Document qdRNqbxq2BvRJgXaQRYLGQJ2M

In re: IN THE CIRCUIT COURT FOR THE THIRD JUDICIAL CIRCUIT MADISON COUNTY, ILLINOIS All Asbestos Litigation in Madison County WESTINGHOUSE ELECTRIC CORPORATION1S SECOND SUPPLEMENTAL RESPONSE TO PLAINTIFFS' INTERROGATORY NUMBERS 7 AND 8 AND NOTICE OF COMPLIANCE___________________________ Westinghouse Electric Corporation ("Westinghouse"), by counsel, files this Second Supplemental Response to plaintiff's Interrogatory Numbers 7 and 8 in compliance with paragraph 4 of the Court's Order of October 29, 1987, and paragraph 13 of the Court's Order of November 17, 1987. INTERROGATORY NO. 7: As to any product containing asbestos in any form, has this defendant, or any predecessor (s) : (a) Ever designed such a product? (b) Manufactured such a product? (c) Processed such a product? ; (d) Sold such a product? (e) Distributed such a product? (f) Patented such a product? (g) Relabeled such a product which was manufactured, sold or distributed by another company? ANSWER: Westinghouse believes that the answer to Interrogatory No. 7(a), (b), (c), (d) , and (e) is yes and investigation is continuing as to No. 7(f) and (g). PLAINTIFFS { EXHIBIT INTERROGATORY NO* 8; If your answer to No 7(b), 7(d) and 7(e) is *Yes", then give the trade name of the product, the year the defendant or predecessor first sold or distributed such product, and the year the defendant last sold or distributed such product. ANSWER: During the time periods relevant to this litigation, Westinghouse manufactured and sold asbestos-containing products. Westinghouse also sold and distributed asbestos-containing products manufactured by other companies. In addition, Westinghouse manufactured, sold and distributed Westinghouse products which incorporated asbestos-containing components manufactured by other entities. . ' The following is a list of asbestos-containing products1 that Westinghouse reasonably believes that it manufactured, sold or distributed during the relevant time periods: air conditioners and compressors arc chute on DHP breaker assembly armatures brakes for motors, bridge hoists, cranes and other industrial equipment, and linings breakers bus ways capacitor-start capacitor-run motors capacitor-start split phase motors cement insulating material, BT-4105 circuit breakers condensers control equipment control rod drive mechanisms control items such as relays, contactors, overload relays, overhead controls, and control assemblies CPL arrester CRC test press xNot all variations of these general product descriptions contained asbestos. DC armatures for motors DC contactor electrical tape electronic tubes elevators epoxy resin insulating material, B7-365 escalators fans flexible laminate floodlights, aviation lights and light fixtures fluorescent lights fractional horse motors gaskets gas-pak gas heat electric cool air conditioner units generators governors heat transfer products heating coils high voltage incandescent lamp, 230V immersible transducers induction heating equipment and systems JF autostarter lighting arresters magnetic controller magnetic relay mercury lamp mercury vapor rectifier micarta plate and tube ^ molded line traps > molded parts for electrical equipment, including: spacer barrier mounting or terminal blocks arc boxes and shields electrical insulator sleeve plug board barrier support coil shield motors and motor insulating materials moveable vail panels network protectors outdoor switches with heating elements oxygen analyzer probe assembly oxygen shield power reclosures protective relays pumps and packing range timer reductor gears safety switches shaft seal main loop circulating pumps single phase brake motors sleeving split-phase motors SVS arrester (500) ' -3- steam & gas turbines and ancillary insulating materials switchgears tape thermal demand meter traction motors transducers transformers treated and untreated fabric and paper valves and packing varnish treated insulating material for electrical equipment welding electrodes welding machines wire wound resistor assembly Westinghouse also believes it may have distributed, through Westinghouse Electric Supply Company ("WESCO"), a Westinghouse division, asbestos-containing products manufactured by Westinghouse and other companies. The following is a list of asbestos-containing products of other companies that were advertised for sale through WESCO catalogs, and available for sale through various WESCO offices. _ American Beauty Heater Cord Armored Thermostat Cable Asbestos Insulated Heat-resisting Fixture Cord, type AF Asbestos Insulated Wire and Cable Asbestos Ranger and Rheostat Wire "Rockbestos" Collyer Asbestos Heater Cord General Cable Asbestos Insulated Fixture Wire General Cable Asbestos Insulated Flexible Cord Heater Cord Type HPD Rockbestos Asbestos Varnished Cambric Wire, Types ABC and ' AVP Rockbestos Asbestos-covered Nickel Cord Rockbestos AVC Boiler Room Wire and Cable Rockbestos AVC Switchboard Wire Rockbestos Heating Resisting Fixture Wire Rockbestos Power Cable Rockbestos Stove Wire Rockbestos Table LH Hotbed or Industrial Heating Cable Thermostat Cable There may be other asbestos-containing products manufactured by companies other than Westinghouse that local WESCO offices distributed that are not included in the catalogs and. -4- consequently, are not on this list. Furthermore, there say have been additional asbestos-containing products that were advertised for sale in the WESCO catalogs, but which Westinghouse is unable to identify as having contained asbestos based upon the limited product descriptions in the catalogs. Accordingly, these catalogs are being made available to plaintiffs for inspection, upon reasonable notice. Westinghouse has been unable to locate catalogs for certain years. Consequently, there may have been asbestos-containing products manufactured by companies other than Westinghouse which Westinghouse is unable to identify and list for those years. Westinghouse also supplements this response by incorporating by reference any other asbestos-containing products not identified in the lists above which may have been manufactured, sold or distributed to plaintiffs* employers as reflected in purchase orders, purchase invoices, or other sales-related documents within the possession of plaintiffs* counsel and plaintiffs' employers, but which Westinghouse has not yet determined to have contained asbestos. The information contained in this pleading is based on the results of a reasonable, good faith investigation of available records and interviews with current and former Westinghouse employees. Accordingly, Westinghouse will supplement this response if any additional information is obtained through continued investigation. -5- Respectfully submitted, WESTINGHOUSE ELECTRIC CORPORATION By: See Affidavit Attached Counsel: Robert W. Schmieder Roger F. Wilson Hinshav, Culbertson, Moelmann, Hoban & Fuller 521 West Main Street, Suite 300 P.O. Box 509 Belleville, Illinois 62222 CERTIFICATE OF SERVICE I hereby certify that a true and exact copy of the foregoing Westinghouse Electric Corporation's Second Supplemental Response to Plaintiffs* Interrogatory Numbers 7 and 8 and Notice of Compliance was mailed to all counsel of record for the parties and the respondent employers this day of December, 1987. 12028701 COMMONWEALTH OF PENNSYLVANIA ) ) SS: COUNTY OF ALLEGHENY ) Before me, the undersigned authority, a Notary Public in and for said Commonwealth and County, personally appeared R. E. PETERS, who, being duly sworn, deposes and says that he is ASSISTANT SECRETARY of WESTINGHOUSE ELECTRIC CORPORATION; that he is authorized to make this Affidavit for and on its behalf; and that the statements contained in the foregoing ANSWERS TO INTERROGATORIES are true and correct to the best of his knowledge, information and belief. SWORN TO and subscribed before me this of bc-Cl day , 198 7. Notary Public fBECCAS.TMt. MUM PUBLIC FITTS3UR5H. AUESHEW COUNTY MY COBWSSiON EXPIRES Uimtv . 2* * *** R. E. PETERS Assistant Secretary