Document qX0DE0Y90pqz6ay5JG5rmVQ5
*
PLAINTIFFS
BRAYTON & ASSOC
I EXH^IT
3 3 3 3r
1 WILLIAM. G. HOBACK, ESQ.
I
I2
ERICKSEN, ARBUTHNOT, BROWN, 1304 Willow Street
GTR-18
FEB n 1991
3
Martinez, California 94553
(415) 229-1702
KILDUFF & DAY, Ino-. --
-J
4 Attorneys for Defendant(s),
THE GOODYEAR TIRE & RUBBER COMPANY 5
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7
8 SUPERIOR COURT OF CALIFORNIA, COUNTY OF SOLANO
9
10 IN RE:
11
SOLANO COUNTY COMPLEX
No. 2830
12
ASBESTOS LITIGATION
THE GOODYEAR TIRE & RUBBER COMPANY's ANSWERS TO PLAIN
13
TIFFS ' STANDARD INTERRO GATORIES TO DEFENDANTS,
14 GENERAL ORDER NO. 30.00
J
15 COMES NOW defendant, THE GOODYEAR TIRE & RUBBER COMPANY
16 (hereinafter GOODYEAR") , and pursuant to the provisions
17 of General Order No. 30.00, and under the. applicable California
18 Code of Civil Procedure section? and ;i.n compliance with the
19 California Rules of Court and Local Rules of Court, answers the
20 interrogatories propounded by plaintiffs, as follows:
21 PRELIMINARY STATEMENT
22 The answers to these interrogatories are based upon a
23 search of corporate files and records regularly maintained in
24 the ordinary course of business of THE GOODYEAR TIRE & RUBBER
25 COMPANY and information obtained during interviews with various
26 employees of the company over a series of many years. However,
27 THE GOODYEAR TIRE & RUBBER COMPANY's involvement in these
28 matters is based on the fact that, it distributed asbestos-
1 containing products manufactured by GOODYEAR AEROSPACE CORPORA
2 TION. The assets and interests of GOODYEAR AEROSPACE CORPORA
3
TION were sold to LORAL MANUFACTURING CORPORATION in 1987, and
4
all records related to GOODYEAR AEROSPACE CORPORATION were trans
5
ferred to LORAL at the time of the sale. Thus, THE GOODYEAR
6 TIRE & RUBBER COMPANY must rely principally on the memories of
7
its employees to respond to interrogatories concerning details
8 of the production and sale of GOODYEAR AEROSPACE CORPORATION
9
asbestos-containing products.
10
No single person associated with THE GOODYEAR TIRE &
11
RUBBER COMPANY has the knowledge or the documents necessary to
12
supply every answer required or requested by these interroga
13
tories, and many of the individuals who may have had personal
14
knowledge of the matters addressed by these interrogatories are
15
presently unavailable to this answering defendant.
16
THE GOODYEAR TIRE & RUBBER COMPANY has little informa
17
tion available to identify customers to whom GOODYEAR AEROSPACE
18
asbestos-containing products were sold. THE GOODYEAR TIRE &
19
RUBBER COMPANY ceased marketing said products in 1978 and, as
20
indicated above, any records reflecting such sales are no longer
21
in its possession. With the exception of the answers as else
22
where herein provided, it is impossible to further identify
23
quantity and type of product sold and delivered; to further
24
identify and produce documents related to such sales or
25
deliveries; or to state dates on which such products were sold
26
or delivered.
27
Additionally, and in the context of either "CASE
28
SPECIFIC" or "WORK SITE" interrogatory answers as defined by
-2-
1 this ^General Order and/or other general orders of this, or
2 other, courts, further answers as may be contemplated or
3
requested thereunder are impossible. All available and "geo
4
graphically defined" information pertaining to sales, work
5
sites, warehouses, or otherwise as may be contemplated or
6 requested thereunder is provided herein; same are expressly
7
provided in response to any such "CASE SPECIFIC" or "WORK SITE"
8 interrogatories that may be deemed served in any specific
9
litigation or specific file matter.
10
Should further information be located regarding the
11
subject matter of these interrogatories, THE GOODYEAR TIRE &
12
RUBBER COMPANY will supplement its answers as such information
13
becomes available.
14
Defendant, THE GOODYEAR TIRE & RUBBER COMPANY, has never
15
mined asbestos nor manufactured, distributed or sold thermal
16
insulation containing asbestos.
17
SPECIFIC ANSWERS-
18
1. (a) Hayes A. Jenkins
19
(b) THE GOODYEAR TIRE & RUBBER COMPANY, 1144 E.
20
Market St., Akron, Ohio 44316.
21
(c) Objection. The scope of inquiry of this
22
subpart is irrelevant to the subject matter of this litigation
23
and is not likley to lead to the discovery of admissible
24
evidence.
25
(d) Objection. The scope of inquiry of this
26
subpart is irrelevant to the subject matter of this litigation
27
and is not likley to lead to the discovery of admissible
28
evidence.
3-
1 2 ... (a) THE GOODYEAR TIRE & RUBBER COMPANY
2 (b) Ohio
-
3
(c) 1898
4
(d) 1144 East Market Street, Akron, Ohio 44316
5
(e) Not applicable.
6 3. No.
7
4. Yes, since approximately 1920.
8 5. No.
9
6. No.
10
7. No.
11
8. Yes.
12
(a) Industrial brakes, in which the brake
13
linings contained asbestos.
14
(b) 1948.
15
(C) 1972.
16
(d) Industrial brake linings were made with asbes
17
tos type Chrysotile 7D. Percent of asbestos was 10% to
18
30% depending upon the lining. This was combined with
19
phenol-formaldehyde resin and sometimes copper and dust
20
to produce a solid molded and thermo-setting phenolite
21
compound which contained no free asbestos. There were a
22
number of different formulae at any one time and over
23
the years and specifications and formula changed from
24
time to time.
25
(e) Industrial brakes were used in off-the-road
26
hauler trucks, loaders, shuttle cars, foundry transfer
27
cars, lifters, mining cars and industrial equipment,
28
etc., i.e., non-over-the-road vehicles and equipment.
