Document rpazEYLny2B8bRXE1o5eG72ZJ

harolo A. qsncvan OCNNJ3 C- nose MICHACL. U NCSTt lDWARO ; R7.CV/CIYK CLARK - 3M:*H STCVCN G SAI.tV CA>'! . a *>*... r a CHARLES U. wT-CY Donovan. Robe. Nester & Szewczyk, P. C. Attqsmev* xt Law CAST WASHINGTON STREET Hcllxvtl-le, Ilunoxs Baaso- aiso October 14, 1987 Hon. Willard V. Portell Clerk of the Circuit Courts Madison County Courthouse Edwardsville, IL 62024 Re: Asbestos cases ARCA COOC 610 TCLCFHQNc iJS*3Q20 VINCENT U. HATCH cr* ccjns^ Dear Sir: Enclosed please find the following which we ask that you file: Complaint Answer Demand for Jury Trial Interrogatories Request to Produce Notice of Deposition Answers to Interrogatories Notice of Compliance Motion Original Retained Other () .( ) () () () () ( xxx ) { xxx ) () () () Check Enclosed () Very truly yours, DONOVAN, ROSE, NESTER & SZEWCZYK, P.C. MJN:cd Enclosure cc: Attorneys of Record IN THE CIRCUIT COURT THIRD JUDICIAL CIRCUIT MADISON COUNTY, ILLINOIS DONALD SINCLAIR, ROBERT SINCLAIR, AND GEORGE WENNER, ROY CARSON, BRUCE LUSK AND EDWARD MEINERS, ELAINE HARDISON ETC., WILLIAM ADAMS THROUGH LEWIS FLEURY, Plaintiffs, v. ANCHOR PACKING COMPANY, ET AL, Defendants. ) ) \ 86-L-451 86-L-450 86-L-453 86-L-824 86-L-836 86-L-1024 j 86-L-1827-86-L-2458 ) ) ) GENERAL OBJECTIONS TO INTERROGATORIES AND REQUEST TO PRODUCE Anchor Packing Co. sets forth the following General Objections to Plaintiff's Interrogatories and Request to Produce and incorporate each of these objections by reference to every response provided hereinafter: 1. The Interrogatories and Request to Produce are overly broad, unreasonably burdensome, harassing, cumbersome, vague, ambiguous and not intended nor reasonably calculated to lead to the discovery of admissible or relevant evidence. 2. The Interrogatories and Request to Produce are difficult to understand or unintelligible due to the use of particular phrases or terms which have more than one meaning within and without the industry.- 3. The Interrogatories and Request to Produce are of excessive depth in time, not being limited to the matters in dispute as said forth in the Complaint. The Interrogatories and Request to Produce go back many years in time and Anchor Packing Co. has found it difficult, and in some cases impossible, to reconstruct or retrieve the information requested. 4. The burden is upon plaintiffs to establish his exposure to products manufactured by Anchor Packing Co. in order to recover based on his allegations againsts Anchor Packing Co. . To the extent that plaintiffs have not identified any product of Anchor Packing Co. to which they have been exposed, the Interrogatories and Request to Produce herein are irrelevant and immaterial to any issue in this litigation and are not calculated to lead to the discovery of admissible evidence. Further, to require Anchor Packing Co. under such circumstances, to respond to questions requiring disclosure of masses of irrelevant information is beyond the scope of permissible discovery. 5. Not withstanding these objections. Anchor Packing Co. responds to the Interrogatories and Request to Produce based upon facts known or believed by Anchor Packing Co. at the time of it's answer pursuant to Court Order. These answers provided herein do not in any way waive the objections stated hereinabove. DONOVAN), ROSE, NESTER & SZEWCZ^K, P.C. 8 East Washington Street Belleville, Illinois 62220 (618)235-2020 IN THE CIRCUIT COURT THIRD JUDICIAL CIRCUIT MADISON COUNTY, ILLINOIS DONALD SINCLAIR, ROBERT SINCLAIR, AND GEORGE ) . WENNER, ) .ROY CARSON, BRUCE LUSK, AND EDWARD MEINERS, ) ELAINE HARDISON, SPEC. ADMINISTRATOR OF THE ) ESTATE OF LESLIE HARDISON, ) WILLIAM ADAMS, through LEWIS FLEURY, ) Plaintiffs, ) ) ) vs. ) ) ANCHOR PACKING COMPANY; A.P. GREEN REFRACTORIES ) CO.; A.W. CHESTERTON,INC.; ARMSTRONG WORLD .) INDUSTRIES, INC.;AMERICAN WIRE & CABLE; ATLAS ) ABESTOS; THE BABCOCK & WILCOX COMPANY; ) BENJAMIN FOSTER CO., DIVISION OF AMCHEM ) PRODUCTS, INC.;BIGLOW-LIPTAK CORP.; THE ) CARBORUNDUM COMPANY, INCORPORATED; THE CELOTEX ) CORPORATION; CERTAIN-TEED CORPORATION; CHARLES ) TAYLOR SONS CO.; CHICAGO FIRE BRICK COMPANY; ) CHRISTY FIREBRICK CO.; COMBUSTION ENGINEERING; ) CORHART REFRACTORIES COMPANY; CRANE PACKING ) COMPANY; CROWN CORK & SEAL COMPANY, INC.; ) DIDIER TAYLOR REFRACTORIES CORPORATION; EAGLE- ) PICHER INDUSTRIES, INC.; ELLIS SAFETY PRODUCTS ) CO.; FIBREBOARD CORPORATION; THE FLINTKOTE ) CORPORATION; GARLOCK, INC.; GENERAL REFRACTORIES) COMPANY; GENERAL ELECTRIC COMPANY; GEORGIA ) PACIFIC; GENERAL GASKET CORP.; GRANT WILSON, ) INC.; GUNNING REFRACTORIES, INC.; HARBISON- ) WALKER CORPORATION; HESTER-BRADLEY CO.; H.K. ) PORTER COMPANY; INTERNATIONAL INSULATION CO.; ) INTERNATIONAL VERMICULITE; J.H. FRANCE ) REFRACTORIES COMPANY;JOHN E. BRAZEE & CO.; ) J.P. BUSHNELL PACKING; KAISER REFRACTORIES, A ) DIVISION OF KAISER ALUMINUM & CHEMICAL ) CORPORATION; KEENE CORPORATION; KENNECOTT ) CORPORATION; KIMBALL SAFETY PRODUCTS; LACLEDE ) CHRISTY CORPORATION; LAWRENCE REFRACTORIES; ) M.A. BELL CO.; M.H. DETRICK COMPANY; MEXICO ) REFRACTORIES CO. ; MIDWESTERN SAFETY EQUIPMENT ) CO.; MINE SAFETY APPLIANCES COMPANY; ) MINNESOTA MINING AND MANUFACTURING COMPANY; ) MUNDET CORK COMPANY; NATIONAL ELECTRIC COIL CO.;) NATIONAL GYPSUM COMPANY; NATIONAL REFRACTORIES, ) INC.; NICOLET INDUSTRIES, INC.; NORTH AMERICAN ) REFRACTORIES COMPANY; OWENS-CORNING FIBREGLAS ) CORPORATION; OWENS-ILLINOIS, INC.; PFIZER, INC.;) PITTSBURGH CORNING CORPORATION; PLIBRICO ) COMPANY; QUIGLEY COMPANY; RAYMARK INDUSTRIES, ) INC.; THE ROCKBESTOS CC.; ROCK WOOL ) MANUFACTURING CO.; THE SAGER CORPORATION; ) SOUTHERN TEXTILE CORPORATION; SURFACE ) COMBUSTION; THERMIC REFRACTORIES, INC.; UNITED ) STATES GYPSUM COMPANY; U.S. MINERAL: W.R. GRACE;) WESTERN FIREBRICK CO.; WESTINGHOUSE ELECTRIC ) CORPORATION; WHEELER PROTECTIVE APPAREL, INC. ) WTSF.-FT. SANTO cn. } Nos. 86-L-451, 86-L-450, 86-L-453, 86-L-824,86-L-83 6, and 86-L-834 No. 86-L-1024 No. 86-L-1827 Through No. 86-L-2458 INTERROGATORIES TO DEFENDANTS 1U: ANCHOR PACKING COMPANY Please take notice that pursuant to Rule 213 of the Illinois Rules of Civil Procedure, you are required within Thirty (30) days after service hereof to serve upon the undersigned sworn answers to the following interrogatories. The defendant corporation or company shall designate an officer or agent to answer the interrogatories who shall answer the interrogatories by providing all of the information available to the organization whether the answering individual personally knows it or not. Each interrogatory is to be answered fully and separately. DEFINITIONS As used in these interrogatories: A. With respect to all questions, all information is to be divulged which is within the knowledge, possession or control of the corporation or company to whom these interrogatories are addressed, as well as the corporation or company's attorneys, investigators, agents, employees