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 -- 0oc/ 7010 fSC^Oftsr ---------- -- 6 fiUc^r w 777 "7# 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- Take advantage of this golden opportunity to sample full size packages of all these outstanding Goodyear adhesives products. You pay only S3.49 for two items and get the other four free -- a Si6.00 value. Simply return coupon with your check or take this ad to your local Goodyear dealer or building materials distributor. 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___________________________________________________________ COMPANY__________________________________________________ STREET ________________________________________________________ CY-CHM-?30014 3uy T-.-o, Gee Four Free Pg- i/C 31d. 3-3/8 x 11-1/8 Bid. 7-3/8 x 10-1/8 L.M Qualified Reuodeler 1 Piio-Nail,by Goodyear. Itjust might make the nail obsolete. P!io-.N'ail * panel and construction adhesives can take care of almost every bonding project--inside and out, whether main tenance. or a complete remodeling job. Use Piio-Nail construction adhesive for T&G flooring, house siding, stair treads/risers, blown shingling and roofing, drywall, metal, tile. ..even concrete and cement block. Piio-Nail panel adhesive bonds wall panels, drywall. hardboard. corkboard, foam insulation... to studs, masonry, drvwall or concrete. Plio-Na'il construction adhesives meet tough building codes and HUD requirements. Look for the Goodyear blimp display in your store. You'll find both Piio-Nail adhesives right underneath. And probably notice less nails. Contact W. J. P.uscoe at (216) 253-8148 for the store nearest you. GOODYEAR CHEMICALS Gy-chw- Pi Ci;S* X - ': Ziqe 3Aw 0:3 rfl 33`5<5 i L-? 7 - *5 t i M --5 = s-iiy *.* >. N W Ayer /aMSJKI International 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 and tenths size cartridges trom 094-980-77-NP-0017 1/6-page B6W Professional Builder S Aparcaenc Business March 1977 4 Plio-nail, by Goodyear. Itjust might make the nail obsolete. Plio-N'ail=- panel and construction adhesives can take care of almost every bonding project--inside and out. whether main tenance or a complete remodeling job. 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. Plio-N'ail panel adhesive bonds wall panels, drywall. hardboard. corkboard. foam insulation.. .to studs, masonry, drvwall or concrete. Both types meet tough building codes and HUD requirements. Look for the Goodyear biimp display hanging in your store. You'll find both Plio-N'ail adhesives right underneath. And probably notice iess nails. Contact W../. Ruscoe at (216) 253-8148 for the store nearest you. GOOD-YEAR CHEMICALS C94-980-79-NP C;2 ': sage 9'0 8 3 i6*5 ? lti :: !54ii ^ ramiiy r*aPCyp',df'-- r*ow T&-- ' N W Ayer /`MSIInl International New Goodsear Plio-Nail 'panel adhesive develops sufficient strength to hold a 4 \ 8 panel firmly in place--even without nails. You can use this remarkable new adhesive to bond wall panels. dr\ wall, hardboard. eorkboardortoam insulatio" to masonrv. studs. Hihrtoor. dry wall or concrete. PIio-Nail goes on easily in one lilmiinates finishing work on dr\ wall v automatically. Andeliminates nail pop* (ioodsear Plio-Nail panel adhc ihle in stores even where. Stick v ' QQD/YEAR * Plio-Nail. Tough as nails. 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 ana construction ^Z'goodSyea] 3o:n r.oes meet "Cjgn cuilOinq coca ana HUD requirements. Look for the Goodyeor blimp : so ev hanging in your store Tnars wnere , :u .i ` nd Pho-Noil adhesives Tough as nans GOOD-YEAR ~ CHEMICALS ruo-iNau, oy u^oayear. Itjust might make the nail obsolete. They just might be some of the hottest-moving items in your inventory this year, too! Reason: panel and construction adhe sives are really catching on with con sumers. They're learn ing how and where to use them--from big jobs, like flooring and paneling, to minor repairs. And they know how easy and fast--even funadhesives are to work with. This accom plished, which adhesives do they choose? Plio-Nail'! Because they've seen Plio-Nail advertised in major, national do-it-yourself magazines. And be cause they recognize and trust the Goodyear n Your in-store disolav is another grabber! Customers can test Plio-Nail adhesives' tough bond using their own strength... they liter ally sell themselves! Not surprising, be cause Plio-Nail-construction adhesive has passed tight building codes and meets all requirements of AFG-01 and HUD-FHA I'seOf-Materials bulletin #><). Finding Plio-Nail adhesive in-store? Only Goodyear gives you draw power like this--a large, blow--up blimp to"fly"< >\vr you merchandiser. It's one of Ana lica'.best-recognized symbols ofquaiiiy! Call your Building Material Distributor representative f- -r full promotion package, display, and st*>ek. Fix-up tinir > PlioNail time. A "clean-up" 'ppor tunity for you! GOOD-YEAR CHEMICALS 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 to measure up to the stubborn life of the new material. The tube of this new Good year Asbestos Cord Steam Hose has proved by le-t '.hat it has 12 times greater resis tance under pressure uud heat to hardening, eraekiu", blis tering, and swelling than the best cotton-fabric steam hose. The carcass of the new hose -- the "weakest link" in ordi nary hose--has 5 limes better than normal resistance to beat and flexing. The cover has strength and toughness ini!' equal to lube and carc.i-- -- an expert Goodyear pro duction for an exacting j---- There arc constant ....... velopments in the Iim-Goodyear Mechanical linl.i-. r Goods. A searching ih-s>'...... meat policy makes hn-in- -for the Goodyear 11 Find out about the Goo-i.. .r franchise. For compl- i-formation,w rile to G.... ;Akron, Ohio, or Los \ California. BELTS PAC K I Mi 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- <. ,t I he Ini- : ' ' * re**f.i-;. jri >ifrr 'ii*.' mni /< ' ' J 'Md.Ml*. Uli'h'rti'j til? .!.. r 1 .'(Ii;. tiltltl 'ihrtc ||o,f. riir ..... -r. im|h mid 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. ..* ( *..r r.. ,,:rv ............. .. . ` l - - . .. l.'J.ca. -Law % . -- - :vp.v`.v pr 1 .:.r * r . ,,..r Swip.**.:^ "r - v- ' r t^ v-UiCivv".' ' ' ` - V -r r? :................... - T; . -- I1 \<.r v. 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