4
1 (f) The brake linings were marked with and ink
2 stamped part numbers.
3
(g) See Subpart (e) above.
4
(h) THE GOODYEAR TIRE & RUBBER COMPANY until
5
around 1970 and its wholly-owned subsidiary, GOODYEAR 6
AEROSPACE CORPORATION, after that.
7
(i) Lake Asbestos of Quebec, Ltd. 8 P.O. Box 88
Black Lake, Quebec
9
Asbestos Corporation, Ltd.
10 1940 Sun Life Bldg.
1155 Metcalfe Street .
11 Montreal, Quebec H5B 2x6 12 Johns-Manville Candada, Inc.
295 The West Mall
13 Etobicoke, Ontario M96 427 14 Bell Asbestos Mines, Inc.
P.O. Box 99
15 Thetford Mines, Quebec C6G 5S4 16 (j) None.
17 18 (a) Asbestos gasket material, sometimes called 19 asbestos packing material. 20 (b) About 1914.
21 (c) Discontinued in 1969 by THE GOODYEAR TIRE & 22 RUBBER COMPANY when production was transferred to 23 Goodyear Canada, Inc. Discontinued by the latter in 24 1973.
25 (d) Approximately 80% chrysotile asbestos and 20% 26 rubber. There were various minor changes in specifica 27 tions and formulation over the years. 28 (e) The product was used to cut gaskets from it.
5-
1 (f) The product was marked Goodyearite or Durabla.
2 (g) See Subpart (e) above.
3
(h) Goodyear.
4
(i) See Subpart (i) above.
5
(j) None.
6
7
(a) Industrial furnace door hose with an outer ply 8
of woven fabric of asbestos and cotton not manufactured
9
by GOODYEAR and asbestos content not known was imbedded
10
in the outer layer of rubber. Fabric content accounted
11
for approximately 10% of total product weight.
12
Industrial steam hose, including pile driver hose with
13
braided 9 cut 2-ply yarn of asbestos and cotton. The
14
ply accounted for approximately 3.78% by weight.
15
(b) GOODYEAR industrial hose.
16
(c) Furnace door hose from about 1959 until 1976
17
steam hose from about 1931 until 1970.
18
(d) See Subpart (a) above.'
19
(e) See Subpart (a) above.
20
(f) GOODYEAR at its Plant 2 in Akron, Ohio, and a
21
former plant in North Chicago, Illinois.
22
(g) See Subpart (a) above.
23
(h) GOODYEAR.
24
(i) None.
25
(j) None.
26
27
Conveyor belt with asbestos burn shield. The material
28
was manufactured by others and we are unable to determine
-6-
1 asbestos content. The burn shield accounted for approximately
2 5% of the product's weight.
3
(a) GOODYEAR conveyor belt.
4
(b) Before 1962.
5
(c) 1962.
6 (d) See Subpart (a) above.
7
(e) See Subpart (a) above. 8
(f) None.
9
(g) Conveying hot material.
10 (h) GOODYEAR at its Plant 2 in Akron, Ohio.
11
(i) None.
12
(j) Not applicable.
13
14
(a) Goodyear adhesive.
15
(b) 1970.
16
(c) 1981.
17
(d) A styrene butadiene rubber resin mastic con-
18
taining 30% petroleum distillate and 1.3% asbestos.
19
(e) The product was a viscous material placed in
20
caulk tubes and used as an adhesive to bond material
21
together, for instance, in furniture repair, paneling,
22
etc.
23
(f) Goodyear.
24
(g) See Subpart (e) above.
25
(h) Goodyear at its former Ashland, Ohio plant.
26
(i) Johns-Manville.
27
(j) None.
28
9. No.
-7-
1 (a) through (f) Not applicable.
2 10. No.
3
(a) through (j) Not applicable.
4
11. No.
5
(a) through (f) Not applicable.
6
12.
Yes
m
/
(a) Motor Wheel Corporation, with principal
8 at 1600 Larch Street, and subsequently 4000 Collins
9
Road, Lansing, Michigan.
10
11
(b) Unknown.
-
12 (c) Michigan.
13
(d) 1/17/64.
14
(e) 12/26/86.
15
(f) Plants were in Ashburn, Georgia, Rolling
16
Prarie, Indiana, Newton, Kansas, Pine Grove, Pennsyl
17
vania, Chicago Ridge, Illinois, and La Grange, Indiana.
18
(g) The company produced electric brakes for
19
mobile homes and trailers with asbestos brake linings.
20
Also heaters which are sometimes referred to as furnaces
21
for mobile homes in which 3 or 4 pre-cut asbestos
22
gaskets were installed, usually in heat chamber
23
connections to the manifold.
24
25
(a) Goodyear Aerospace Corporation.
26
(b) 1939.
27
(c) Delaware.
28
(d) 1934.
-8-
1 " ' ... (e) 1987.
2 (f) Akron, Ohio.
3
(g) Industrial brakes as described in answers to
4
prior interrogatories and aircraft brakes.
5
13. No.
6 14. No as to raw asbestos fiber. As to asbestos-
7
containing products, GOODYEAR lacks records or sufficient
8 information to enable an answer; however, belief is the response
9
is no.
10 (a) through (c) Not applicable.
11
15. Yes.
12 (a) The GOODYEAR TIRE & RUBBER COMPANY Plant 2 in
13
Akron, Ohio, from 1913 to 1976, a former plant in North
14
Chicago, Illinois from around 1959 to 1976 and a former
15
plant in Ashland, Ohio from 1970 to 1981.
16
16. See Answer to Interrogatory No. 8 above.
17
17. No.
18
(a) through (d) Not applicable.
19
18. No.
20
19. Yes.
21 (a) Asbestos packing, also referred to as asbes
22 tos gasket material;
23
(b) Federal;
24
(c) September 23 , 1919;
25
(d) 1919 through 1979;
26
(e) 1939, 1959;
'
27
(f) THE GOODYEAR TIRE & RUBBER COMPANY;
28
(g) Secretary of THE GOODYEAR TIRE & RUBBER CO.