or other representatives. If you cannot answer the following interrogatories in full after exercising due diligence to secure the full information to do so, so state and answer to the extent possible, specifying your inability to answer the remainder, stating whatever information or knowledge you have concerning the unanswered portion and detailing what you did in attempting to secure the unknown information. B. "Defendant" includes the named defendant. C. "Documents" include, without limitation, books, records, writing, notes, letters, correspondence with whomever, memoranda and recordings in possession or control of defendant or defendant's attorneys, investigators, agents, or employees. Such reference to documents includes originals and copies, microfilms and transcripts made, recorded, produced or reproduced by any means and every means. "Documents" also includes the content of any applicable computer database. D. Where used with respect to documents, "identify" means to give the date, title, origin, author and addressee (where appropriate) to enable plaintiff to retrieve it from a file; and, further, "identify" means to give the name, address, position or title of the person who has custody of the document. Whenever identification is requested and defendant is willing to produce the documents voluntarily for inspection and copying without the necessity of plaintiff's filing a motion to produce, defendant may respond by stating when and where the document may be inspected, or by attaching a copy of the requested document to the answers to these interrogatories. E. Where appropriate, the singular includes the pleural and vice-versa. -2- You are to answer these interrogatories by placing your answers, when possible, in the spaces provided. INTERROGATORY NO. 1: As to the person answering these interrogatories, state: (a) Name; (b) Title or position with defendant; (c) Business Address; (d) Length of time employed by defendant; (e) State year by year all other positions titles or jobs that perssn has held with the defendant. (f) The years during which Defendants have been licensed to do business within the State of Illinois, or State of Missouri and with regard to such years please state: (1 ) The type of business conducted within the State of Illinois or State of Missouri; (2) The names and addresses of any franchise holders, dealers, or customers located in the State of Illinois or State of Missouri during the last three years; (3) Whether or not Defendant directly or indirectly supplies the persons or entities identified in 1.(f)(2) with any products or services; if so, please describe the relationship between Defendant and those persons or entities and state the approximate dollar value of Defendant's 1930 to present sales to them -3- these ANSWER: (a) David I. Muir (b) Vice President and Treasurer (c) One Buttonwood Square, Philadelphia, PA 19130 (d) 1971-Present (e) Secretary-1971-Present Treasurer-1971-Present . Vice President (Finance)-1982-Present (f) Anchor Packing is a Deleware Corporation with corporate headquarters in the City of Phila delphia, Pennsylvania. Defendant has sales/ INTERROGATORY WMfh?-1SeHafas citrhleityperinsonboathnswSet.rLinoguis, MO, and (con11) interrogatories made reasonable inquiry of all available sources of information such that plaintiff may rely on these answers as the truthful and complete answers made on behalf of this answering defendant? State the proper legal name and the present address of the principal place of business of each of defendant's related companies. For each related company identified, please state: (a) Whether or not the company is licensed to do business in the State of Illinois (b) The business relationship between the company and defendant; (c) The nature of the products or services that defendant sells to or purchases from the company; (d) The type of business the company conducts within the State of Illinois; (e) Whether or not the company advertises Defendant's products or services within the State of Illinois; (f) Whether or not the company sells defendant's products or services within the State of Illinois; and, if so, the approxi mate value of those sales or services during 1930 to present; -4- ANSWERS TO INTERROGATORIES 1(f) cont. Chicago, Illinois, as well as other cities nationally. These are offices from which salesmen operate and merchandise is shipped. Anchor merely distributes packing and sealing products, some of which contain asbestos. Such products are manufactured by others. Anchor in no way alters or changes the chemical composition or asbestos content of such products sold by it. The majority of these products were manufactured by Raymark Industries, Inc., formerly Raybestos-Manhattan, Inc., and more recently by Garlock, Inc. These products are generally sold directly by Anchor to industrial users. (g) Whether or not the company pays any type of taxes to the State of Illinois or any political body located within the State of I11inois: fh) Whether or not defendant has any control, directly or indirectly, over the company's advertising of defendant's products or services. ANSWER: See Answer to Interrogatory No. 1 INTERROGATORY NO. 3: State the following concerning this defendant: (a) Full and Correct name; (b) Principal place of business; (c) State of incorporation; (d) Date of incorporation, and name of Corporation; (e) Is this defendant authorized to transact business in the State of Illinois? If so, state the date such authority was first issued and last renewed; (f) Does this defendant have an agent, representative or place of business in Illinois? If so, state the name and address of such agent, representative, other place of business; or (g) Does this defendant have an agent for service in the State of Illinois? If so, state the name and address of the registered agent. -5- ANSWER: (a) (b) (c) (d) (e) (f) (g) The Anchor Packing Company One Buttonwood Square, Philadelphia, PA 19130 Delaware Approximately 1908, The Anchor Packing Compan Yes. Last renewal 2/7/85. Yes. The Anchor Packing Co., 999 Criss Circle Elk Grove Village, Illinois 60007 Yes. CT Corporate System, 208 South LaSalle Street, Chicago, Illinois 60604. INTERROGATORY NO. 4* Has this defendant been sued under its correct name? If not, state the correct legal name of the defendant and provide the information requested in No. 3 above concerning the defendant as correctly named. ANSWER: Yes. INTERROGATORY NO. 5` Has this defendant ever acquired through purchase, reorganization or merger another corporation, company, or business which manufactured, sold processed, distributed or contracted to apply asbestos products ? ANSWER: See Answer to Interrogatory No. 1. INTERROGATORY NO. 6: If the answer to Interrogatory No. 5 is "Yes", then state the following concerning such predecessor: -6- ( a ) Full and correct name; (b) The principal place of business; (c ) State of incorporation * (d) Date of ,acquisition by defendant; (e) Was this business authiorized to tr business in the State >of Illinois? (f) Attach ciopies of all papers pertai to the acquisition. ANSWER: see Answer to Interrogatory No. 1. 