably with heat insulating materia1 of its own weight. High Light Reflectivity--Where left exposed and untreate (as with the underside of a roof deck) Kaylo Structun Insulating Block has high light reflectivity. Its light r< flection factor is from 70 to 80 per cent. Non-Abrasive Surface--Its surface is non-abrasive. It he a somewhat "soapy" feel that makes it pleasant to handl At the same time it has a firm surface that assures goc contact with surfaces applied over it. Ne Added Binder--It contains no added binder, but i: stead constitutes its own binder. Hence its characterise! are not modified as to temperature limit, solubility, ins lation value, fire resistance or otherwise by "bind limitations." 'r ' ' ' r < L NSULATING BLOCK (20-LB. DENSITY) 'sod Workability--Kaylo Structural Insulating Block is isponsive to wood working tools. It can be sawed with a md saw or power saw, can be routed, tongue-and'ooved, sanded, and, in fact, run through moot woodorking equipment. gh Modulus of Elasticity--The modulus of elasticity of >-lb. density block is approximately 160,000 lb. per sq. in. >w Speckle Hoot--The specific heat of Kaylo Structural isulating Block is approximately 0.22. sllulor Structure--Kaylo Structural Insulating Block is pout 80 per cent inter-communicating air cells. The cells I e extremely small, less than a micron in diameter. 1 iw Moisture Absorption--Kaylo Structural Block is hyoscopic. It will absorb moisture from humid air and will ach equilibrium at lower moisture contents when exposed 1 > lower humidities. However, because of its extremely nail '--'re size and other characteristics, its behavior with spe j moisture differs from that of most porous ma rt it has unusual capacity to distribute moisture iti... its mass, and to give it off to surrounding air of wer moisture concent. s moisture absorption when surrounded by humid air low. Test specimens dried for 24 hours at 215* F., cooled nd then exposed on all surfaces to an atmosphere of 90 er cent relative humidity and a temperature of 120* F. t six hours, absorbed less than one per cent of moisture y volume. onsistent with the common practice for good construe* on involving porous insulating materials of high interna! irface area, Kaylo Structural Insulating Block should e sealed against moisture on the warm side when it is jbjected to extremely low temperatures. ligh Wot Strength--Kaylo Structural Insulating Block, ke most other insulating materials, is not intended to erve immersed in water or exposed to extremely damp or .umid conditions, yet its flexinl strength when wet (imnersed 10 hours) is reduced only about IS per cent. Dimensionally Stable--The dimensions of Kaylo Struct ural Insulating Block change little with changes in moist ure content. Experience has shown from the manufacture of thousands of units of laminated structures that they have unusual dimensional stability and unusual freedom from warping. Available with end without Reinforcing--In the form of roof tile Kaylo Structural Insulation is available with a steel reinforcing mat. In the form of core material for var ious types of structure it is available without reinforcing. Accepts Nalls and Screws--Both nails and screws can be used with Kaylo Structural Block. Tables showing holding power of both are available on request. Nails should be of the cement-coated type without barbs that abrade the sides of the opening they make as they are driven into the block. Galvanized or non-ferrous nails may be used where greater resistance to corrosion is required. Screws may be inserted either with or without drilling a pilot hole. Sizes--Kaylo Structural Insulating Block is made in a standard size of 18 x 36 inches. Since most uses