Document pprpmNK920Yv5d0nqn7XLKZVD
FILE NAME: Goodyear (GY)
DATE: 0000 DOC#: GY084
DOCUMENT DESCRIPTION: Answers to Plaintiff's First Set of Request for Admission to Defendant, Goodyear
IN THE COURT OF COMMON PLEAS OF SUMMIT COUNTY, OHIO
WILLIAM F. CLARK, et al.
Plaintiffs
-vs -
OWENS-CORNING FIBERGLAS C O R P ., et a l .
Defendants
CASE NO. A C V 94 04 1107
JUDGE WILLIAM H. VICTOR
) ANSWERS TCy ) PLAINTIFF'S FIRST SETOF ) REQUEST FOR ADMISSIONS TO ) DEFENDANT, GOODYEAR TIRE & ) RUBBER COMPANY J
Plaintiffs, WILLIAM F. CLARK, et a l ., request Defendant, Goodyear Tire & Rubber Company, within thirty-two (32) days after service of this request, to make the following admissions for the purpose of this action only and subject to all pertinent objections to admissibility which may be interposed at trial. Each of the following Requests for Admissions refers to the Goodyear Tire & Rubber Company's Akron facilities only, and, when applicable refers to asbestos, talc/soapstone, or asbestos-containing products used in its Akron facilities.
Admit that each of the following statements is true: 1. That all persons that work in a rubber factory are exposed
1
58. That O ien Lee was never provided a respirator while employed at Goodyear Tire & Rubber Company. Response: For want of knowledge, denied. Goodyear has no present means of determining the truth or falsity.
59. That John Nardella was never provided a respirator while employed at Goodyear Tire & Rubber Company. Response: Denied for want of knowledge. Goodyear has not inquired of this Plaintiff, since it is now prohibited from so doing.
60. That Goodyear Tire & Rubber Company was aware of the dangers to humans of exposure to airborne asbestos fibers prior t o : a. 1983; Response: Admitted.
b. 1982; Response: Admitted.
25
1 op- .
l^ U J . f
Response Admitted.
d. 1980; Response Admitted.
e . 1979; Response : Admitted.
f . 1978 ;
ly o q n n r ic o
Admitted.
g- 1977; Response : Admitted.
h. 1976; Response : Admitted.
26
i. 1975; Response : Admitted.
j. Response : Admitted.
1974;
k. Response : Admitted.
1973;
1. 1972; Response : Denied.
m. 1971; Response : Denied.
n. Response : Denied.
1970;
27
O. 1969; Response Denied.
P- 1968 ; Response
q- 1967 ; Response: Denied.
r . 1966 ; Response: Denied.
s . 1965 ; Response: Denied.
t . 1964 ; Response Denied.
28
U. 1963 ; Response : Denied.
v. Response : Denied.
1962 ;
w . 1961; Response : Denied.
x. Response : Denied.
1960;
y. Response : Denied.
1959;
z. Response : Denied.
1958;
29
aa. 1957; Response: Denied.
bb. 1956; Response: Denied.
cc . 1955; Response: Denied.
dd. 1954 ; Response: Denied.
ee . 1953; Response: Ui>diX^C^Un O
f f . 1952; Response: Denied.
30
g g . 1951; Response : Denied.
hh. 1950 ; Response : Denied.
1 1 . 194 9; Response : Denied.
3D 194 8 ;
Response : Denied.
kk. 194 7; Response : Denied.
1 1 . 194 6 ;
Response : Denied.
31
mm. 1945; Response: Denied.
n n . 1944; Response : Denied.
oo. 1943; Response : Denied.
61. That Goodyear Tire & Rubber Company was aware that some of its employees were exposed to asbestos fibers in the work environment at its Akron facilities prior to: a. 1983 ; Response: Admitted.
b. Response : Admitted.
1982;
c. Response :
Admitted.
1981;
32
d. 1980; Response : Admitted.
e. Response : Admitted.
1979;
f. Response : Admitted.
1978;
g. Response : Admitted.
1977;
h. Response : Admitted.
1976;
i. Response : Admitted.
1975;
33
j. 1974 ; Response: Admitted.
k. Response: Admitted.
1973;
1. 1972 ; Response: Admitted.
m. Response: Admitted.
1971;
n. Response: Admitted.
1970;
o. Response: Admitted.
1969 ;
p. 1968 ; Response: Admitted.
q. Response: Admitted.
r . 1966; Response: Admitted -
s. 1965; Response: Admitted.
1967;
t. Response: Admitted.
1964;
u. Response: Admitted.
1963;
v. 1962; Response: Admitted.
w. Response: Admitted.
1961;
X . 1960; Response; Admitted.
y- 1959 ; Response: Admitted.
z . 1958 ; Response: Admitted.
a a . 1957; Response: Admitted.
3 6
b b . 195 6; Response : Admitted.
c c . 1955; Response : Admitted.
dd. 1954; Response : Admitted.
e e . 1 Qc;n .
Response : Admitted.
f f . 1952; Response : Admitted.
gg- 1951; Response : Admitted.
37
hh. 195 0; Response: Admitted.
ii. 194 9; Response: Admitted.
jj. 1948; Response: Admitted.
kk. 1947; Response: Admitted.
il. 1946; Response: Admitted.
nini. 1945;
Response: Admitted.
38
144. T h a t asbestos is recognized by the U n i t e d Stau
Department of Environmental Production A g e n c y (EPA) as a
primary carcinogen to humans.
Response
Objection.
Public information is as readily available to
Plaintiffs as to this Defendant.
Respectfully submitted,
THOMAS W. BEVAN # 0054063 JAMES C. WATSON # 0020139 V E R N E R R. RUDDER # 0003442 Attorneys for Plaintiffs 10360 Northfield Road Northfield, Ohio 44067 (216) 467-8571 (216) 650-0088
106