Document r69B5zEwLjJLQ0jJyKDDXwVYa

FILE NAME DuPont DUP DATE 1993 DOC DUP091 DOCUMENT DESCRIPTION Legal - Supplemental Answers to Interrogatories by D.P. MacMurray 3/24/93 IN THE SUPERIOR COURT OF THE STATE OF DELAWARE IN AND FOR NEW CASTLE COUNTY DANIEL P. MACMURRAY Indivi- OO dually and as Executor of the : Estate of MABEL P. MACMURRAY 80 8H Plaintiff 90 65 : 68 E. I. DUPONT DE NEMOURS & : COMPANY INC et al 80 26 Defendants OO Asbestos DANIEL P. MACMURRAY AS EXECUTOR OF THE ESTATE OF MABEL P. MACMURRAY SUPPLEMENTAL ANSWERS TO INTERROGATORIES DIRECTED TO MABEL P. MACMURRAY BY ALL DEFENDANTS 11. With respect to any products containing asbestos manufactured packaged furnished supplied or sold by each defen- dant named in this action that you claimed to have worked with or around state the following for each defendant a The name of the product or products ANSWER In addition to plaintiff's previous answers plaintiff Daniel MacMurray believes he was also exposed to asbestos as follows Mr. MacMurray helped develop a DuPont product which contained asbestos During the late 1950s or early 1960s while Mr. MacMurray was working at the DuPont Engineering Development Laboratory he worked with a DuPont product known as polyimide where with the help of Mr. Ewing he combined raw asbestos with polyimide to make a brake block After he learned this product was resistant to heat he came up with the idea of using it as a binder in asbestos friction products to prevent break fade It is Mr. MacMurray's understanding that this procedure was later patented and that in the late 1960s DuPont opened a plant in Glasgow to make products with polyimide resins During the time periods when Mr. MacMurray lived in Wilmington Delaware with his wife she would be exposed each evening to the asbestos he brought home on his clothing as well as each time she washed the clothes he wore while working with asbestos It is Mr. MacMurray's understanding that at the DuPont Buffalo New York River Road Plant in the early 1960s there was a process in which Tedlar film was used as a laminate for wallboards containing asbestos supplied by Manville Mr. MacMurray was present during the use of Tedlar at the DuPont Buffalo New York plant during the early 1960s During this time Mr. MacMurray was involved with a plastic product called celuseal in the area where the Tedlar lamination work was being done While he was working at the DuPont Buffalo plant where he was exposed to asbestos he regularly returned home to Wilmington Delaware every weekend He routinely took his asbestos contaminated clothing home which would be washed by his wife Mr. MacMurray also was exposed to the asbestos used in the wadding for shotgun shells used in Remington firearms at the DuPont Bridgeport Connecticut plant where he worked for 2 years While he was working at the DuPont Bridgeport Connecticut plant where he was exposed to asbestos he regularly returned home to Wilmington Delaware every weekend He routinely took his asbestos contaminated clothing home which would be washed by his wife He also was exposed to asbestos by the use of asbestos gloves in the Forge Shop where he made modifications to a rolling 2 mill for forging shotgun and rifle barrels at the Remington Arms Ilion New York plant He now understands asbestos was used in the manufacture of nylon stocks for Remington firearms at the Remington Ilion New York plant but presently is unaware that he was exposed to asbestos during this process Mrs. MacMurray lived with him in Ilion New York During the time periods when Mr. MacMurray lived in Ilion New York with his wife she would be exposed each evening to the asbestos he brought home on his clothing as well as each time she washed the clothes he wore while working with asbestos At all of the locations Mr. MacMurray worked no special precautions were taken or special clothing was worn by him when working with asbestos In addition two different containing tile samples of tile Mr. MacMurray installed in his home which he referred to in his deposition have been analyzed The attached report reveals that they did indeed contain asbestos During his deposition Mr. MacMurray described his exposure to asbestos insulation at various DuPont plants An example of this is contained in the pictures from the DuPont Spruance plant in Richmond Virginia which Mr. MacMurray has just found See attached pictures Finally plaintiff s counsel is now aware that DuPont used raw asbestos in the manufacture of the following products and Mr. MacMurray and his counsel are presently investigatng into whether he and therefore his wife may have been exposed to asbestos as a result of their operations 1. Paint films 2 3 4 laboratory Radiator stop leak products Cement block primers a paint like material Undetermined products in the elastomers 5. As a component of talc an ingredient in DuPont paints and primers JACOBS & CRUMPLAR P.A. Cumpara Cumpara By Thomas C. CumparCuampara Thomas C. Crumplar 2 East 7th Street P.O. Box 1271 Wilmington DE 19899 302 656-5445 Attorney for Plaintiffs Date 5/24/93 MCMURYSU.SW rad