Document qm9RGw5gzqXy26b6zzG38BLM5

FILE NAME Rogers Corporation ROG DATE 2014 DOC ROG003 DOCUMENT DESCRIPTION Legal - Defendant Rogers Corporation's Ammended Answers to Plaintiffs Interrogatories 7478-688 IN THE CIRCUIT COURT STATE OF MISSOURI TWENTY JUDICIAL CIRCUIT City of St. Louis JEFF KOVAR Plaintiff V. A.W. CHESTERTON COMPANY et al Defendant ) ) ) Cause No CC01123 ) ) PRODUCTS LIABILITY ) ASBESTOS DOCKET ) ) JURY TRIAL DEMANDED ) CERTIFICATE OF SERVICE The undersigned certifies that true and correct copies of Rogers Corporation's Amended Answers to Plaintiff's Interrogatories were served on Plaintiff's counsel Jerry J. Fitzgerald at O'Brien Law Firm 815 Geyer Ave. St. Louis MO 63104 via email fitzgerald@obrienlawfirm.com and U.S. mail postage paid and this Certificate of Service only was served with the Clerk of the Court by using the Missouri Filing ECF system which will send a notice of electronic filing to all known counsel of record on July 2 2014 Copies are available to all defense counsel by contacting the undersigned Respectfully submitted ROGERS CORPORATION Timothy McCambridge Timothy By s L. Krippner Timothy Krippner McCambridge 60578 & Mahoney Ltd SegaWilllis Tower Suite 55S0i0nger 233 South Wacker Drive Chicago 312 Illinois 60606 645-7800 312 645-7711- fax No CC01123 Page 1 of1 IN THE CIRCUIT COURT FOR THE CITY OF ST LOUIS STATE OF MISSOURI TWENTY SECOND JUDICIAL CIRCUIT JEFF KOVAR Plaintiff V. ROGERS CORPORATION et al Defendants Case No. CC01123 Division 18 DEFENDANT ROGERS CORPORATION'S AMENDED ANSWERS TO PLAINTIFF'S INTERROGATORIES NOW COMES Defendant Rogers Corporation hereinafter referred to as Rogers Corp. or Responding Defendant by its attorneys SEGAL MCCAMBRIDGE SINGER & MAHONEY LTD and for its Amended Responses Responses to Plaintiff's Interrogatories Interrogatories states as follows PRELIMINARY STATEMENT Rogers Corp.'s Response to each Interrogatory incorporates this Preliminary Statement a The information supplied in these Responses is not based solely upon the knowledge of the executing party but includes substantial information assembled by and within the knowledge of the party's authorized agents representatives and unless privileged attorneys Because much of the information is of or relates to events of many years ago it is difficult if not impossible for Responding Defendant to retrieve or reconstruct some of the requested information Many of the individuals who might have had personal knowledge of the matters to which Plaintiff's discovery relate are deceased or are otherwise unavailable to Responding Defendant and investigations to date indicate that some information in documents which might relate to matters inquired into by Plaintiff's discovery may have been destroyed Responding Defendant is engaged in a continuing investigation in an attempt to locate or confirm the absence of such information or documents and Responding Defendant is also engaged in a continuing investigation with respect to the matters inquired into by Plaintiff's discovery Therefore Responding Defendant reserves the right to amend these responses if new or more accurate information becomes available or errors are discovered Furthermore these Responses are given without prejudice to Responding Defendant's right to rely on at trial subsequently discovered information or on information inadvertently omitted from these responses as a result of mistake error or oversight b | The word usage and sentence structure is that of the attorneys who in fact prepared these Responses and does not purport to be the exact language of the executing party c The Interrogatories have been interpreted and answered in accordance with the Missouri Rules of Civil Procedure and plain English usage and to the extent not specifically challenged by objection the definitions and instructions of same were included d Responding Defendant further objects to these Interrogatories as Responding Defendant has not been provided with sufficient information by Plaintiff to enable it to respond fully to these discovery requests The Plaintiff has not identified with specificity the product allegedly sold by Responding Defendant which Plaintiff claims were a substantial causative factor in producing her alleged asbestos disease e | The Responses are limited to those matters not subject to the attorney privilege and to those matters that do not constitute attorney work product f Responding Defendant objects to these Interrogatories to the extent they imply that Responding Defendant was under a duty to provide warnings for its products or that any products sold by it would expose workers to harmful dust levels g In responding to these Interrogatories Responding Defendant does not concede the relevancy materiality or admissibility of any information sought by the discovery requests or any Responses thereto The Responses are made subject to and without waiver of any