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; (a) No (b) No (c) No (d) Yes (e) Yes (f) No (g) Yes -7- T 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; Anchor sells asbestos containing products and sealing products which are manufactured by others and sold directly by Anchor to industrial users. A majority of these products were manufactured by Raymark Industries, Inc., formerly Raybestos- Manhattan, Inc., and more recently by Garlock, Inc this product line has been essentially unchanged from 1908 until 1986 when Anchor ceased distribute INTERROGATORY NO. 9` Have any of the products (cont.) listed above in Interrogatories No. 7 been altered in chemical composition since first being marketed? ANSWER: Anchor merely distributes packing and sealing products some of which contain asbestos. Such products are manufactured by others. Anchor in no way alters or changes the chemical composition or asbestos content of such products sold by it. Anchor has no knowledge as to any change in the composition of its products made by their manu facturers. INTERROGATORY NO. 10; If so, please state: (a) The trade name of each such product; (b) The date each such product was altered; (c) The nature of the alteration; (d) The reason for the alteration. ANSWER: N/A -8- ANSWERS TO INTERROGATORIES 8. cont. of asbestos containing products except certain sheet and gasket products. INTERROGATORY NO. 11: What is the name, address, and the job title of each individual who participated in the design and preparation of manufacturing specification for each such product? ANSWER: Anchor does not design its products. INTERROGATORY NO. 12 Do any written memoranda, specifications, blueprints or other written materials of any kind or character relating to the design and preparation of said products now exist? ANSWER: Anchor does not design its products. INTERROGATORY NO. 13: If so, please state: (a) List each written material or document; (b) Who presently has possession of each such document? (c) Where is it located? -9- its products. ANSWER: Anchor does not design INTERROGATORY NO. M: In what year did the defendant first begin selling or distributing anY products containin asbestos ? asbestos containing Anchor first began selling ANSWER: products in approximately 1908. INTERROGATORY NO. 15: In what year did the defendant last sell the any product which contained asbestos ? ANSWER: :hor is currently selling asbestos containi jducts limited to certain gasket and packin INTERROGATORY NO. 16: As to the named defendant or any predecessor(s) or acquired business, state the various types of products, such as blocks, pipe covering, -10- cements, tape, spray-on insulation, mastics, and cloth, or any other asbestos containing products and in connection with each type of such product, state how the same was packaged (i.e., bags, boxes, sacks, etc.) for sale. ANSWER: Anchor sells packing and sealing products, some of which contain asbestos. Anchor sells its products directly and primarily to industrial user and therefore, no retail packaging per se. Some asbestos containing products are sold in boxes which are black, pale blue, or orange. They may exhibit Anchor's emblem, the letter "A", in red. A white label on such boxes contains the style, INTERROGATORY NO. 17* Is your company, as of the (cont.) date of answering these interrogatories, still manufacturing, selling or distributing any products containing asbestos? If so, give the brand names of such products, the binding material and date first manufactured. ANSWER: see Answer to Interrogatories No. 15 & 16. See also defendant's Notice of Compliance. INTERROGATORY NO. 18: Were each of your asbestos containing products generally expected to reach, or were packaged to reach, the consumer or user, without substantial change in the condition in which it was sold? ANSWER: Yes. ANSWERS TO INTERROGATORIES 16. cont. size, and weight of the product contained therein. A white caution label is affixed to each box. Other products such as cut gaskets, are wrapped in brown paper and tied with a string, to which a caution label is affixed directly on to each sheet. INTERROGATORY NO. 19: If your answer to Interrogatory No. l8 is "No", with respect to any product, explain in what way the defendant claims its products were altered or substantially changed after sale or distribution and before reaching the helper, mechanic or bystander. ANSWER: N/A. INTERROGATORY NO. 20: Based upon the material contents of your products, the method of manufacturing, and the method of application, can your products be generally applied or installed without liberating asbestos fibers? (a) If there is a different answer concerning different products manufactured, sold, distributed, or used by your company then specify the different products by exact manufacturers name and popular name. (b) If there is a difference in your answer depending on the year or years in which a particular product was used, then specify in detail what year or years you are referring to and the specificic products you are referring to and the year involved. ANSWER: Yes. The asbestos containing products which Anchor distributes are generally encapsulated or lubricated in some manner. As a result, these products generally do not emit dust or fibers into the air. -12- INTERROGATORY NO. 21: Was it a foreseeable use of your asbestos containing products that they may have to be removed, stripped or replaced at any time after installation? If your company contends the plaintiff(s) misused any of your products then state how and under what circumstances your product was misused. ANSWER: Defendant has insufficient information at this time regarding misuse of the products by the plaintiffs. Defendant can only respond to this interrogatory in terms of specific products which have not yet been identified by the plaintiffs. INTERROGATORY NO. 22: Prior to releasing the asbestos products manufactured, sold, etc. to the public for sale, were any tests conducted on same to determine potential health hazards involved in the use of materials contained therein? ANSWER: No. Anchor's products are safe and non-hazardous for their normal and intended use. INTERROGATORY NO. 23: If so please state: (a) The name, address, and job classification of each individual who conducted such tests. (b) The results of such said tests. (c) Date of such studies. -13- ANSWER: N/A. INTERROGATORY NO. 24: Do any written memoranda, specifications, blueprints or other written materials of any kind or character exist relating to the testing of said product ? ANSWER: N/A INTERROGATORY NO. 25: If so, please state: (a) List each such written material or document. (b) Who presently has possession of each such document and where it is located. ANSWER: N/A -14- INTERROGATORY NO. 26: Did defendant or any of its subsidiary companies make any design changes as a result of such tests? ANSWER: No. INTERROGATORY NO. 27: If so, please state: (a) The nature of the change made. (b) The name, address, and job classification of each person in charge of making a change. ANSWER: N/A INTERROGATORY NO. 28: After releasing said products to the public, were any tests conducted thereon to determine potential health hazards involved in the use of materials contained therein? ANSWER: No. Anchor Packing does not know what tests may have been conducted by the manufacturer. INTERROGATORY NO. 29: If so, please state: (a) The name, address, and job classification of each person conducting said tests. -15- (b) The results of said tests. ANSWER: N/A INTERROGATORY NO. 30` Prior to 1970, did you or your predecessor(s) ever have any labor inspectors or anyone from your company whose job it was to go to areas where your products were being used or installed to make a dust level count? If so, state when this procedure started, the purpose of such procedure, and what action, if any, was taken in response to the findings, and attach results. ANSWER: No. INTERROGATORY NO. 31- If your company performed or had performed any dust level counts, what action based on the results did your company take? ANSWER: N/A INTERROGATORY NO. 32: Has your company or its predecessor(s) ever conducted any studies concerning the -16- effects of the inhalation of asbestos dust or fibers on one using or being exposed to any of the asbestos materials manufactured, sold or distributed by you, or your predecessor(s)? If answer to this question is "Yes", give the date and nature of such studies, if any; the name or names of the persons conducting such studies and their addresses; what the purpose of the studies were; and attach a copy of any reports based upon such studies, showing to whom such reports were given, and the date. ANSWER: No. ~ INTERROGATORY NO. 33= Has your company or its predecessor(s) ever conducted or caused to be conducted any studies designed to minimize or eliminate the inhalation of asbestos dust and fibers by those exposed to the use of your company's asbestos products? If so, give the following: (a) Name of the person or firm conducting such studies. (b) The date the studies began and the date completed. (c) Any publication or dissemination of the results of the studies. (d) The nature of any action to eliminate or minimize inhalation of asbestos dust or fibers. (e) Attach copies. -17- ANSWER: No. INTERROGATORY NO. 34: If your answer to Interrogatory No. 33 is "Yes", state the name and address of * such industrial hygienist or hygienists. ANSWER: N/A INTERROGATORY NO. 35 Does your company have, has it ever had, or has your predecessor(s) ever had, a Research Department? If so, give the year such Research Department was established, and whether or not such Research Department has operated continuously since being established. (a) How much expended each year on research, etc. (b) What percentage of gross sales did your company or its predecessor(s) spend on research concerning the health affects of asbestos. -18- ANSWER: No. INTERROGATORY NO. 36: Prior to 1965, did your company, or any predecessor(s), ever at any time give persons who would be applying or removing your asbestos products instructions concerning safety precautions to use in applying such products? If so, describe such instructions, to whom they were given, the dates they were given, and the manner of giving such instructions. ANSWER: Anchor primarily sells asbestos containing packinc and sealing products to industrial users who purchase such products for intended purposes. No special instructions, therefore, are provided. INTERROGATORY NO, 37: Did your company, or your predecessor(s), ever place any warning signs on the containers in which asbestos products were packaged? ANSWER: Yes. -19- INTERROGATORY NO. 3$' If you have answered Interrogatory No. 37 in the affirmative, please state: (a) On what date did your company, or your predecessor(s), issue an order directing a warning be placed on your asbestos products, or containers? (b) On what date was such warning actually first placed on your asbestos products or containers? (c) On what date did your asbestos products, accompanied by such warning, first reach the contractor? (d) State the exact wording of the first warning. (e) State the exact size of the warning printed on your asbestos products or container. (f) Did your company, or its predecessor(s) dictate the exact size of the printed warning? , (g) Why did your company or its predecessor(s) place such warning on your asbestos products or containers? (h) Did your company or its predecessor(s) place such warning on your asbestos . products or containers because you received a directive, command, suggestion, legal opinion, or any type of communication (written or otherwise) from any person, firm, corporation, governmental agency, committee, association, attorney or institute? If so, from whom and on what date did you receive such directive, command, suggestion, legal opinion, or other type of communication. (i) If the wording of the warning has ever been changed or altered, state when it was changed and the exact change in the wording. ANSWER: (a-i) At a meeting of the Fluid Sealing Asso. in approximately March, 1975, facsimilies of a caution label were distributed. Anchor then began to affix caution or warning labels onto the packages of its asbestos containing products and directly onto sheet packing. The original caution label read as follows: (cont.) INTERROGATORY NO. 39: Did your company or its predecessor(s) ever place any warning directly on any of its asbestos pipe covering, block, cloth, millboard or other asbestos products? ANSWER: See Answer to Interrogatory No. 38. INTERROGATORY NO. 40: Did your company ever stamp the name of the company, its initials, or any identifying logo on any of its asbestos pipe covering, blocks, cloth, millboard or other asbestos product? ANSWER: gee Answer to Interrogatory No. 38. INTERROGATORY NO. 41: Did the warning inquired about in Interrogatories 39 and 40, or similar warning, ever appear in any of your sales literature? If so, attach copies of such sales literature, showing the date such literature was printed. ANSWERS TO INTERROGATORIES 38 (a-i) cont. "Important. Asbestos hazard. Do not breathe dust. Do not use airhose machine without dust collection equipment. Do use vacuum or wet cleaning methods to dispose of dust in sealed container. Do wear mask if unable to avoid dust." In 1980 caution label was revised to read as follows "Caution. This product contains asbestos fibers. Persons handling this product should avoid breathing