involve manufacturing operations, thick nesses that are practical can best be worked out with the manufacturer ot Kaylo Insulating Products after approxi mate quantities needed are known. These will usually be between one and two inches thick. Certain thicknesses are suggested by certain building re quirements. A thickness offrom 1^ to 2 inches of Kaylo Structural Insulating Block is required to withstand a typical building fire for one hour--usually somewhat more for a partition than for a door because of the greater per formance required of a partition. 204b. and 11-lb. Density Block Can Be Used in Combination. Where two thicknesses of insulation are used to build up an jneulating structure it is * visible to use the two den sities in combination to develop the best insulation value strength and fire resistance. AMERICAN STRUCTURAL PRODUCTS COMPANY Toledo 1, Oblo c ; LAMINATION --------------------:------ ST ominotion over a Koylo Insulating Cor*--Almost any face material may be bonded to Kaylo Structural Insulating Block surfaces. Bonding agents can be selected to meet the requirements of the particular facing--also to satisfy m* ... jm --- . ADHESIVES FOR JOINING .......... .. STRUCTURAL INSULATING BLOCK TO: i. 4 Wood Vonoor Aluminum Stainless Stool C' the service requirements of the finished product--and still offer some choice in curing procedures. Some adhesives which may be used with various tvpes of face materials are listed below. (This list is not intended to be complete. Its only purpose is to identify a partial list of adhesives. These have been found to provide a tensile strength of 35 lb. per sq. in. and a minimum shear strength of 100 lb. per sq. in. when cured in the manner indicated.) ADHESIVES FOR JOINING LIKE MATERIALS: Insulating Block to Insulating Block Aluminum to Aluminum Stainless Steel to Stainless Stool Owrit* Na. 1C24A Q 3026AWH207 3026AW7 (nocelil. 01131 (cere 711 O CafabanO 770 Q Vinyl**.! MA 71-11 Sarlita til Wik 7026 0 Rndwn Sync. X 1341 Q + 1301W (OW) Dun* Ne. 30764 A rn 71S o o IrmIvIi No. 1 ^ Intofloko 4167 Vulceleck 00 oo Dupont 4433 ooo 00oDupont 4444 G. t. 7147 o G. E. 7031 o MA 2I.II AmboHif* PI14 o Settik (XI 13S lidui A o Owrito No. 3074 O Ne. A. NH767 oN100 ooo3 MEC S36 Wddweed 0 IaioIvIi No. 1 O IfitoHoko 4162 oo Vwlcaleck Ovpeet 4433 Dupont oo ooo ooo 0. E. 7142 0. 1. 7031 Vlnyltool MA 21.19 , AioboHito rsu SetKk 703* o o A ** o o UOie Silicate ledwa Q o Owrito 3024A Ftnecelit* 01131 o o WUMd o Iniefut* 1 o 0. t. 3142 o OOMotksn tl 1 SeUctron 3003 o VinyUool o MA 2S-1S AmboHit# o MI4 Setiik 7026 Sottik fxe 131 Sodium Sil'COt* o o o RpdwK Syncs X-S34S 0 o + I30LW (OW) Vulcaleck Dveeet 4433 Dveeaf 4444 OO OOO OOO G. L 7031 Settik 7034 0 O Settik EXE 131 O (dun Q OODve~. 4453 O. E. 7031 SecHk TOW O Q Seitik EXE 131 Q (dun 0 ~ ^0 Clamped at roam temperature for 24 hours. Q Clamped in oven at 120s F. for 1 hour. Symbols for method of cur*: 0 Placed in press at 10 p.s.i. at 300* F. for 10-30 minutos. For Maximum Strength f Q Placed in pross at 100 p.s.i. at 300* F. for 10-30 minutos. [ Q Clamped in oven at 250 F. for 10-30 minutes. gh-frequency curing hu been tried successfully on sn experimental basis with m-ood. aluminum snd stainless steel bonded to a Kaylo sulitmg core. Msny of the manufacturers making the above listed adhesives can provide adhesives suitable for high-frequency curing. r AMBOSOeAK) OTCSQiJCTQiJISAQ. I (PBQDTS <SM(?