questions or objections as to the competency relevancy materiality privilege or admissibility of evidence documents or information referred to herein or the subject matter thereof in any proceeding including trial GENERAL OBJECTIONS Responding Defendant makes the following additional General Objections to these Interrogatories ( GENERAL OBJECTION NO 1 Responding Defendant objects to these Interrogatories to the extent that they seek information subject to the attorney privilege or which constitutes protected work product GENERAL OBJECTION NO 2 Responding Defendant objects to each interrogatory to the extent that it calls for proprietary and confidential business information and as such is protected from disclosure as trade secret information Responding Defendant's Responses to these Interrogatories are made without waiver of any such privilege or protection against disclosure GENERAL OBJECTION NO 3 These Interrogatories are not product specific and as such Responding Defendant objects GENERAL OBJECTION NO 4 Responding Defendant objects to any definition within these Interrogatories that purports to include entities other than Rogers Corp. which is the entity named in the above captioned litigation Each of the following Responses to Interrogatories are limited in scope as described in the Preliminary Statement Similarly Responding Defendant objects to any definition that encompasses products not at issue in this litigation GENERAL OBJECTION NO 5 Responding Defendant objects to the extent these Interrogatories assume facts not in evidence and call for speculation and legal conclusions GENERAL OBJECTION NO 6 Responding Defendant objects to the extent these Interrogatories call for medical or scientific conclusions beyond the scope of Responding Defendant's knowledge and capabilities GENERAL OBJECTION NO 7 Responding Defendant objects to the extent these Interrogatories purport to impose upon Responding Defendant any obligations different from or in addition to those set forth in the Missouri Rules of Civil Procedure or discovery decisions of this Court GENERAL OBJECTION NO 8 Responding Defendant objects to the extent these Interrogatories are premature not case specific nor specific to a particular Plaintiff and request information relevant to Plaintiff locations witnesses and other things that have not been identified to date or seeks the premature disclosure of information contrary to the Missouri Rules of Civil Procedure GENERAL OBJECTION NO 9 Responding Defendant objects to the Plaintiff's definitioonf Product and any requests that seek information or documents about products other than the product allegedly at a issue in the LYLE KOVAR case at the locations at issue and during the relevant time period Requests for information and documents about other Responding Defendant products are overly broad unreasonably burdensome and are not reasonably calculated to lead to the discovery of admissible evidence GENERAL OBJECTION NO 10 Responding Defendant objects to the extent that these Interrogatories assume Responding Defendant's products created dust created a health hazard or were dangerous when used as intended GENERAL OBJECTION NO 11 The foregoing General Objections are hereby explicitly incorporated into each and all of the responses hereinafter provided to all Plaintiff's Interrogatories in the captioned action INTERROGATORIES 1 Identify the person verifying these Answers on behalf of Defendant including their full name address length of employment with this defendant and current job title ANSWER Terrence Mahoney Vice President Rogers Corporation One Technology Drive Rogers CT 06263. Length of Employment - 5 years 2 Identify by full name address and job title your Custodian of Business Records ANSWER Responding Defendant incorporates its Preliminary Statement and General Objections in response to this Interrogatory Rogers further objects to this Interrogatory as vague overly broad unduly burdensome ambiguous duplicative seeks discovery of information and materials beyond the permissible scope of discovery and is not reasonably calculated to lead to the discovery of admissible evidence By way of further objection this Interrogatory seeks general investigative information concerning Rogers the subject of which is wholly irrelevant and not limited with adequate specificity to the facts alleged in this litigation 3 Has Defendant ever had a document retention policy If your answer is yes identify ~~ the date of each such policy and specify its document retention requirements protocol ANSWER Responding Defendant incorporates its Preliminary Statement and General Objections in response to this Interrogatory Responding Defendant further objects to this Interrogatory as vague overly broad unduly burdensome ambiguous and not reasonably calculated to lead to the discovery of admissible evidence Responding Defendant further objects to this