-9
1 " ' -.20. No.
2 (a) through (g) Not applicable.
3
21. This answering defendant lacks sufficient
4
information to enable it to answer the inquiry made in this
5
interrogatory; however, to the best information and belief by
6 this answering defendant, the response is "No".
7
22. No.
8 (a) through (c) Not applicable.
9
23.
Yes, as to advertisements published in trade
10 journals. No, as to other such documents. Such documents would
11 have been disposed of routinely in such departments where they
12 were created under GOODYEAR'S record retention schedule.
13
24. Yes.
14
Such advertisements as still exist are produced.
15
See EXHIBIT "A" attached hereto.
16
25.
(a) THE GOODYEAR TIRE & RUBBER COMPANY
17 Corporate Executive Offices
1144 E. Market Street
18 Akron, Ohio 44316
19 (b) James Boyazis, Vice President and Secretary,
20 whose address is the same as listed in Subpart (a) of
21 this interrogatory.
22 26. Not applicable.
23 27. Not applicable.
i ii
i
24 28. Industrial brakes and brake linings were packaged
i
25 in cardboard boxes of appropriate size and dimensions.
26 Asbestos gasket material was packaged in paper for
27 shipment, in flat sheets 1/64 to 1/4 inch thick and 2-foot
28 square and placed in cardboard boxes.
-10
1 ' -.Hose was shipped in various lengths and dimensions
2 wrapped in burlap or cardboard.
3
Conveyor belt in varying lengths and widths was wrapped
4
in cardboard or burlap for shipment.
5
Adhesive was poured into 55-gallon drums and shipped to
6 a distributor which repackaged the product in caulk tubes.
7
29. All were marked manufactured by THE GOODYEAR TIRE 8
& RUBBER COMPANY, had the GOODYEAR winged foot logo and 9
identified the contents. The printing and such were black and 10
logos were sometimes blue and white. Gasket material manufac 11
tured for the Durabla Manufacturing Company identified that 12
company instead, and is believed to have had the Durabla mark.
13
30. No.
14
(a) through (c) Not applicable.
15
31. Not applicable.
16
32. No.
17
33. No.
18
(a) through (e) Not applicable.
19
34. Yes, as the responsible federal agencies have
20
published regulations on asbestos in the Federal Register over 21
the years, GOODYEAR has transmitted those regulations to its 22
nationwide operations directing that they be implemented and
23
followed.
24
(a) Possibly some of such transmittals exist in
25
some files somewhere. GOODYEAR has made no attempt to
26
i save them because as each federal regulation on the
27
subject issues it supercedes prior ones and GOODYEAR
28
personnel now rely on current regulations.
-11-
1 (b) Federal regulations relating to asbestos
2 which are as equally available to plaintiff as to
3
GOODYEAR are not in the custody of anyone but are freely
4
distributed to operating personnel throughout the
5 company nationwide.
6 35. Jay Wellman, M.D., Medical Director for THE GOOD
7
YEAR TIRE & RUBBER COMPANY;
8 J. L. Holtshouser, Manager of Industrial Hygiene
9
for THE GOODYEAR TIRE & RUBBER COMPANY.
10
36. NO.
11
37. (a) No.
12 (b) No.
13
(c) No.
14
(d) No.
15
(e) No.
16
(f) No.
17
(g) No.
18
(h) No.
19
(i) No.
20
(j) Yes.
21 00 No.
22 (1) No.
23
(m) No.
24
(i) Not applicable.
25
38.
(a) 1954 through 1988.
26
(b) All general publications and those peculiar
27
to subcommittees to which GOODYEAR representatives
28
belonged which issued over the period.
-12-
1 (c) Ergonomics subcommittee and Rubber & Plastic
2 Subcommittee.
3
39. No.
4
40. Yes.
5
(a) Journal of Occupational Medicine.
6 (b) 1947.
7
(C) J. L. Holtshouser, THE GOODYEAR TIRE & RUBBER
8 COMPANY, Corporate Headquarters, Akron, Ohio.
9
41. No.
10
42. No.
11
43. Yes.
12
(a) Plant 2 Akron, Ohio around 1970. Ashland, Ohic
13
plant around 1970 to 1981.
14
(b) See Subpart (a) above.
15
(c) Corporate Industrial Hygiene Department.
16
(d) Yes, in part
17
(e) Corporate Industrial Hygiene Department.
18
44. No.
19
(a) through (e) Not applicable.
20
45. No.
-
21
(a) through (e) Not applicable.
22
47. No.
23
(a) through (d) Not applicable.
24
48. No.
25
(a) through (d) Not applicable.
26
49. No.
27
(a) through (c) Not applicable.
28
50. One record suggests that such a claim was made
-13-
1 1981.'-However, the first claim that GOODYEAR can verify with
2 its records was made on 5/24/85.
3
51. Objection. This interrogatory is overly broad,
4
lacking in particularity, resonse would be unduly burdensome,
5 the information sought is immaterial in view of admission
6 asbestos-containing products were produced, is not relevant to
7
any other issue relative to this defendant and not calculated to
8 lead to evidence which is either probative or admissible at time
9
of trial.
10
52. Objection. This interrogatory is overly broad,
11
lacking in particularity, resonse would be unduly burdensome,
12
the information sought is immaterial in view of admission
13
asbestos-containing products were produced, is not relevant to
14
any other issue relative to this defendant and not calculated to
15
lead to evidence which is either probative or admissible at time
16
of trial.
17
53. Yes.
18
(a) - (c) GOODYEAR entered into contracts with
19
various insurers to cover both this company and all its
20
subsidiaries effective the dates shown below.
21
Hartford Accident & Indemnity Co.
7/1/40-1/1/49
22
Liberty Mutual Insurance Co.
1/1/49-1/1/53
23
Continental Casualty Co.
1/1/53-1/1/61
24
The Aetna Casualty & Surety Co.
1/1/61-1/1/71
25
The Travelers Indemnity Co.
