Document pv4BQdMjRg9ZreGbzvvKZO6w
FILE NAME: Kaiser Gypsum (KG) DATE: 1996 KG046 DOC#: KG046 DOCUMENT DESCRIPTION: Legal - Response to Request for Production
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1 DILLINGHAM & MURPHY PATRICK J. HAGAN, ESQ. - BAR NO. 68264
2 ELIZABETH B. MORI, ESQ. - BAR NO. 178688 Fourteenth Floor
3 625 Market Street San Francisco, California 94105-3315
4 (415) 896-0400
5 Attorneys for Defendant KAISER GYPSUM COMPANY, INC.
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IN THE SUPERIOR COURT FOR THE STATE OF CALIFORNIA
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IN AND FOR THE COUNTY OF SAN FRANCISCO
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11 BART DOUGLAS STOCKMAN,
CASE NO.: 962298
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Plaintiff,
13 vs.
14 ABEX CORPORATION, et al.,
DEFENDANT KAISER GYPSUM COMPANY, INC.'S RESPONSE TO PLAINTIFF'S REQUEST FOR PRODUCTION OF DOCUMENTS
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Defendants.
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18 PROPOUNDING PARTY: PLAINTIFF, BART DOUGLAS STOCKMAN
19 RESPONDING PARTY: DEFENDANT, KAISER GYPSUM COMPANY, INC.
20 SET N O .:
ONE
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GENERAL OBJECTIONS
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Responding defendant KAISER GYPSUM COMPANY, INC.
23 (hereinafter referred to as "KAISER GYPSUM") hereby objects to
24 plaintiff's Request for Production of Documents, set number one,
25 served by hand on November 22, 1996, on the grounds that said
26 request is irrelevant, overly broad, compound, burdensome,
27 oppressive and harassing and it is not reasonably calculated to
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1 lead to the discovery of admissible evidence. Without waiving
2 these objections, KAISER GYPSUM responds as follows:
3 SESBQflSg m REQUEST n o . I:
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KAISER GYPSUM incorporates its general objections as stated
5 above and specifically objects to this request as vague and
6 ambiguous as well as overly broad in terms of time and products,
7 and as to the meaning of the term "appearance." KAISER GYPSUM
8 further objects to this request as overly broad in that it
9 requests information relating to products to which the plaintiff
10 was never exposed. Without waiving said objections, KAISER
11 GYPSUM responds that it has located the documents attached as
12 Exhibit A which appear responsive to plaintiff's request and
13 which depict both asbestos-containing and non-asbestos-containing
14 products.
15 RRSPgNRE- T_Q..REQUEST NO, 2 :
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KAISER GYPSUM incorporates its general objections as stated
17 above and specifically objects to said request as vague and
18 ambiguous as well as overly broad in terms of time and products,
19 and as to the meaning of the term "appearance." KAISER GYPSUM
20 further objects to this request as irrelevant and not reasonably
21 calculated to lead to the discovery of -admissible evidence in
22 that it requests information regarding non-asbestos-containing
23 products. Without waiving said objections, KAISER GYPSUM
24 responds that it has located the documents attached hereto as
25 Exhibit B which appear responsive to plaintiff's request. In
26 addition, to the extent that any of the documents produced
27 pursuant to Request Number 1 may be responsive to said request,
28 KAISER GYPSUM refers plaintiff to those documents.
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1 KEfiBOMSg TQ,.REQUEST NO. 3:
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KAISER GYPSUM incorporates its general objections as stated
3 above and specifically objects to this request as vague and
4 ambiguous as well as overly broad and unintelligible in that
5 responding defendant cannot identify which documents, if any,
6 might be responsive to said request. KAISER GYPSUM further 7 objects that in the absence of an inquiry more precisely 8 formulated, KAISER GYPSUM cannot respond to this request. 9 Without waiving these objections, KAISER GYPSUM refers plaintiff 10 to those documents produced pursuant to Requests Number 1 and 2 11 to the extent that they may be responsive to this request.
12 R E S P O N S E ...T Q - R E Q U E S X - . N a . - ^ l
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See Response to Request No. 3.
14 15 Dated:
DILLINGHAM & MURPHY
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By:
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Attorneys for Defendant
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KAISER GYPSUM COMPANY, INC.
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