>AK)V I TOLEDO 1, OHIO Subsidiary of OWINS-IUINOIS GLASS COMPANY Kayla Structural Insulating Black--is a near-white, rigid mineral insulating material weighing approximately 20 pounds per cubic foot. It is composed principally of calcium silicate. Except for density and for those characteris tics that are changed by density it is similar to Kaj/tc Heat Insulating Block, a lightweight insulation used to insulate against heat loss from hot surfaces. Kaylo Structural Insulating Block (20-lb. density) is designed to develop maximum strength and fire resistance without sacrificing its advantages of light weight and low thermal conductivity. In fact the practical combination of these four properties--strength, weight, insulating value and fire resist ance--makes it almost unique as a building material. It weighs nominally 20 pounds to the cubic foot (actually on an oven dr basis from 19.5 to 22 lb.), has a compressive strength of approximate! v oso-> lb. per sq. in., a "k" of 0.66 at 100 mean and outstanding resistance to the travel of heat and flame at building fire temperatures. r I 20-LB. DENSITY For use in fabrications that are to be Underwriters' Labor atories inspected, Kaylo Structural Insulating Block is furnished bearing the Underwriters' label for fire hazard classification for building material. Kavlo Structural Insulating Block is not a finished build** ing'material in itself and is not made for exposure to the weather. Its principal uses are as a structural roof tile, or roof deck unit, in which a steel reinforcing mat is inserted 1 at the time of forming, and as a core material. In this \ latter use it serves as the core of laminated structures 1 where the faces or laminates are applied with adhesives, and also as the core of structural shells or envelopes where * the Kaylo core material is simply inserted in the open spaces and held by its own contact or by such conven tional methods as clips or other attachments. f In any of these applications it adds rigidity to the structure an istly increases insulation value and fire resistance. Mon Temperature, `t. OGood Insulation Valuo--At low mean temperatures Kaylo PHYSICAL PROPERTIES Structural Insulating Block is one of the most efficient structural mineral insulations. At high mean temperatures it still compares favorably with heat insulating materials Light Weight--Nominal 20-lb. density Kaylo Block is about of its own weight. a third lighter than yellow pine. On an oven-dry basis it High Light Reflectivity--Where left exposed and untreated weighs from 19.5 to *22 pounds per cubic foot. (as with the underside of a roof deck) Kaylo Structural High Strength--Its compressive strength is approximately 500 lb. per sq. in. with a deformation of 5 per cent. Flexural Insulating Block has high light reflectivity. Its light re flection factor is from 70 to 80 per cent. strength is approximately 175 lb. per sq. in. Non-Abrasive Surface--Its surface is non-abrasive. It has Fireproof--Kaylo 20-lb. density Structural Insulating Block has been tested at the Underwriters' Laboratories in Chicago and given the following rating, based on com parison with untreated Red Oak as 100. a somewhat "soapy" feel that makes it pleasant to handle. At the same time it has a firm surface that assures good contact with surfaces applied over it. No Added Binder--It contains no added binder, but in stead constitutes its own binder. Hence its characteristics Flame spread....................... 0.0 are not modified as to temperature limit, solubility, insu Fuel contributed..................negligible lation value, fire resistance or otherwise by "binder Smoke produced.................. 