dust. Breathing asbestos dust may cause cancer or other serious bodily harm." In 1986 the caution lahel was revised to read as follows: "Danger. This product contains asbestos fibers. Persons handling this product should avoid creating dust. Breathing asbestos dust is a cancer and lung disease hazard." ANSWER: See Notice of Compliance. INTERROGATORY NO. 42: On what date was the sales literature inquired about in Interrogatory No. 41 first provided to distributors or sellers of your company's asbestos products, or your predecessor(s)1s products? ANSWER: 1981 INTERROGATORY NO. 43* Were any material safety data sheets ever prepared by your company or its predecessor(s ) ? If so, attach copies. ANSWER: No. INTERROGATORY NO. 44: Did your company or its predecessor(s) ever recall any products containing asbestos from the common market? (a) State all details of such recall, giving the name of the product, the time of recall and any further action taken in connection with the recall. Unknown at this time. ANSWER: Investigation continuing. INTERROGATORY NO. 45= Has your company or its predecessor(s) ever directly advised any contractor to whom you sell your products containing asbestos of threshold limit values for exposure to asbestos dust recomended by the American Conference of Governmental Industrial Hygienists? If so, state the date or dates that you so advised such contractors, the manner in which you advised such contractor, and the name of each contractor. ANSWER; No. Anchor sells to industrial users and not to contractors. INTERROGATORY NO. 46; Prior to 1964 did your company or its predecessor(s) ever manufacture products containing asbestos without a warning? List the years. ANSWER: No. Anchor has never manufactured asbestos containing products. Anchor is not a manufacturer Anchor merely distributes packing and sealing products, some of which contain asbestos. -23- INTERROGATORY NO. 47: After 1964 did you ever manufacture products containing asbestos without a warning? If so, list the name of the product and the years. ANSWER: Anchor is not a manufacturer. Anchor merely distributes packing and sealing products, some of which contain asbestos. INTERROGATORY NO. 48: Is your company, as of the date of answering these interrogatories, still manufacturing, selling or distributing any products containing asbestos? If so, give the brand names of such products and the binding material and dates of first manufacture of such product. ANSWER: Anchor is not a manufacturer. Anchor merely distributes packing and sealing products, some of which contain asbestos. See Notice of Compliance INTERROGATORY NO. 49: Did your company or any predecessor(s) ever have a division or subsidiary company engaged in the contracting business of applying asbestos products? If so, give the name of such division or subsidiary company, the full address of the home office of such division or subsidiary company, and the dates such division or subsidiary company was engaged in the contracting business. -24- ANSWER: No. INTERRROGATORY NO. $0: Did any division of your company or subsidiary company engaged in the contract business of applying asbestos products or your workmen's compensation insurance carrier ever have any claims for lung diseases or death from lung diseases, whether directly or * indirectly attributed to asbestosis, mesothelioma, lung cancer, or any exposure to asbestos products prior to 1972? If the answer is "Yes", give the name of such employees and attach copies of such claims and copies of all documents relating to the disposition and handling of such claims. ANSWER: Pursuant to Court Order no response to this interrogatory is required. INTERROGATORY NO. 51: Give the location of the state industrial accident board handling each such claim, the disposition of such claims, and the amounts paid in workmen's compensation benefits to each such employee, and the name of the compensation carrier. -25- ANSWER: Pursuant to Court Order no response to this interrogatory is required. INTERROGATORY NO. 52: Did your company or its predecessor(s) ever make any industrial hygiene surveys concerning it's asbestos products? If so, give the date of such surveys, and attach copies of such surveys. ANSWER: No. INTERROGATORY NO. 53: State the year that this defendant or any predecessor(s) was first advised of either threshold limit values or maximum allowable concentrations of both asbestos dust and total dust by the American Conference of Governmental Industrial Hygienists, and state the name of the employee-official of the company receiving such advise and attach copies of the instrument communicating such advise. ANSWER: Anchor was never advised of either threshold limit values or maximum allowable concentrations of both asbestos dust and total dust by the American Conference of Governmental Industrial Hygienists. -26- INTERROGATORY NO. 54: Was such threshold limit values or maximum allowable concentrations inquired about in Interrogatory No. 53 TOTAL dust and not just asbestos dust? ANSWER: N/A INTERROGATORY NO. 55= State in detail what test, if any, your company ever made with** regard to the quantity, quality or threshold limit values or asbestos dust or particules to which applicators or consumers of your product were exposed while using your products containing asbestos. (a) If there were any such tests or studies, give the name or names of the person(s) conducting the tests, the date of the tests and attach true copies of any reports, findings or mem orandums concerning such tests or studies. ANSWER: None. -27- J INTERROGATORY NO. 56: When did any official with your company first have knowledge, information or understanding that asbestos would or could or might produce the diseases of: (a) Asbestosis; (b) Mesothelioma; (c) Lung cancer; (d) Any other diseases; (e) With reference to your company give the name of such official who first had such knowledge list them and attach copies. (f) If there are any documents, records or memorandums of any kind concerning such knowledge, list them and attach copies. ANSWER: Pursuant to Court Order no response to this interrogatory is required. INTERROGATORY NO. 57: Do you have any photographs of the products inquired about above or their packages or containers? If so, please attach exact copies. ANSWER: See Notice of Compliance. continuing. Investigation is -28- INTERROGATORY NO. 5 : Has the answering defendant or any of it-s predecessors ever mined asbestos? If so, state the dates in which such mining too place and the locations of the mines. ANSWER: No. -29- INTERROGATORY NO. 59: List, by brand name every product containing asbestos which defendant or defendant's predecessors has manufactured since 1910. As to each such product, please state the following: (a) The type of product (e.g., acoustical Plaster, fireproofing, concrete, etc.); (b) The date the product first went into