Interrogatory because it is not sufficiently limited to a specific time location or product and thus seeks information that is wholly irrelevant to the present case By way of further objection Responding Defendant objects hereto as this Interrogatory seeks discovery of information and materials beyond the permissible scope of discovery This Interrogatory does not seek information concerning a specific product produced by Responding Defendant Instead this Interrogatory seeks general investigative information concerning Responding Defendant As such this Interrogatory is overly broad not particularized and such a response from Responding Defendant would create an inestimable amount of work to prepare this Interrogatory is intended to create an unreasonable burden and the burden is incommensurate with the results sought 4 - With respect to Defendant please identify a The full and correct name b All names by which Defendant has been known or has conducted business and the dates during which it has been known by or conducted business under each such name The principal place of business Each state in which Defendant maintains an office for the usual and customary transaction of business fl The present state of incorporation Whether Defendant is authorized to transact business in the State of Missouri and if so the date such authority was first issued and last renewed and g The location of each agent representative and place of business in Missouri ANSWER Responding Defendant incorporates its Preliminary Statement and General Objections in response to this Interrogatory Responding Defendant further objects to this Interrogatory to the extent it seeks information subject to the attorney privilege or which constitutes protected work product Responding Defendant objects to this Interrogatory as vague overly broad burdensome ambiguous and not reasonably calculated to lead to the discovery of admissible evidence even with the purported definitions contained herein Without waiving the foregoing objections and subject to same Responding Defendant responds as follows a Responding Defendant conducts business as a corporation named Rogers Corporation b The Rogers Paper Manufacturing Company was founded in 1832. In 1927 The Rogers Manufacturing Company was incorporated in Massachusetts In 1945 the company changed its named to Rogers Corporation Rogers Connecticut See above objections Massachusetts See above objections See above objections 5 Identify by full and complete trade name all thermoset plastics thermo plastic plastic resin and plastic compound materials which you or any predecessor entity has at any time Designed or contracted to design Manufactured or contracted to manufacture b Processed or prepared or contracted to process or prepare Sold or contracted to sell Distributed or contracted to distribute Acquire ANSWER Responding Defendant incorporates its Preliminary Statement and General Objections in response to this Interrogatory Responding Defendant further objects to this Interrogatory as vague overly broad unduly burdensome ambiguous and not reasonably calculated to lead to the discovery of admissible evidence Responding Defendant further objects to this Interrogatory because it is not sufficiently limited to a specific time location or product and thus seeks information that is wholly irrelevant to the present case By way of further objection Responding Defendant objects hereto as this Interrogatory seeks discovery of information and materials beyond the permissible scope of discovery This Interrogatory does not seek information concerning a specific product produced by Responding Defendant Instead this Interrogatory seeks general investigative information concerning Responding Defendant As such this Interrogatory is overly broad not particularized and such a response from Responding Defendant would create an inestimable amount of work to prepare this Interrogatory is intended to create an unreasonable burden and the burden is incommensurate with the results sought 6. For each asbestos thermoset plastics thermo plastic plastic resin plastic compound materials referred to in Answer 5 above identify whether asbestos was ever an ingredient ANSWER See above response to Interrogatory Number 5 7 For each asbestos thermoset plastics thermo plastic plastic compound materials referred to in Answer 5 above identify the following resin and plastic a The product's packaging b Writing that appears on the product packaging including any logos C. Colors of products packaging and colors of writing including logos on products packaging d The name and current or last known address of each current or formeremployee~ with knowledge of the design manufacturing and sale of asbestos containing products ANSWER See above response to Interrogatory Number 5 8 If you have stopped producing distributing and selling any of the asbestos thermoset plastics thermo