1/1/71-1/1/77
26
The aforelisted insurers provided general liability
27
coverage with limits of $300,000 per person, $1,000,000
28
per occurrence for bodily injury. Since 1/1/77,
-14-
1 ` - -.GOODYEAR has been self-insured for primary limits.
2 54. No.
3
(a) through (g) Not applicable.
4
55. No.
5
(a) through (g) Not applicable.
6 57. No.
7
(a) through (f) Not applicable.
8 DATED: January 29, 1991
9
ERICKSEN, ARBUTHNOT, BROWN, KILDUFF & DAY, Inc.
10
Bv:
11 WILLIAM G. HOBACK
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
-15-
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W J. Ruscoe Company, Dept. OR P. O. Box 2746 Akron, Ohio 44301 Enclosed is my check tor S3.49. Please send me a Goodyear adnesives 6-pack. (Otixohm juiy is. isaai
NAME___________________________________________________________
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STREET ________________________________________________________
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1
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Itjust might make the nail obsolete.
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GOODYEAR
CHEMICALS
Gy-chw- Pi Ci;S* X -
': Ziqe 3Aw 0:3
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Goodyear Plio-Nail puts it all together.
Neus Goodsear Plio-Nail1 construction adhcMse ha> hich strength and excellent aging propemes. Specialls designed tor bonding ioisIs. flooring and siding Meets HI D Specihcanon AFG-UI As ailable in quarts
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Aparcaenc Business March 1977
4
Plio-nail, by Goodyear.
Itjust might make the nail obsolete.
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Use Plio-N'ail construction adhesive for TiG flooring, house siding, stair treads; risers, blown shingling and roofing, drvwall. metal, tile...even concrete and cement block.
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Both types meet tough building codes and HUD requirements.
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GOOD-YEAR
CHEMICALS
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New Goodsear Plio-Nail 'panel adhesive develops sufficient strength to hold a 4 \ 8 panel firmly in place--even without nails.
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QQD/YEAR
*
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New Goodyear Pho-N.ur* panel adhesive develups sufficient strength 10 hold a 4 s 8 panel rirmly in place-even without nails. Bonds wall panels, drywall. hardboard. corfcboard or team insulauon to masonry, studs, subrioor. drywull or concrete. Goes on in one step. Shims automatically. Eliminates nail pops. Available m stores every where. Slick with it.
Pllo-Nail
vs.
The Nail Goodyear Plio-Nail'" construction cahe3 ve 'S designed lor tough sub-fioormg era cst vork Pho-Noil1 ponelodhesiveistorcrywciiond ocr.eung installations.
Piio-Naii bonds tight to eiimma'e some ol the hecdacnes caused By nails Witn Pvo-Ncii mere s no worry aoout nails ocooirg sauecumg ,cin;sorlinisning work cnary'woil P' o-'oi s'est, easy and strong lor ootn ocneiing
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Itjust might make the nail obsolete.
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Now, a New Goodyear Asbestos Cord Steam hose
Another major devel opment by Goodyear which shows you why this line of Mechan ical Rubber Goods makes sales for you
So far a* existing materials permitted,Goodyear was malt ing a fine steam hose. But Goodyear designers wanted a carcass stock that had higher resistance to steam under pressure. They found it in asbestos*treated cord. Then they built a cover and tube
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36 -- Jin -- I found anor-ivar rnmt of. c-rTs-series of ads. Do vou want this
1 el '
putt Fit. ?KI*T. :i. ml
>1 THERN PnttFTl J`*l RN\L. mT : M [
mmmuarded
with ASBESTOS!
II
I
a new Goodyear Asbestos Cord Steam Hose with unusual resistance to heat and pressure
/^TF \ '1 hn-e ran become .< prcttv co?ll' item around
|>inei- hnu?c. L tiller the com* lunrd ctTccis of heat ami pres* urc the poorer srades 1:0 10 pieces fat. Ami until rccenlU.
ei r11 the best grades of cotton* f.ihric -team lioe li.nl a ton^h mail to tra\ el.
Non. hi the introduction f
a famous beat-reciting ruate* rial, Goodyear has made a team hue *ith ma> limes the service lifcofold-fa'hhmcd
V* 1 ill.- material. It 1..... <1 `I*, tin- r.rca*s i*f tl.e h..... ' ili- l"rm m| i"nE> ....... . 1 It. l.ini'lc braids .ire ulil>/- 1 * In- Ii :ivi' the lien Iim"C m**r- 1 1iut 1 limn 11nnnnt
rr>t%ttm-
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lint^hm ...- '!' ilw Ii.ir.l-
"t Hnrk 'mu rju put 11
GomUear \-Ucstn* t\. Meara Hose is fine mod. hose to sa\ e nionn for n ..u boiler cleanin'* ami on ml.
jobs about the plant. 1 t,.T. M--Coodvear Terhni. Man -- n ill ln>* it to '
tlchime, \ir. nr NX l|o*c-iou "lioiitd hair il
pecial Cooils car totijhm .. Uoe. Ju>t virile to 0*d*. \kroo.0..nrLnn \nM*le.i .mil a.k the O.T. '1. to 1 ill
it e its
ii o l i> t n <; o o n s
IIOSE
IMCKIM.
BOTH THE
LATEST
MD GREATEST IN RUBBER
TUm net#ei iucri in steam /ioh
--C9dvflr
Cord
NEW CARCASS
NEW TUBE
NEW COVER
H^OODYEAR is not only the Greatest Name in Rubber. Goodyear means the latest, tested,
proved successful developments in rubber.
Aware that industry is constantly changing, improv ing its processes, Goodyear engineering and Good year manufacturing keep fully abreast of the new requirements with new developments in Goodyear Mechanical Rubber Goods.
The result is that industries of all types '*here rub ber is used are confidently looking to Goodvear for the latest and best.
This creates a constantly growing demand for the scores of better mechanical rubber goods that bear the Goodyear name. The Goodyear franchise opens the door to this growing market. Investigate it. A line to Goodyear. Akron, Ohio, or Los Angeles. Calif., will bring full information.