production; (c) (d) The date the product was discontinued from production; k The last date the product was sold; (e) All manufacturing locations of the product; (f) The identity of the plant manager(s) or managing agent(s) of defendant who has knowledge of the products manufactured by defendant and its predecessor(s), and who may be called upon by plaintiffs to testify by deposition. ANSWER: Anchor did not manufacture asbestos containing products. INTERROGATORY NO. 60: As to each product identified in response to the foregoing interrogatory please indicate: (a) The type of asbestos contained in the product as it was first manufactured; (b) The percentage of asbestos contained in the product as it was first manufactured; -30- (c) Any modifications to the product which altered the percentage or type of asbestos in the product and the dates of such modification; (d) The source of asbestos in each product; (e) The color, physical characteristics, and appearance of each product; (f) A full and complete descritpion of the package in which the product was sold, including, but not limited to, type of package, size, color(s), and writings thereon; (g) All other names under which the product was sold; (h) The number and date of each patent or patent application 3fs to the product; (i) If the product continued to be produced after the deletion of asbestos, all reasons why the asbestos was deleted, the identity of the person who made the decision to delete the asbestos, and the date the product was first produced without the asbestos; (j) If the product is no longer produced, all reasons it was discontinued, the identity of the person who made the decision to dis continue the product, the brand name of replacement product, and the date the replacement product first went into production; (k) The identity of the custodian, managing agent, or employee who has photographs, drawings, or labels for each product;, (l) The reasons why asbestos was used as an ingredient in each such product; (m) The content of any warning labels, inserts or other writings provided with such product with ever such printed warning, what period of time it has or had accompanied the product, the exact wording of the warning, any amendments made to the -31- the wording, whether the warning was located on each product or packaging, what asbestos products the warnings appea r(ed) ; and on (n) Any special instructions provided with such product regarding the use. protection or safety procedures to be employed by persons handling such product. ANSWER; N/A INTERROGATORY NO. 61: With respect to your Answer in Interrogatory No. 60, did you specifically inform the purchaser or user of your products during the same time period that your products were manufactured and sold that, such products could cause cancer, asbestosis, and other serious diseases? ANSWER: Anchor denies that its products caused such disease. INTERROGATORY NO. 62: Identify the distribution chain of defendant's asbestos products since 1925 along with any documents evidencing or confirming such chain, including but not limited to distribution from and to other defendants . -32- ANSWER: Anchor sold its products directly to industrial users. See Notice of Coraplaince regarding sales to industrial users identified in plaintiff's Interrogatories since 1981. Defendant does not have records of such sales pre-dating 1981. INTERROGATORY NO. 63: Identify your distributors and/or suppliers of raw asbestos, asbestos cement and other asbestos products with which you had business contact. ANSWER: Pursuant to Court Order no response to this interrogatory is required. INTERROGATORY NO. 64: Is this defendant aware or has it possessed knowledge concerning the reported causal connection between exposure to asbestos or asbestos products and : (a) asbestosis? (b) lung cancer? (c) mesothelioma? (c) other cancer? ANSWER: Anchor denies its products caused such diseases. INTERROGATORY NO. 65: If answer to preceding Interrogatory as to any or all of its subparts, is in the affirmative, identify: (a) When and how defendant first learned of such connection; (b) If knowledge was obtained by attendance at any conference, lecture, convention, symposium or meeting, identify such meeting and provide the identity of persons attending and documents obtained; (c) (d) If knowledge was obtained from medical or scientific studies, or any other published work, identify same; , If otherwise obtained, identify manner of receipt of document or communication. ANSWER: Not applicable INTERROGATORY NO. 66: With regard to any knowledge obtained subsequent to that identified in your answer to Interrogatory 65 (a) above, identify: (a) All documents or communications, oral or written, concerning the causal connection between exposure to asbestos or asbestos products and disease, and identity of persons so communicating; (b) Did answering defendant obtain from or transmit any such information to other defendants in this case? If so, identify: (1) Manner of receipt or communication for each contact; -34- (2) All documents and persons involved, ANSWER: Not applicable. INTERROGATORY NO. 67: As to any knowledge possessed by answerin g defendant at any time referred to in your answer to Interr ogatory 64, did you educate your employees, distributo rs or purchasers of the hazards known to you and the safety precautions necessary to guard against cancer and other dise ases arising from the use and handling of your products? If so, identify: (a) When and in what manner customers, insulators, factory workers and the general public were so informed; (b) Documents communicating or otherwise dis seminating such information; (c) Programs initiated or sponsored to establish or promote safety procedures, methods or usage of equipment; (d) Published articles or reports by employees (present or prior), including those of medical directors, scientists, engineers or other professionals; (e) Symposia or lectures sponsored for the benefit of asbestos workers and/or the general public. -35- ANSWER: Not Applicable. INTERROGATORY NO. 68: When and by what manner were you first aware of the hazards relating to exposure to asbestos or asbestos products: (a) (b) For inside insulators and contractors. For outside insulators and contractors. ANSWER: Anchor has never sold insulation products INTERROGATORY NO. 69: If you have knowledge or information concerning the following, answer in the affirmative or negative, whether: (a) Early detection of mesothelioma results in any appreciable rate of cure or arrest; (b) A single exposure to asbestos may cause mesothelioma, other cancers or asbestosis; (c) Cumulative or multiple exposures to asbestos result in a greater risk of harm to the exposed person; (d) An outside insulator has a risk of harm from exposure to asbestos or asbestos products; -36- (e) Stripping or removing old asbestos creates a greater risk of