Document qdk0bV6aMDMrXLYgY7gnkogQn
FILE NAME: Hampshire (HAMP)
DATE: 1993 Nov 23 DOC#: HAMP112
DOCUMENT DESCRIPTION: Legal - Hampshire's Supplemental Responses to Requests for Admissions
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i. 1981-1985
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ANSWER TO REQUEST NO. 14
Denied as to a through g. Admitted as to h and i.
REQUEST NO. 15:
That during the following time periods you maintained your home office on West 24th Street in Baltimore, Maryland:
a. 1911-1915 b. 1916-1920 c. 1921-1925 d. 1926-1930 e. 1931-1935 f . 1936-1940 g- 1941-1945 h. 1946-1950 i. 1951-1955 j- 1956-1960 k. 1961-1965 1. 1966-1970 m. 1971-1975 n. 1976-1980 o. 1981-1985
ANSWER TO REQUEST NO. IS:
Denied as to a through e. REQUEST NO. 16t
Admitted as to f through o.
That at various times from 1921 to the present you maintained branch offices in the following cities:
a. Bladensburg, Maryland b. Richmond, Virginia c. Roanoak, Virginia d. Norfolk, Virginia e. Charleston, W. Virginia f. St. Albans, W. Virginia
LAW O FFICES
THOMAS & U B O W ITZ. P.A.
.POTSS(OKAL ASSOCIATION FIFTH FLOOR
5 0 0 N. CHARLES STREET BALTIMORE. MARYLAND
21201-4303
ANSWER TO REQUEST NO. 16:
Admitted. REQUEST NO. 17:
That in the following time period Hampshire Corporation sold, distributed, used, installed and/or applied acoustical products
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LAW OFFICES KOMAS 4 LIBOWITZ. P A ROFESSIONAL ASSOCIATION
FIFTH FLOOR IO N. C H A R LE S STREET ALTIMORE. MARYLAND
21201-4005
REQUEST NO. 77:
In connection with the manufacture of your asbestos-containing products, your own employees would at times perform the following functions with respect to your asbestos-containing products:
a. mix; b. saw; c. cut;
d. trim; e. test; f. spray or gun; g- handle; h. sand.
ANSWER TO REQUEST NO. 77:
Denied. See Answer to Request No. 6.
REQUEST NO. 78i
In connection with your own business, you employed individuals who performed duties of:
a . pipecoverers;
b . insulators ;
c. pneumatic gun operators;
d. spray gun operators;
e . plasterers ;
f. installing asbestos-containing ceiling floor
tiles;
g. installing
asbestos-containing
drywall/
wallboard;
h. brake and/or clutch mechanics;
i. vehicle assembly workers or maintenance men;
j . steamfitters;
k. pipefitters;
l. joiners;
m . shipfitters;
n. electricians;
o . latherers;
p. sheet metal workers;
q. bricklayers;
r. millwrights;
s. welders;
t . burners;
u . ironworkers ;
v . laborers ;
w . carpenters;
x . painters;
y . boilermakers;
z . plumbers ;
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iHAWMQH PLAINTIFFS
j EXHIBIT
aa. roofers? bb. operating engineers; cc. automobile and/or truck mechanics.
ANSWER TO REQUEST MO. 78?
Admitted as to d, e, f, g, o, v, w, x, and aa. Otherwise
denied.
REQUEST NO. 79:
At no time did you advise persons who used, handled or were exposed to your asbestos-containing products that:
(a) you had concluded that respirators in use were inadequate to assure prevention of illnesses and diseases arising out of exposure to asbestos dust, and
(b) you had knowledge that respirators procured for use by your employees exposed to asbestos were not capable of filtering asbestos fibers smaller than 3.5 microns in diameter.
ANSWER TO REQUEST KO. 7 9 S
Denied. See Answer to Request No. 33.
REQUEST NO. 80:
You first installed vacuum and/or exhaust systems on equipment used in fabricating, processing, cutting, mixing or handling asbestos and/or asbestos-containing products at your manufacturing facilities in the following time period:
a. before 1930; c. 1930-1939? e. 1950-1959; g- 1965-1969; i. 1976-1979? k. 1986-1990?
b. 1930? d. 1940-1949? f . 1960-1964? h. 1970-1975?
j- 1980-1985; 1. 1991-1993.
LAW O FFICES KOMAS 4 LIB O W ITZ. P.A.
WOfCSSJOMAL ASSOCIATION
FIFTH FLOOR DO N. C H A R L E S S T R E E T IALTIMORE. M ARYLAND
2 1 2 0 1 -4 3 0 5
ANSWER TO REQUEST NO. BO: Denied. Not applicable. Hampshire is not a manufacturer.
REQUEST NO. 81:
You first required your employees to have regular chest x-rays in the following time period:
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