plastic plastic resin and plastic compound materials listed in Answer 5 state for each product a The reason you stopped b The date you stopped C. Whether any studies were conducted before you directed that production and sale to be stopped and if so identify each such study by title date author and subject matter ANSWER See above response to Interrogatory Number 5 9 State whether any brochures writing or other materials written or photographic were made available to distributors drywall commercial buyers installation workers users or the general public concerning the design manufacture distribution selling installation and use of the asbestos thermoset plastics thermo plastic plastic resin and plastic compound materials referred to in Answer 5. For each such brochure or material identify the material author date and present location and custodian ANWER See above response to Interrogatory Number 5 10 Between 1958 and 1978 did you or any predecessor entity sell or deliver any material or products to the Square D Facility located in Cedar Rapids Iowa If your answer is yes identify a Type brand name full name and complete trade name of each product sold and delivered to the facility b The dates on which each product identified in a was sold and delivered to the facility C. Which products identified in a contained asbestos as any part ingredient or component d The type grade brand name full name complete trade name of asbestos in each product identified in a e The products package f Writing that appears on the product packaging including logos g Colors of products packaging and colors of writing including logos on product's packaging h Each entity from which you or any predecessor entity acquired each product identified in a for sale or delivery to the facility i Each warning which you provided with each product identified in a and j All persons who were involved with or who have knowledge of the sale or delivery of each product identified in a Specify which person is the most knowledgeable concerning each product at the facility ANSWER Responding Defendant incorporates its Preliminary Statement and General Objections in response to this Interrogatory Responding Defendant further objects to this Interrogatory as vague overly broad unduly burdensome ambiguous and not reasonably calculated to lead to the discovery of admissible evidence Responding Defendant further objects to this Interrogatory because it is not sufficiently limited to a specific product and thus seeks information that is wholly irrelevant to the present case By way of further objection Responding Defendant objects hereto as this Interrogatory seeks discovery of information and materials beyond the permissible scope of discovery This Interrogatory does not seek information concerning a specific product produced by Responding Defendant Instead this Interrogatory seeks general investigative information concerning Responding Defendant As such this Interrogatory is overly broad not particularized and such a response from Responding Defendant would create an inestimable amount of work to prepare this Interrogatory is intended to create an unreasonable burden and the burden is incommensurate with the results sought Without waiving the foregoing objections Responding Defendant has made a diligent search of all relevant and available records and a reasonable inquiry in responding to this Interrogatory and identified the below indicated sales of products to the Square D facility located in Cedar Rapids Iowa between 1958 and 1978. See copies of relevant records provided a _ Year Product 1960 1961 1962 1963 1964 1965 1966 | 1967 | Molding Materials Molding Materials Duroid Molding Materials Molding Materials Duroid Molding Materials Duroid Glass Phenolic Molding Extruded Molding Materials DAP Molding Materials Glass Phenolic Molding Extruded Molding Materials Glass Phenolic Molding Extruded Molding Materials 1971 1971 1971 1972 21.81 462 ' 21.77 467 Black 462 variant 21.84 466 21.24 468 Black 1972 1972 1972 21.77 - 467 Black 462 variant 21.81 - 462 21.84 466 1973 1973 21.81 462 21.84 466 1974 1974 1975 21.81 21.84 www 466 21.84 466 1975 1976 21.81 462 21.81 1976 1976 21.84 466 32.27 611 Black Pounds Sold 78,260 135,325 100 121,250 221,290 1,680 279,420 2,588 7,900 299,750 20 8,200 312,043 11,000 242,050 10,000 10,000 10,000 10,000 Asbestos Containing Unknown Fiber Type Unknown No Unknown Unknown No Unknown No No Unknown No No Unknown No Unknown Yes Yes Crocidolite and Chrysotile Crocidolite and Chrysotile in some formulations Yes Chrysotile Yes Chrysotile 652 49,750 200,190 10,000 197,800 278,975 160,000 48,200 211,025 167,675 578,205 16,330 Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes In some Crocidolite and Chrysotile in some formulations Crocidolite and Chrysotile Chrysotile Crocidolite and Chrysotile Chrysotile Crocidolite and Chrysotile Chrysotile Chrysotile Crocidolite