0.0 limitations." STRUCTURAL INSULATING BLOCK Good Workability--Kaylo Structural Insulating Block is responsive to wood working tools. It can be sawed with a hand saw or power saw, can be routed, tongue-andgrooved, sanded, and, in fact, run through most wood working equipment. High Modulus of Elasticity--The modulus of elasticity of 20-lb. density block is approximately 160,000 lb. per sq. in. Low Specific Hoot--The specific heat of Kaylo Struc tural Insulating Block is approximately 0.22. Cellular Structure--Kaylo Structural Insulating Block is about 80 per cent inter-communicating air cells. The cells are extremely small, less than a micron in diameter. Low Moisture Absorption--Kaylo Structural Block is hygroscopic. It will absorb moisture from humid air and will reach equilibrium at lower moisture contents when ''nosed to lower humidities. However, because of its emely small pore size and other characteristics, its ocnavior with respect to moisture differs from that of i -most porous materials. It has unusual capacity to dis'tribute moisture within its mass, and to give it off to surrounding air of lower moisture content. Its moisture absorption when surrounded by humid air is low. Test specimens dried for 24 hours at 215 F., cooled and then exposed on all surfaces to an atmos phere of 90 per cent relative humidity and a tempera ture of 120* F. for six hours, absorbed less than one per cent of moisture by volume. Consistent with the common practice for good construc tion involving porous insulating materials of high internal surface area, Kaylo Structural Insulating Block should be sealed against moisture on the warm side when it is subjected to extremely low temperatures. High Wet Strength--Kaylo Structural Insulating Block, like most other insulating materials, is not intended to serve immersed in water or erpoOB"to extremely damp or humid conditions, yet its flexural strength when wet (immersed 10 hours) is reduced only about 15 per cent. Dimensionally Stable--The dimensions of Kaylo Struct ural Insulating Block change little with changes in moist ure content. Experience has shown fi^fcthe manufacture of ............ .. of units of laminated-j^Ktures that they have*unusual dimensional stability and unusual freedom from warping. Available with and without Reinforcing--In the form of roof tile Kaylo Structural Insulation is available with a steel reinforcing mat. In the form of core material for var ious types of structure it is available without reinforcing. Accepts Noils and Screws--Both nails and screws can be used with Kaylo Structural Block. Tables showing holding power of both are available on request. Nails should be of the cement-coated type without barbs that abrade the sides of the opening they make as they are driven info the block. Galvanized or non-ferrous nails may be used where greater resistance to corrosion is required. Screws may be inserted either with or without drilling a pilot hole. Sixas--Kaylo Structural Insulating Block is made in a standard size of IS x 36 inches. Since most uses involve manufacturing operations, thick nesses that are practical can best be worked out with the manufacturer of Kaylo Insulating Products after approxi mate quantities needed are known. These will usually be between one and two inches thick. ^ Certain thicknesses are suggested by certain building re quirements. A thickness of from 1 to 2 inches of Kavlo Structural Insulating Block is required to withstand a typical building fire for one hour--usually somewhat more for a partition than for a door because of the greater per formance required of a partition. 