Latest Goodyear developments in Mechanical Rubber
Goods
The Goodyear COMPxs* Endless Belt
The Goodyear TlIOR Beit Seamless
The Coodvear CO.Mt'Vss Cord Oil Well Belt -- DOUBLE
The Goodyear Emerald Cord Air H ose
The Goodvear Emerald Cord Hv-Pressure Water Hose
The Goodyear A$bc*ti>Cord Steam Hose
TUXE I Xi
CooJ*ear tovilet you to hvar John Philip Soum tnU In* lln.l ...Arthur Pryor tod hit Utn.J Reseller* Quartet and Ooo.Ucjr Concert Dance Orehetira . . .
every Weiinetilty anti iatunU*
nii:huover N. II.C. I(el .Vrw.,rt. WRAP mill \aM'iull*il Mat..... ..
p ir i; i v <:
Goodyear Durability;
The SCL-2 brake stands up to rugged operating conditions with
low cost per hour of operation.
Arte: perhaps the tr.ost extensive and difficult test program any brake has ever been subjected tv --Cark Equipment Company selected Goodyear
brakes tor their Moce! 175 front-end loader. And vha; a test program :t was. Only after
f.vo years of laboratory testing--stress coat, strain gage, cycle at 2300 psi. cycle-torque, thousands of stops on the dynamometer at disc temperatures up to 7'/`r F. and many mere--did Clark allow the brake to be held tested.
Field test locations and operations were picked as being the most adverse available. An addi
tional two years of operating m sand, grat e.. r'..k. chemicals and snow proved Goodyear s 5CL-J : oe the most consistent low cost per hour t: tcer. non. outlasting competition by a wide margin.
'h hen you face ciffauit brakmg requirements turnjo Goodvear. For complete tm'orrr.ation....... Jum Evans. Marketing Manager. Industrial Sr Goodyear Aerospace Corporation. P.O. E. . c_* Berea. Kentucky 40403. 1606) 9S6-93S1.
We know how to make things work.
kifjo.L. b
GOODpYEAR
INDUSTRIAL BRAKES
Gv-AEa-Pcorc-iC c3:a
LM T. < 10'.
S"g i Wring jrn --A* 30
N W Ayer A'JSSnl International
If it moves, Goodyear can stop it.
It's a fact. :hs: as a leader in disc brake
technology, Goodyear can supply brakes to meet any requirement. We otter the broadest
line of industrial disc brakes in the world today, with caliper sizes from 2'-4 lbs. to 300 lb. units. Any applications, large or small, truck or machine. Goodyear can do the job.
Disc brakes otter a variety of advantages over band and shoe brakes. They're compact and can perform in both static or dynamic applications with equal reliability. Their r.on-self-energizir.g characteristics assure smooth, controlled braking and superior control. The large exposed disc surface dissipates energy rapidly.
Goodyear develops and manufactures its own friction materials. Friction matenals
that exhibit minimum face at high temcera tures and energy rates.
Chances are. you're probable using a Goodyear friction lining now. Doesr. t .1 make good sense to come to tne source arc go Goodyear all the way.
A major plant expansion at our Berea c.an: puts us in a better-than-ever position tv : your needs. So if you make sometr.m; mvi moves, call on us to stop it. Comae: Sian Spencer. Product Manager. Industrie: Err.!-.-.?. Goodyear Aerospace Corporation. Glaucs a ... Berea. Kentucky 40403, 6061 9$6-i*'X
We know how to make things work.'
iNDuSTRiAL BRAKES
GOODYEAR
Aerossac*
GY-AE3-PIC3J5
Pije--a/c--Si*a
iPCusiry Week--June 29. Aug. 2W 1931
N WAyer.i'ioUSI International
GooJyear disc bi akes.
More efficient, more effective than band brakes under dynamic operation.
As 2 leader :n CjC crcl-ie technology. we supply akes for bow thrust engines. propeller shafts, anchor r.ciasses. -ainches, as -.veil as ether uses.
Disc brakes offer many advantages over band and .e brakes. They are smaller. They can perform m both itlc and dynamic situations. Their non-seli-er.ergi2ing arcctenstic assures smootn. controlled payout and per.or brake control. The large exposed disc surface :s:?atcs mere energy ar.d r.eat.
Goodyear-manutactured fr.ction materials exhibit mmum face at elevated temperatures and high energy :ut rates. As the lir.mgs wear, pistons continually vance, keeping displacement constant for eac.n plication. Quick change lining design allows minimum vr.time for replacement.
Our c srakes are available m a complete caiiper ce;.gns from 2;? ib. units to 300 lb. cesig' varying canper multiples, disc thicknesses, ccerc: pressures, etc., one arake caliper can ae used ocrcomplete product ime.
Goodyear has been supplying brakes :c: c.: trucks and earn moving equipment tor nearly::::. 'Ve can heip you. too For more information, c Evans, ibuoi 56-93Sl or write Marketing Mar Industrial Brakes. Goodvear Aerospace tMracrc: Box 427. Berea. Kentucky 40403.
We know how to make things work.
u OiT
GOODfYEAR
INDUSTRIAL BRAKES
Ov.Asq.p'C3::
Ae'cssace
rss:::a 3ra*es va^re //men Pevtsa 1 cage a/w to .`.orocai-^eo Apr.A^g N W Ayer iMSHnl International
Goodyear Bralceubility:
Disc brakes, more efficient, more effective than band brakes
under dynamic operation.
As a Aacer in disc prake technology. we supply
Our disc brakes are available m a complete _ne
brakes tor bow thrust engines. propeller shahs, anchor ; cadper cesigr.s from 2;.-:ib. to 300 ib. ur.es. By crying
.'.'..d.asses. winches. as wed as ocher uses.
i caliper multiples. disc thicknesses, operaung pressure:
Disc brakes oner many advantages over band ar.d I etc., one brake cauper can oe used across a cc.mciete
shoe brakes. They are smaller. They can periorm in both ! product one.
static and dynamic situations. Their non-seii-er.crgtzir.g i
For complete information, cal! Jam Evans,
characteristic assures smooth, controlled payout and
i Marketing Manager. industrial Brakes. Good-.ea:
superior brake control. The large exposed disc surface
Aerospace Corporation. Box 427. Berea. Ker.tuckv
cissipates more energy- and heat.