and Chrysotile Crocidolite and Chrysotile Chrysotile Chrysotile if 1977 1977 1977 1977 1978 1978 1978 1978 21.81 462 21.84 466 32.27 RX Black Unknown Product 21.81 462 21.84 - 466 32.AL 611 32.27 611 Black 314,525 323,110 54,700 19,600 10,400 261,200 20,365 56,868 formulations Yes present Crocidolite and Chrysotile Yes In some formulations Unknown Yes Yes In some formulations In some formulations Chrysotile Chrysotile if present Crocidolite and Chrysotile Chrysotile Chrysotile if present Chrysotile if present 11 Between 1958 and 1978 did you or any predecessor entity have any contracts or agreements with any entity to provide sell or supply materials or products to the Square D facility located in Cedar Rapids Iowa If your answer is yes identify a The date of each contract or agreement b Each entity with which you or any predecessor entity had each agreement The materials or products provided sold or supplied to each entity identified in b at each location The name address job title and employer of all persons who were involved with or who have knowledge of each contract or agreement Specify which person is the most knowledgeable concerning each subject matter ANSWER Responding Defendant incorporates its Preliminary Statement and General Objections in response to this Interrogatory Responding Defendant further objects to this Interrogatory as vague overly broad unduly burdensome ambiguous and not reasonably calculated to lead to the discovery of admissible evidence Responding Defendant objects to this Interrogatory as it calls for a legal conclusion Responding Defendant further objects to this Interrogatory because it is not sufficiently limited to a specific product and thus seeks information that is wholly irrelevant to the present case By way of further objection Responding Defendant objects hereto as this Interrogatory seeks discovery of information and materials beyond the permissible scope of discovery This Interrogatory does not seek information concerning a specific product produced by Responding Defendant Instead this Interrogatory seeks general investigative information concerning Responding Defendant As such this Interrogatory is overly broad not particularized and such a response from Responding Defendant would create an inestimable amount of work to prepare this Interrogatory is intended to create an unreasonable burden and the burden is incommensurate with the results sought 12 With respect to any product you or any predecessor entity sold or distributed to the Square D facility located in Cedar Rapids Iowa between 1958 and 1978 did you or any predecessor entity ever provide to anyone any warning or caution or like information concerning the following a Asbestos or containing materials b Possible health effects hazards or any other risks associated with exposure to asbestos or containing materials C. Threshold limit values of exposure to asbestos and d Recommendations related to working with or around asbestos or asbestos- containing materials ANSWER Responding Defendant incorporates its Preliminary Statement and General Objections in response to this Interrogatory Responding Defendant further objects to this Interrogatory as vague overly broad unduly burdensome ambiguous and not reasonably calculated to lead to the discovery of admissible evidence Responding Defendant further objects to this Interrogatory because it is not sufficiently limited to a specific product and thus seeks information that is wholly irrelevant to the present case By way of further objection Responding Defendant objects hereto as this Interrogatory seeks discovery of information and materials beyond the permissible scope of discovery This Interrogatory does not seek information concerning a specific product produced by Responding Defendant Instead this Interrogatory seeks general investigative information concerning Responding Defendant As such this Interrogatory is overly broad not particularized and such a response from Responding Defendant would create an inestimable amount of work to prepare this Interrogatory is intended to create an unreasonable burden and the burden is incommensurate with the results sought Without waiving the foregoing objections and subject to same Responding Defendant states that it became generally aware of the hazards associated with asbestos exposure in the early 1970s through various media outlets Thereafter Responding Defendant issued warnings to its customers of its encapsulated containing products including but not limited to letters to customers and placement of warning labels on the packaging of such products To the extent Plaintiff identifies a specific product Responding Defendant will endeavor to respond hereto subject to all objections and privileges Investigation continues Responding Defendant reserves the right to supplement this response 13 Between 1978 and 1995 did you or any predecessor entity