harm than installation of asbestos or asbestos products; (f) Cancer resulting from exposure to asbestos develops generally after: ( 1 ) 1-5 years. ( 2) 6-10 years. (3 ) 11-20 years. (g) There is any known relationship between smoking and mesothelioma; (h) There is any reported cause of mesothelioma other than exposure to asbestos. ANSWER: Pursuant to Court Order no response to this interrogatory is required. INTERROGATORY NO. 70: As to each answer to Interrogatory 69, identify at least one person or document upon which answering defendant relies. ANSWER: Pursuant to Court Order no response to this interrogatory is required. INTERROGATORY NO. 71: Did you perform, direct to be performed, finance, sponsor or receive the results of any studies or tests concerning the relationship between asbestos exposure and asbestosis and/or cancer? If so, identify : -37- (a) When, where and at. what intervals such studies were performed; (b) Were such studies in writing or reported at a later date in writing; (c) Were the results of such studies published or otherwise disseminated? If so, state to whom and when; (d) Who performed such studies; (e) Will you produce the results of such studies at this time or state where the results are maintained. ANSWER: No. INTERROGATORY NO. 72 Identify the scientific or medical periodicals to which defendant, its medical department or industrial hygiene division subscribed from 1925 to the present, and the dates of such subscriptions. ANSWER: Pursuant to Court Order no response to this interrogatory is required. INTERROGATORY NO. 73 Did defendant, its medical department or industrial hygiene division maintain a medical and/or scientific library at any time from 1925 to the present? If so, state: -38- (a) The dates such library existed; (b) The number of volumes maintained therein; (c) The number of employees, part-time or full-time, assigned to maintenance of library, and to whom in the corporate structure those employees report(ed). said ANSWER: No. INTERROGATORY NO. 74: Identify all trade organizations, associations, or other entities, including but not limited to A.T.I., I.H.F., N.I.M.A., A.I.A., N.I.C.A., T.I.M.A., Q.A.M.A., P.I.C.A., or Q.A.P.A., to which you have belonged or in which you have participated since 1925, stating the applicable dates of such membership or participation. ANSWER: Defendant is unsure what all of the initials in the above organizations stand for. INTERROGATORY NO. 75: Identify all persons attending on your behalf any meetings held by trade organizations, associations, or other entities identified in answer to Interrogatory No. 74* -39- ANSWER Pursuant to Court Order no response to this interrogatory is required. INTERROGATORY NO. 76: Identify the names or nature of all notes, reports, studies, or other writings submitted by you or received by you at meetings held by organizations described in answer to Interrogatory No. 74- ANSWER See Answer to Interrogatories No. 74. INTERROGATORY NO. 77: Identify any documents received by you from or submitted by you to those trade organizations, associations or other entities identified in answer to Interrogatory No. 74 relating to the relationship between asbestos exposure and disease. ANSWER: See Answer to Interrogatory No. 74. In addition, see Answer to Interrogatory No. 38. INTERROGATORY NO. 78: Identify all agreements, oral or written, between you, any of the other defendants in this lawsuit, and/or any other organizations, associations or other entities identified in your answer to the Interrogatory No. 74 or anv medical or scientific foundations, relating to the standardization of: (a) Specifications for asbestos cloth products; (b) Specifications for paper or burlap bags, or other packaging to be used for the trans port and/or storage of asbestos cement; (c) Warning or caution labels to be applied to asbestos products and/or their packaging, cartons, containers, or boxes; (d) Methods of dissemination of public rela tions information ter defendant's purchasers, advertisers, distributors, factory workers, contractors, insulators, users, consumers of asbestos products and/or the general public; (e) Safety equipment and/or protective clothing to be utilized while handling defendant's asbestos products; (f) Medical programs to be offered or sponsored by defendant. ANSWER: None. INTERROGATORY NO.79: Did you direct to be performed, sponsor, finance, receive the results of or were you aware of any studies or tests performed by the Saranac Lake Laboratory of the Trudeau Foundation relating to asbestos exposure and its effects upon human life? If so, identify: -41 - (a) All documents summarizing findings or results of those studies or tests which you have in your possession or control; (b) All communications, oral or written, between answering defendant and Saranac personnel, including but not limited to Gerrit W.H. Schepers, M.D. (c) All documents relating to Saranac studies received or submitted by you either directly, though associated or predecessor companies, through other companies, or through any trade associations, organizations or other entities; (d) . All recommendations or findings of such . studies relating to: (1) Adequacy or inadequacy of threshold limit values; (2) Substitution of materials other than asbestos to be used in the insulation process. (e) Where documents and/or communications identified in answers to (a)-(d) of this Interrogatory are maintained. ANSWER: No. -42- INTERROGATORY NO. bO: How many employees of answering defendant are known by defendant to be suffering from, have suffered from or whose deaths have been caused by asbestosis? State the date such disease of any employee was first known by defendant. ANSWER: Pursuant to Court Order no response to this interrogatory is required. INTERROGATORY NO. 8l: H<3w many employees of answering defendant are known by defendant to be suffering from, have suffered from or whose deaths have been caused by lung cancer? State the date such disease of any employees was first known by defendant. ANSWER: Pursuant to Court Order no response to this interrogatory is required. INTERROGATORY NO. 82: How many employees of answering defendant are known by defendant to be suffering from, have suffered from or whose deaths have been caused by mesothelioma? State the date such disease of any employee was first known by defendant. ANSWER: Pursuant to Court Order no response to this interrogatory is required. -43- INTERROGATORY NO. 83* Do you send or have you at any time sent counsel or other representatives to courses at defending asbestos cases? If so, identify. ANSWER: Pursuant to Court Order no response to this interrogatory is required. INTERROGATORY NO. 84: Identify all expert witnesses who have testified in other cases, pending or * * otherwise, on behalf of answering defendant. ANSWER: None. INTERROGATORY NO. 85: Identify all present or former