1 40403. two) 9E6-9331.
Goodyear manufactured friction materials exhibit
minimum face at elevated temperatures and high energy
r.put rates. As the linings w ear, pistons continually
advance, keeping displacement constant tor each application. Quick-change lining design allow-s minimum downtime for replacement.
We know how to make things work.
GOODpYEAR
INDUSTRIAL BRAKES
GY.AER-P00705 Jr. Pg. aw Bid. Bid: 8111 L.M: 7*10
fl.oontr--January 15. '580
N WAyer /*'JSilnl International
BrakeAbility
-----------------:--------------------------
For marine applications,
V
Goodyear disc brakes perform.
Dynamically, statically...ana economically.
:.vs. ..*
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l.'J.ca. -Law
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We know how to make things work.
GOODYEAR INDUSTRIAL BRAKES
Cjt-KAgI?a-?wqaC.o5 3l
B>a 81 ii
LM 7 1 n Maritime fleoone'--Sest t9?9 N W Ayer /i'iSHnl International
lough bt akes.
Goodyear outbrakes the competition in severe, big hauler tests.
her. Canada recommenced m-ere. new braking requirements. I"..: R.i cec.de J to compare competitive crake v.vtems :or use on tfieir large Mark-
Series trucks. The rest a.as a tough one: effectively
topping a vehicle weighing over .' jiJ.LUU pounds. rolling down a 10jj grace at speeds up to 2S rr.ph.
The winner -- GoodyearsSCL. 19-2 crake. Three calipers mounted on a -a/ cue in each front wheel provided
sufficient braking torque to decelerate the truck in stopping instances shorter than the proposed requirements, proving its superiority over ail other braking systems.
Each of the three calipers is designed to dev elop over 1.000.000 inch.- lbs. of torque at a hydraulic pressure of a.UOO psi. The Canadian tests used '; of design torque.
The lining material, specially developed and manufactured bv
Goodyear, providesconsister.:.;. crake torque at severe energ-.
with disc temperatures over - - F 'tou snouid mink accu: reqluc.n.
your brakes ita Gooovear :>.o make more kinus of indu*::... rr. than anvtxxiy eise
So fine out now .iCv_: in; . "r that's cesi tor you pv wr-i.ng . Goodyear Industr.ai Stakes. 0.. v -f Berea. Kentucky ooCOO. Or e --..
call' 6061 936-93 Si
AD t`094-900-77-.\'P-0027 To appear in:
Engineering 5, Mining Journal - Auzusc Page 4-clr bid. S' x 11 1/8
LM: 7' x 10 1/3
bi ake problems, talk some torque with us.
Goodyear has the brakes to help die you out from under the new safety standards requirements. Proven designs--with spnngapplied hydraulic release--to meet torque demands up to 440.000 lbs/ins. .And all of them meet OSHA's specifications for automatic parking and emergency brake features.
So, whether your problems are with shuttle-cars, shovels, trucks, loaders, whatever--in surface, sub-surface, or partialwater environments--when you need to soK e brake problems, it's ume to talk some torque with your Goodyear man.
He'll tell you all about our full line - f
economical off-the-shelf disc-brake desnmv
and our total capability to meet all your fur.::
brake requirements.
rf Call or write him today. Good\ ear I::
dustrial Brakes, Berea, KY40403. (606)
'
GOOD'fYEAR
INDUSTRIAL BRAKES
094 932 74-NP 0469V kV A vr & Son. Inc.
eg. d/w old 9 5/16a 11 S/16-Trj Ef>9>nftn9 & Mining Journal
Jun
Aw9ut
iaTHAM-LAIRD & KUDNEH INC.
NEW TORE
No/17-546 , Job PO-2636 17.910
Pag^B&Wg Vertical
Machine Design, December L9T1969
(Mechanical Drives Issue
F
Brakea
16-ton
forging
without aslip
Goodyear disc brakes hold 20-fool steel alloy ' slugs tight enough for rough cutttng. then control-----
------ intifi/in prnricaly J'nnnjh Int finishing rntc
Goodyear brakes are a sure thing. Goodyear Industrial Brakes, Dept. L-1B, Akron, Ohio 44316.
!
GOOD-YEAR
INDUSTRIAL BRAKES
iATHAM-LAIRD & KUDNER, INC.
NIW YOSX
. JobPO-2G03 17.390
Page'TUlW; Vertical
NO- Machine Design, December 181 1969 j / HriVA* T^tllA fs-' -
Stop a Saturn rocket in it s tracks
4:
What does it take to stop the world> largest__ v
tracked vehicle, plus a giant Saturn Vrocket, plus >
thprnrfrpt'twhaliiImini
1illlullll H"
Goodyear disc brakes. They have what it takes.
Goodyear Industrial Brakes, DepL L-1B, Akron,
Ohio 44316.
GOOD-YEAR
INDUSTRIAL BRAKES
No 17-535 -
Job PO-1566 -
TATHAM-LAIRD & KUDNER. T
HEW YOU
17.656 Page, B&W, 7 x 10 ins.
Product Engineering, September i, 1969 Machine Design. October 16.1S69
Power Transmission Design. November. iC")?
Two small Goodyear disc brakes hold
16-ton forgings-
without giving
an inch.
Adamson United Company mills 20-foot alloy
steel blanks into extruder screws--with the help
of four Goodyear disc brakes.
Two brakes lock the workpiece while the huge
forgings are rough-cut under tremendous pres
sure. Two additional brakes control rotation of
the workpiece for smooth finishing cuts.
Results? The compact size of the Goodyear
brakes simplified the design of the milling ma
chine headstock.
~: ^ -
-Thnir pncitiuaflrip praunntc cllpp^gn
rm.M
break tools and tum expensive forgings into scrap.