sell or deliver any material or products to the Square D facility located in Springfield Missouri If your Answer is yes identify a Type brand name full name and complete trade name of each product sold and delivered to the facility b The dates on which each product identified in a was sold and delivered to the facility C. Which products identified in a contained asbestos as any part ingredient or component d The type grade brand name full name and complete trade name of asbestos in each product identified in a e The products package f Writing that appears on the product packaging including logos g Colors of products packaging and colors of writing including logos on product's packaging h Each entity from which you or any predecessor entity acquired each product identified in a for sale or delivery to the facility i Each warning which you provided with each product identified in a and j All persons who were involved with or who have knowledge of the sale or delivery of each product identified in a Specify which person is the most knowledgeable concerning each product at the facility ANSWER Responding Defendant incorporates its Preliminary Statement and General Objections in response to this Interrogatory Responding Defendant further objects to this Interrogatory as vague overly broad unduly burdensome ambiguous and not reasonably calculated to lead to the discovery of admissible evidence Responding Defendant further objects to this Interrogatory because it is not sufficiently limited to a specific product and thus seeks information that is wholly irrelevant to the present case By way of further objection Responding Defendant objects hereto as this Interrogatory seeks discovery of information and materials beyond the permissible scope of discovery This Interrogatory does not seek information concerning a specific product produced by Responding Defendant Instead this Interrogatory seeks general investigative information concerning Responding Defendant As such this Interrogatory overly broad not particularized such response from Responding Defendant would create an inestimable amount of work to prepare this Interrogatory is intended to create an unreasonable burden and the burden is incommensurate with the results sought Without waiving the foregoing objections Responding Defendant has made a diligent search of all relevant and available records and a reasonable inquiry in responding to this Interrogatory and has not identified any records of sales of Rogers products to the Square D facility located in Springfield Missouri between 1978 and 1995. Given evidence regarding Plaintiff's work at the Square D facility located in Columbia Missouri the following records of sales were identified to that facility during the requested time period See copies of relevant records provided | Year 1979 Product 867 Breaker Bases 1980 | 611 Green Med and Soft flows for trial 862 Black - Circuit 1981 Breaker Housing & Cover 1982 molding materials 1983 1983 466 XA Pounds Sold Unknown Unknown Asbestos | Fiber Type | Containing No some | Chrysotile if formulations present No Unknown Unknown 104,000 Unknown Unknown Yes Unknown Chyrsotile 14 Between 1978 and 1995 did you or any predecessor entity have any contracts or agreements with any entity to provide sell or supply materials or products to the Square D facility located in Springfield Missouri If your answer is yes identify a The date of each contract or agreement b Each entity with which you or any predecessor entity had each agreement C. The materials or products provided sold or supplied to each entity identified in b at each location d The name address job title and employer of all persons who were involved with or who have knowledge of each contract or agreement Specify which person is the most knowledgeable concerning each subject matter ANSWER Responding Defendant incorporates its Preliminary Statement and General Objections in response to this Interrogatory Responding Defendant further objects to this Interrogatory as vague overly broad unduly burdensome ambiguous and not reasonably calculated to lead to the discovery of admissible evidence Responding Defendant objects to this Interrogatory as it calls for a legal conclusion Responding Defendant further objects to this Interrogatory because it is not sufficiently limited to a specific product and thus seeks information that is wholly irrelevant to the present case By way of further objection Responding Defendant objects hereto as this Interrogatory seeks discovery of information and materials beyond the permissible scope of discovery This Interrogatory does not seek information concerning a specific product produced by Responding Defendant Instead this Interrogatory seeks general investigative information concerning Responding Defendant As such this Interrogatory is overly broad not particularized and such a response from Responding Defendant would