20-lb. and 1 V>Lb. DoncBy Block Can Ba Usad In Combination. Where two thicknesses of insulation are used to build up an insulating structure it is possible to use the two den sities in combination to develop the best insulation value strength and fire resistance. Kaylo Division OWENS-ILLINOIS GLASS COMPANY Talada 1, Ohio r LAMINATION .oininatien a Koylo Insulating Cor*--Almost any face material may bfe bonded to Kaylo Structural Insul ating Block surfaces. Bonding agents can be selected to meet the requirements of the particular facing--also to satisfy the service requirements of the finished product --and still offer some choice in curing procedures. Some adhesives and primers which mav be used with various types of face materials are listed below Th, list is not intended to be complete. Its only purpose is to identify a partial list of adhesives. An adhesive no* listed does not imply that it is not suitable. These ha\S been found to provide a tensile strength of 35 lb per square inch and a minimum shear strength of 100 lb per square inch when cured according to the manufac turer's recommendation. They are not listed in the order of their adhesive strength.) ADHESIVES AND PRIMERS FOR JOINING STRUCTURAL INSULATING SLOCK TO: U k Weed Veneer er Paper or Plastics Steel, Stainless Steel Galvaneal, or Aluminum Kaylo Insulating Block or Cement-Asbestos Board Dvrito No. 302 6A Pnacol*f* 013) Pscora 711 Catobond 720 Vinyltesl MA 21-11 Dvrit No. 3026A or O No. A NH 267 N100 oo OOPocora 711 W Ovrit* 3026A PonocaKt* Ol 131 Armstrong J 1162 o 3MCC 126 GOO ImaMo 1 o P*NOCOlil 01131 O GJ. 2142 o o 0 o o Ambsrlits PI 14 Soil* 7026 dux Synco $-1361+1 JOlW (DW) tortabond t-12 0 o o o o Insalut* No. 1 lntrlah 4162 Vwlcatoch DuTont 4633 OwPonf 4646 0 00 00 000 000 Soloaron 3003 Vmyhool MA 21*19 Ambortito Pt-14 Sott* 7026 loifik ext 138 0 o o 0 o oArmstrong J-1162 * (0006006 (: 2 0 Sodhm Silicate 0 Tg o G.f. 2142 G.t 7031 lotKh 7026 lotik U! 13* 0 dux 0 0 oSynco X-S34S + 1301W (DW) 0 --nobond 1*1 2 o 0 Togo o So>K6 1007 Vloytsool MA 2I-1S 0 0 Amborfit* Pt-14 0 t*ds 0 - 0V Amorous J-1162 t- I Q Clamped at room temperature for 24 hours. Q Clamped in ov*n at 120* F. for 1 hour. Symbols for method of curt: I 0 Placed in press at 10 p.s.i. at 300* F. for 10-30 minutes. For Maximum Strength J Q Placed in press at 100 p.s.i. at 300* F. for 1(^30 minutes. i Clamped in even at 250* F. for 10-30 minutes. ^-frequency curing has been tried successfully on in experiments! .is with wood, aluminum and stainless steel bonded to a Kaylo .isulating core. Many of the manufacturers making the above listed adhesives can provide adhesives suitable for high-frequency curing. Kaylo Division OWENS-ILLINOIS GLASS COMPANY Tsltd* 1, Ohio M2 503 3m ttdl. Oesns-Wepi G<tt C*-*ny * US* The Right Material... Expert Application First. Kaylo Heat Insulation is proved a better material hydrous calcium silicate. Its light weight, strength, waterinsolubility. low conductivity and wide temperature range give you extra advantages at no extra cost. Second, Kaylo distributors have the technical knowledge and experience to provide you with a complete insulating service. Their trained applicators are skilled craftsmen who do neat and efficient installation. To be .are of getting the most out of your insulating dollars for your next job, call the nearest Kaylo distributor. , Chances are you can find him listed in the yellow pages of your phone liook. Ifnot contact us and we'll give you his name. KAYLO WtITt FOi Fttl 100 -- "Xoylo H.ot Insulotion " Address: Dept. N.JFO. Owens-Illinois Gloss Com. pony, Kqylo Division, Toledo I, Ohio. ... first in calcium silicate ...pioneered by OVSENS ILLINOIS Glass Company MAIN OMICI. TOtlOO l. OHIO-KATIO SAUt OMICtl: AtlANTA CHICAGO HOUSTON NlW T0K FHIIAOUFHIA PITTSlUtOH U lOUil Owenslllinots Glass Company-- Kaylo Division Advertisement No. K I S3, ppeannc <n the following pubheetions: Cltemival Entmeermt Jan . 19S3 Oil A Cat Journal-Jan U. t9SJ Plant Enttneennf Jan . 19S3 Power -- Jan . 1953 Petroleum Refiner- Feb . 