That's what Goodyear disc brakes are doing for Adamson United. What can they do for you?
Write Goodyear, Industrial Brakes, Dept. 1-20, Akron, Ohio 44316.
GOOD/YEAR
INDUSTRIAL BRAKES
No. ]7_S34 _Job?0-1565
TATHAM-LAIRD <5 ETON. . INC.
KTW YOU
17,555
Page. E&W, 7 x 10 ins.
Product Engineering, July 25. M-iO r Machine Design, August 21. 1059 Power Transmission Design. Sepiemcer.
Tap
yourfoot
and stop
60 tons.
Itusedtotakeabrake pedal three feet long to stop a Star Foundry transfer car.
Now it takes only two Goodyear disc brakes --and no more effort than stopping an auto mobile. Even when the transfer car is carrying 60 tons of brick or pipe.
Maintenance is less work, too. No disas sembly is needed to check the Goodyear brakes, -because they caO.baJnspected.at a glance. And servicing requires just a few
Goodyear has stopping power
1
4ll3r
IN RE: COMPLEX LITIGATION
STATE OF OHIO COUNTY OF SUMMIT
)
)
)
I, HAYES A. JENKINS, declare under penalty of perjury
under the laws of the State of California that I am the
Assistant Secretary of THE GOODYEAR TIRE & RUBBER COMPANY and I
verify the foregoing ANSWERS TO PLAINTIFFS' STANDARD
INTERROGATORIES TO DEFENDANTS, GENERAL ORDER NO. 30.00; that
the matters stated therein are not within my personal
knowledge; that the facts stated therein have been assembled Joy
authorized employees and counsel of THE GOODYEAR TIRE & RUBBER
COMPANY and I am informed that the facts stated therein are
true and correct.
I declare under penalty of perjury that the foregoing
is true and correct and that this verification was executed on
February /
1991, at Akron, Ohio.
Bv:
/
<
~
*
,-
/
' /-
HAYES' A. JENKINS
Assistant Secretary
/
/'
/i
1 PROOF OF SERVICE BY MAIL
2
3 I, the undersigned, hereby declare: 4 I am over the age of 18 years, employed in the County of 5 Contra Costa, and am not a party to the within action. My 6 business address is 1304 Willow Street, Martinez, CA 94553. 7 I am readily familiar with our business' practice for
8 collection and processing of documents for mailing with the
9 U.S. Postal Service, and declare that the below-named document 10 will be deposited with the U.S. Postal Service, postage fully 11 prepaid thereon, on the date set forth below, at Martinez, CA. 12 I served the following: THE GOODYEAR TIRE & RUBBER 13 COMPANY'S ANSWERS TO PLAINTIFFS' STANDARD INTERROGATORIES TO 14 DEFENDANTS, GENERAL ORDER NO. 30.00 by placing true and correct 15 copies thereof in an envelope, sealing, placing for collection 16 and mailing following ordinary business practices, and 17 addressed as follows: 18 SEE ATTACHED LIST 19 I declare, under penalty of perjury, and under the laws 20 of the State of California, that the foregoing is true and 21 correct. 22 Executed on February 12, r1991, at Martinez, California. 23
24 25 LINDA KING
26
27
28
ABEX CORPORATION . Sullivan Roche 4 JOhnso^ ` 333 Busn Street, 18th Floor San Francisco, CA 94104-3559
THE BEN01X CORPORATION Gordon & Rees Embarcadero Center West 275 Battery Street, 20th Floor San Francisco, CA 94111 Attn: Michael lueey, Esq.
borg-warner corporation McGlynn, Mcl.org & McDowell 188 Embarcadero Center Suite 200 San Francisco, CA 94105
THE CARLISLE CORPORATION Archer l McComas 2900 Newall Hill Plaza Suite 300 9.0. Sox 5035 Walnut Creek, CA 94596
FORD MOTOR COMPANY Lawrence A. Margoles, Esq. Barfield, Barfield, Dryden
& Ruarte One California Street Suite 3125 San Francisco, CA 94111
GENERAL MOTORS CORPORATION John Krebs, Esq. Parichan, Renberg, Crossman
& Harvey Corporation 2350 West Shaw, Suite 130 Fresno, CA 95115
INTERNATIONAL HARVESTER COMPANY
Harrington, Foa, Oubrow, Canter 4 Keene
611 U. Sixth Street 9th Floor Los Angeles, CA 90017
KAISER ALUMINUM Daven G. Lowhurst, Esq. Thelen, Marrin, Johnson 4
Bridges One Kaiser Plaza Suite 1950 Oakland, CA 94612
LEAR-SIEGLER, INC. HOPEMAN BROTHERS Robert M. Thompson Esq. Thompson 4 Michel 3500 American River Drive Suite 101 Sacramento, CA 95825
aOL-.liu r-r.o
BABCOCK i -I.CCa COMPANY Martin .. Everson, Esq. Anderson, Galloway 4 Lucchese 1676 N. California Slvd. Suite 500 Walnut Creek, CA 94596
UN I ROYAL, INC. Leonard Cook, Esq. McNamara, Houston, Dodge,
McClure 4 Ney P.0. Box 5288 Walnut Creek, CA 94596-1285
UN I ROYAL, INC. Nancy E. Hudgins Law Offices of Nancy E. Hudgins 605 Market Steet, Suite 700 San Francisco, CA 94105
COMBUSTION ENGINEERING Rupert H. Ricksen, Esq. Knox, Ricksen, Snook,
Anthony 4 Robbins 1999 Harrison St., Ste. Oakland, CA 94612
1700
WESTERN MacARTHUR COMPANY Eugene Brown, Esq. Hardin, Cook, Loper,
Engel 4 Bergez One Kaiser Plaza, Suite 2300 Oakland, CA 94612
GARLOCK, INC. Glaspy & Glaspy 201 N. Civic Center Drive Suite 245 Walnut Creek, CA 94596
NICOLET INDUSTRIES, INC. Anthony Griffin, Esq. St. Clair, 2appetini,
McFetridge & Griffin One Montgomery Street Suite 1400 San Francisco, CA 94101
RAYMARK INDUSTRIES/CELOTEX/ CAREY-CANADA Bjork, Fleer,Lawrence & Harris 192 9th Street Oakland, CA 94607 Attn: Robert Bjork, Jr., Esq.