create an inestimable amount of work to prepare this Interrogatory is intended to create an unreasonable burden and the burden is incommensurate with the results sought 15 With respect to any product you or any predecessor entity sold or distributed to the Square D facility located in Springfield Missouri between 1978 and 1995 did you or any predecessor entity ever provide to anyone any warning or caution or like information concerning the following a Asbestos or containing materials b Possible health effects hazards or any other risks associated with exposure to asbestos or containing materials C. Threshold limit values of exposure to asbestos and d Recommendations related to working with or around asbestos or asbestos- containing materials ANSWER Responding Defendant incorporates its Preliminary Statement and General Objections in response to this Interrogatory Responding Defendant further objects to this Interrogatory as vague overly broad unduly burdensome ambiguous and not reasonably calculated to lead to the discovery of admissible evidence Responding Defendant further objects to this Interrogatory because it is not sufficiently limited to a specific product and thus seeks information that is wholly irrelevant to the present case By way of further objection Responding Defendant objects hereto as this Interrogatory seeks discovery of information and materials beyond the permissible scope of discovery This Interrogatory does not seek information concerning a specific product produced by Responding Defendant Instead this Interrogatory seeks general investigative information concerning Responding Defendant As such this Interrogatory is overly broad not particularized and such a response from Responding Defendant would create an inestimable amount of work to prepare this Interrogatory is intended to create an unreasonable burden and the burden is incommensurate with the results sought Without waiving the foregoing objections and subject to same Responding Defendant states that it became generally aware of the hazards associated with asbestos exposure in the early 1970s through various media outlets Thereafter Responding Defendant issued warnings to its customers of its encapsulated containing products including but not limited to letters to customers and placement of warning labels on the packaging of such products See Response to Interrogatory Number 13. To the extent Plaintiff identifies a specific product Responding Defendant will endeavor to respond hereto subject to all objections and privileges Investigation continues Responding Defendant reserves the right to supplement this response 16 | Has Defendant ever provided to anyone a warning or caution concerning any of the following a Asbestos or containing thermoset plastic materials b Possible health effects hazards or any other risks associated with exposure to asbestos or containing thermoset plastic materials c Threshold limit values of exposure to asbestos and d Recommendations related to working with or around asbestos or asbestos- containing thermoset plastic materials ANSWER Responding Defendant incorporates its Preliminary Statement and General Objections Objections in response to this Interrogatory Responding Defendant further objects to this Interrogatory as vague overly broad unduly burdensome ambiguous and not reasonably calculated to lead to the discovery of admissible evidence Responding Defendant further objects to this Interrogatory because it is not sufficiently limited to a specific product and thus seeks information that is wholly irrelevant to the present case By way of further objection Responding Defendant objects hereto as this Interrogatory seeks discovery of information and materials beyond the permissible scope of discovery This Interrogatory does not seek information concerning a specific product produced by Responding Defendant Instead this Interrogatory seeks general investigative information concerning Responding Defendant As such this Interrogatory is overly broad not particularized and such a response from Responding Defendant would create an inestimable amount of work to prepare this Interrogatory is intended to create an unreasonable burden and the burden is incommensurate with the results sought \) Without waiving the foregoing objections and subject to same Responding Defendant states that it became generally aware of the hazards associated with asbestos exposure in the early 1970s through various media outlets Thereafter Responding Defendant issued warnings to its customers of its encapsulated containing products including but not limited to letters to customers and placement of warning labels on the packaging of such products To the extent Plaintiff identifies a specific product Responding Defendant will endeavor to respond hereto subject to all objections and privileges Investigation continues Responding Defendant reserves the right to