1953 Chemical Procesamt -Feb.. 19S3 for Radii fr:m '/4lnch... _< * Nesting Kayio Heat Insulation Requires Fewer Pieces Per Job The complete range of Kayio Insulation includes pipe covering in Simplified Dimensional Standards for diameters from H in. to 72 in., curved block from 72 in. to 60 ft. and fiat block for surfaces of less curvature whose radii approach infinity. With its wide selection of interchangeable sizes and shapes, Kayio Insu lation reduces the number of items needed per job and permits substantial savings in warehousing maintenance stock. WIITt FOI nt( KAY HIOIWt ... Addreifc Oept N*371, Owans-Utinoit Glpss Compony, Koyto OtvioiOA* Tolad# 1, Ohio. first in calcium silicate ...pioneered by OWENS (j)>ILLINOIS Glas* Company MAIN OPMCt: TOIIOO 1, OMIO-KAYIO 5AII5 OfPICISt AKAMTA CHICAGO HOUSTON MW TOtK PHfUOflPMTA PmVtON $T IOUIS Owens-Illinois Glass Company Advertisement No. K 15*"ippcnnng >n the following publications: Plant Knftneermf--Morch. 1953 Oil 6o Gas Journal--March 73. 1953 Chemical Enfineertnt-March. 1953 Chemical Processing - April. 1953 Petroleum Refiner May. 1953 f( PROOF OF SERVICE The undersigned certifies that a copy of the foregoing instrument was served upon the attorneys of record of all parties to the above cause by enclosing same in an envelope with postage fully prepaid, and by depositing said envelope in A5a United States Post Office mail box in Peoria, Illinois, on ^ W . 19 , addressed to such attorneys at their business address as disclosed by the pleadings of record herein. Copy Mailed To: See attached list < c ( 1 F. 5953, W1 lkerson, Ravaleo, Adm./F.st n( e nf I> .ml' F . U i 1 Wr>r:r>ii, Doroflcr'H W11.KF.RS0 - WH.KFRSO.F, ELEVENTH CIRCUIT, McLean Cnnniv. N- R 1, 236 ATTORNEYS FOR PIATNTIFF James Walker Attorney at Law P.0. Box 3455 Bloomington, 1L 61702-5044 ATTORNEYS FOR RAYMARX and CFLOTF.X Fred B. Moore v Livingston, Barger, Brandt & Schroodor 115 W. Jefferson St. - Suite 400 P.0. Box 3457 B1oomin gton, TI. 61701-3457 Raymond H. ModesItt Patrick, Wilkinson, Goeller & Modesitt 333 Ohio St. P.0. Box 1567 Terre Haute, TN 47808-1567 ATTORNEYS FOR V.R. GRACE Bret S. Babcock Reardon, Orr, Dvorak & Babcock 2515 E. Washington St. East Peoria, IL 61611 ATTORNEYS FOR ARF.X CORPORATION Robert W. Scott Swain, Hartshorn & Scott 1806 Savings Center Tower 411 Hamilton Blvd. Peoria, IL 61602 ATTORNEYS FOR EMPIRE ACE, SPRTNKMANN SONS James R. Carter Hafele, Thiemann & Assoc. lK>n First National Bank Bldg. Peoria, II. 61602 ATTORNEYS FOR BRAND INSUI.ATIONS Thomas J. Platt Kurnik, Cipolla, Stephenson and Bnrnslm 120 W. Eastman - Suite 302 Arlington Heights, TL 60004 31 > .) , W i I k e r son n vn I en , Adm./F.st it n of It -ml- Wi''-r e r>n ATTORNEYS FOR A & N INSUMTTON F.dwnrd .1. Matushek III Haske 11 & P*.rrin 200 W.' Adams - Suit* 2600 Chicago, Hi 60606 Gregory C. Knapp Saint & Ambrose 5th Floor - Suite A 200 W. Front St. Bloomington, II. 61701 ATTORNEYS FOR OWF(NS-CORN TNG Robert L. Martier Lundblad & Baker 401 S. T.aSalle St. - Suite 1000 Chicago, lb 60605 ATTORNEYS FOR F.AGTF.-PIClfF.R Bruce W. I.yon Villiams & Montgomery 20 N. Wacker Dr. - Suite 2100 Chicago, II. 60606 ATTORNEYS FOR FMNTROTE Francis A. Spina Tressler, Soderstrom, Maloney & Friess 2100 Manchester Road - Suite 930 Wheaton, II, 60187 ATTORNEYS FOR H.R. PORTER Gary D. Sharp Kohl, Secrest, Wardle, I.vnch, Clark a Ilampi on 30903 Northwestern Highway , P.0. Box 3040 Farmington Hills, MI 48333-0040 ATTORNEYS FOR ARMSTRONG, FIRREROARI), OAF, RFFNK. NATIONAI. GYPSUM, OWENS-fl.I.INOTS, PITTSBURGH CORNING David R. Sinn Christopher P. I.arson lfeyl, Royster, Voelker & Allen 600 Jefferson Bank Bldg. 124 S.W. Adams Peoria, II, 61602 ATTORNEYS FOR FIBREBOARIJ, OWENS-n.f.iNOtS, PirrsnuROM CORNING Rohert Riley Schiff, Hardin 6 Waite 7200 Sears Tower Chicago, II. 606a ?