Berry 4 Berry A Professional Law Corporation 505 Fourteenth Street 12th Floor Oakland, CA 94612
HAMILTON MATERIALS, INC./ HAMILTON DISTRIBUTING Walsworth, Franklin 4 Bevins 111 Sutter Street 19th Floor San Francisco, CA 94104 Attn: Helen H. Kong, Esq.
-. R. CRACE i CCH*awi , . C . Claop, Maroney, Bellgamoa.
Davis & Vucinich -400 Bohannon Drive, Suite 'CC Menlo Parx, CA 94025 Attn: Eve T. Contente, Esc.
KAISER CEMENT CORPORATION/ KAISER GYPSUM, INC. Michael Hoggard, Esq. Kincaid, Gianunzio, Caudle 4
Hubert 200 Webster Street, Suite ETC P.0. Box 1828 Oakland, CA 94604
OWcNS-CORNING John M. Ingle, Esq. Popelka, Allard, McCowan,
Jones 4 Howard 700 Ygnacio Valley Road Suite 330 Walnut Creek, CA 94596
OWENS-CORNING Susan Bennett, Esq. Wright, Robinson, McCammon,
Osthimer 4 Tatuti 44 Montgomery Street 18th Floor San Francisco, CA 94104
KELLY MOORE PAINT COMPANY Kathleen S. Farley, Esq. Burnhill, Morehouse, Burford,
Schofield 4 Blunden 1220 Oakland Blvd.,- Suite 200 P.0. 8ox 5168 Walnut Creek, CA 94596
UNITED STATES MINERAL PROOUCTS Maureen Brooks Richard L. Reynolds, Jr., Esq. Bennett, Sanuelsen,
Reynolds 4 Allard 1951 Webster Street, Suite 200 Oakland, CA 94612-3466
THE SYNKOLOID COMPANY Branson, Fitzgerald 4 Howard P.O. Box 2189 643 Bair Island Road Suite 400 P.O. Box 2189 Redwood City, CA 94064
EXCELSIOR Stunbos 4 Mason 800 Ninth Street, Suite 200 P.O. Box 868 Sacramento, CA. 95804
KELLY-MOORE PAINT COMPANY,INC. Bullen, McKone, McKinley, Gay
Keitges 4 Pach Christopher Center 1000 "G" Street, 5th Floor Sacramento, CA 95814-0884
HGME\NF\SOLANO PLG1 04/11/90-1
1.
.3HN CRANE, INC. McOonala, Cullom Burland 635 Sacramento Street--. Suite 720 San Francisco, CA 94111
PARKER HANNIFIN Wilkes Morgan, Esq. Bronson, Bronson ft McKinnon 100 B Street, Suite 400 Santa Rosa, CA 95401
THE Ft INTKOTE COMPANY landets, Ripley & Diamond 450 Pacific Avenue San Francisco, CA 94133
H.K. PORTER Bogle l Gates 1400 KOIN Center 222 S.u. Columbia Street Portland, OR 97201 Arrn; Richard Hayden
THIOKOL CORPORATION Gilles Nicora 1900 Embarcadero, Ste. 300 Oakland, CA 94606 Attn: Timothy J. Minor, Esq.
PLANT INSULATION Tarkington, O'Connor
O'Neill Speer Street Tower One Market Plaza, 41st Floor San Francisco, CA 94105
CHRYSLER CORPORATION Crosby, Heafy, Roach Hay 1999 Harrison Street Oakland, CA 94612 Attn: John Oittoe, Esq.
BER I-
Brown,
Martinez, CA 94553
SACOMO MANUFACTURING COMPANY Wilkes Morgan, Esq. Bronson, Bronson t McKinnon 100 B Street, Suite 400 Santa Rosa, CA 95401
MANV1LLE PERSONAL INJURY SETTLEMENT TRUST
Ropers, Majeski, Kohn, Bentley, Wagner Kane
1001 Marshall Street Redwood City, CA 94063 Attn: Daniel E. Alberti, Esq
HOPEHAN BROTHERS Thompson Heller 3600 American River Drive Suite ISO Sacramento, CA 95864
HOME\NF\SOLANO PLG1 04/11/90-1
= 01ANC rROC r
THORPE INSULATION Law Offices of Richara Hildebrant 757 West 9th Street San Pedro, CA 90731 Attn: Richard Hildebrant, Esq.
EAGLE-PI CHER INDUSTRIES JACKSON, WALLACE HAYDEN 33 New Montgomery Street 18th Floor San Francisco, CA 94105 Attn: Gabriel A. Jackson, Esq.
RILEY STOKER CORPORATION Reba W. Thomas, Esq. Latham Watkins 633 West Fifth Street Suite 4000 Los Angeles, CA 90071
E.J. BARTELLS Firtan, White Psetzold 150 Spear Street, Suite 1725 San Francisco, CA 94105
Law Offices of John Ladd 1683 Folsom Street San Francisco, CA 94102 Attn: John Ladd, Esq.
ACandS HASSARD, BONNINGTON, ROGERS
HUBER 5 Fremont Center 50 Fremont Street, Suite 3400 San Francisco, CA 94104 Attn: James N. Penrod, Esq.
Owens-Illinois HORGENSTEIN JUBELIRER Federal Reserve Bank Building 101 Market Street, 6th Floor San Francisco, CA 94105 Attn: Laurie K. Anger, Esq.
MICHAEL P. STANLEY,ESQ. BROBECK,PHLEGER & HARRISON One Market Plaza Spear Street Tower San Francisco, CA 94105
BRAYTON & ASSOCIATES P.O. Box 2109 Novato, CA 94948
SHIELD & SMITH 580 California St., #1400 San Francisco, CA 941Q4 CCR
2