supplement this response 17 If your answer to the preceding interrogatory is yes identify a The date the first warning or caution was provided b The content of the warning or caution C. The date of each change of the warning or caution and d The changes made on each date identified in c ANSWER See above response to Interrogatory Number 16 18 Has Defendant ever placed a caution advisory or warning related to asbestos thermoset plastics thermo plastic plastic resin and plastic compound materials If your answer is yes identify a The type brand name full name and complete trade name of each product on which a caution advisory or warning was placed b The date on which the caution advisory or warning was first placed on each product identified in a C. The exact wording location and size of the caution advisory or warning which was first placed on each product identified in a and d Pursuant to Missouri Rule of Civil Procedure 56.01 identify and provide the location of each person whom you believe has knowledge of the caution advisory or warning identified herein ANSWER Responding Defendant incorporates its Preliminary Statement and General Objections in response to this Interrogatory Responding Defendant further objects to this Interrogatory as vague overly broad unduly burdensome ambiguous and not reasonably calculated to lead to the discovery of admissible evidence Responding Defendant further objects to this Responding Defendant objects hereto as this Interrogatory seeks discovery of information and materials beyond the permissible scope of discovery This Interrogatory information concerning a specific product Interrogatory does not seek produced by Responding Defendant Instead this Thereafter Responding Defendant through various media outlets customers of its encapsulated asbestos issued warnings its A containing products including but not limited to letters to customers and placement of warning labels on the Plaintiff identifies packaging of such products To the extent a specific product Responding Defendant will endeavor to subject to all objections and privileges Investigation continues respond hereto reserves the right to supplement this response Responding Defendant ) 19 Identify the date on which the Defendant first became could cause aware that exposure to asbestos a Mesothelioma b Lung Cancer and c Asbestosis ANSWER Interrogatory because it is not sufficiently limited to a specific time location or thus seeks information that is wholly irrelevant to the product and Responding Defendant objects hereto as this present case By way of further objection materials beyond the permissible Interrogatory seeks discovery of information and scope of discovery This Interrogatory Interrogatory does not seek information concerning a specific product produced by Responding Defendant Interrogatory seeks general investigative information Instead this concerning Responding Defendant As it became generally aware of the hazards associated with various media outlets however asbestos in the early 1970s through information Responding Defendant does not recall when if at all it received linking asbestos exposure to any specific disease I a ROGERS CORPORATION Christopher K. Triska Timothy L. Krippner Esq Christopher K. Triska Esq Segal McCambridge Singer & Mahoney Ltd. 233 South Wacker Drive - Suite 5500 Chicago IL 60606 (312)645-7800 VERIFICATION OF TERRENCE W. MAHONEY CONNECT OF I CONC NECU TICT UT COUNTY OF WINDHAM ) ss Rogers Connecticut ) COMES NOW TERRENCE W. states under penalty of perjury MAHONEY as follows who after being first duly sworn deposes and 1 respects to make this verification I make this and advice of counsel and other verification with the assistance representatives of Rogers Corporation My business address is Rogers Corporation P.O. Box Drive Rogers CT 06263-0188 188 One Technology am authorized to sign the forgoing Defendant Amended Responses to Plaintiff's Plaintif's Rogers Interrogatories in Corporation's Kovar v Rogers Corporation et al in the the matter of Jeff of Missouri Circuit Court City of St. Louis State While I do not have personal knowledge of all the facts they were prepared at my direction and recited in the Responses information and belief subject to are true inadvertent to the best of my knowledge not in possession or errors and limited by information undiscovered Consequently defendant make any changes in the Responses if it reserves the right to errors have been made therein that appears at any time that omissions or or more accurate information is available FURTHER AFFIANT SAYTH NAUGHT Terrence W. Mahoney | Rogers Corporation SUBSCRIBED and SWORN to before me by the Affiant on this 2nd day of *Mil Notary Public 5/31/18 My Commission expires 5/31/18 ROBERT ROBERT MCCARIOEM ROBERTROBERT MCCARIOEM NOTARY PUBLIC MCARIOEM STATE {5 3B STATE COMMISSION 3 } EXPIRES STATE 5/31/2018 CONNECTI 3 ; CONNECTI JulyJuly . 2014