employees or answering defendant, other than plaintiffs, who have testified against this defendant in a litigation matter or before a governmental agency or unit. ANSWER: None. INTERROGATORY NO. 86: With respect to your answers to Interrogatories No. 84 and 85, identify all documents, including but not limited to transcripts or notes -44- of testimony employed by or resulting from the testimony of such expert witnesses or employees. ANSWER: None. INTERROGATORY NO. 87: Identify: (a) Any expert whom you intend to call as a witness or otherwise utilize in connection with this litigation; (b) The subject matter on which the expert is expected to testify; (c) The substance of the facts and opinions to which the expert is expected to testify; (d) A summary of the grounds for each opinion; (e) The address of such person and his field or expertise; (f) Identify and produce each treatise, article or text upon whether the expert will rely in his testimony. ANSWER: Pursuant to Court Order no response to this interrogatory is required. INTERROGATORY NO. 88: Identify and produce all board meeting minutes at which asbestos products, the hazards of asbestos exposure, the possible application of warning labels on a asbestos containing products were discussed by the Board of Directors of your company. ANSWER: Unknown at this time. continuing. Investigation INTERROGATORY NO. 89: Please identify by name, address and phone number each person who has provided this answering party with statements in connection with this litigation. ' ANSWER: See Answer to Interrogatory No. 1. Anchor objects to this interrogatory insofar as it request privileged and work product information. INTERROGATORY NO. 90; Please identify each person who has been interviewed in the course of preparing for the trial of this matter. ANSWER: Pursuant to Court Order, no response to this Interrogatory is required. -46- INTERROGATORY NO. 91: Has this De f endant ever sold any asbestos c o n t a ining product s to Ins u 1 ation and Material Company o f St. Louis, Misso uri or a ny other individu al, corpor at ion . partnership or othe r busine ss entities within a 100 m ile radius of Madison County, Illinois since 192 0 i nc luding but no t 1imite d to St. Lou i s County, St. Louis City, St . Charles County, Missouri or Madison County or St . C lair County, Illinois , if so state : a) List all individuals, corporat ions , partnerships or other busi ness ent it ies you have sold asbestos containing products to . b) Stat e all dates when a sbestos containi ng products were sold to thes e entiti es . c) Stat e wha t asbestos co ntaining product s were sold to these entities and identify by brand name. . d) State what quantity of asbestos products were sold to these entities. e) Provide copies of all purchase orders, specifications, contracts or correspondence with the entities identified in a) above or otherwise identify all documents relating to the sale. ANSWER: See Notice of Compliance. No such records are available prior to 1981. -47- INTERROGATORY NO-92: Have you ever sold any asbestos containing products to: Monsanto, East St. Louis, Illinois Marathon Oil Refinery, Robinson, Illinois Shell Oil Company,Refinery,Roxana Illinois Amoco Refinery, Wood River, Illinois Clark Oil Company Refinery, Hartford, Illinois Granite City Steel, Granite City, Illinois Illinois Power Company (Alton Powerhouse) Central Illinois Power Service (Coffeen Powerhouse) Commonwealth Edison (Kinkaid Powerhouse) Illinois Power Company (Portage Des Sioux Powerhouse) Central Illinois Power Service (Meredosia Powerhouse) Illinois Power Company (Grant Fork Powerhouse) Owens-Illinois Glass Co., Alton, Illinois Central Illinois Power Service (Baldwin Powerhouse) Central Illinois Power Service (Pearle Powerhouse) Central Illinois Power Service (Marion Powerhouse) Central Illinois Power Service (Newton Powerhouse) Texaco Oil Company Refinery, Lawrenceville, Illinois American Steel, Granite City, Illinois Cerro Copper, Granite City, Illinois Consolidated Aluminum Company, Granite City, Illinois Olin Corporation, East Alton, Illinois Laclede Steel Company, Alton, Illinois Sinclair Oil Refinery, Hartford, Illinois Apex Oil Refinery, Hartford, Illinois and if so: a) List all individuals, corporations, partnerships, or other business entities you have sold asbestos containing products to. b) State all dates when asbestos containing products were sold to these entitites. c) State what asbestos containing products were sold to these entities and identify by brand name. -48- d) State what quantity of asbestos containing products were sold to these entities. e) Provide copies of all purchase orders, specifications, contracts or correspondence with the entities identified in a) above or otherwise identify all documents relating to the sale. ANSWER: See Notice of Compliance. No such records are available prior to 1981. INTERROGATORY NO. 93: Has this defendant ever been a General Contractor or Subcontractor where it used asbestos containing products at any of the following locations: Monsanto, East St. Louis, Illinois Marathon Oil Refinery, Robinson, Illinois Shell Oil Company Refinery, Wood River, Illinois Amoco Refinery, Wood River, Illinois Clark Oil Company Refinery, Hartford, Illinois Granite City Steel, Granite City, Illinois Illinois Power Company (Alton Powerhouse) Central Illinois Power Service (Coffeen Powerhouse) Commonweath Edison (Kinkaid Powerhouse) Illinois Power Company (Portage Des Sioux Powerhouse) Central Illinois Power Service (Meredosia Powerhouse) Illinois Power Company (Grant Fork Powerhouse) Owens-Illinois Glass Company, Alton, Illinois Central Illinois Power Service (Baldwin Powerhouse) Central Illinois Power Service (Pearle Powerhouse) Central Illinois Power Service (Marion Powerhouse) Central Illinois Power Service (Newton Powerhouse) -49- V '* Texaco 0iL Company Refinery, LawrenceviLle, Illinois American Steel, Granite City, Illinois Cerro Copper. Granite City, Illinois Consolidated Aluminum Company, Granite City, 111inois Oiin Corporation, East Alton, Illinois Laclede Steel Company, Alton, Illinois Sinclair Oil Refinery, Hartford, Illinois Apex Oil Refinery, Hartford, Illinois and, if so: a) List all individuals, corporations, partnerships or other business entities you have sold, asbestos containing products to. b) State all dates when asbestos containing products were sold to these entities c) State what asbestos containing products were sold to these entities and identify by brand name. d) State what quantity of asbestos products were sold to these entitites. e) Provide copies of all purchase orders, specifications, contracts or correspondence with the entities identified in a) above or otherwise identify all documents relating to the sale. ANSWER: See Notice of Compliance. No such records are available prior to 1981. INTERROGATORY NO. 94: Did this defendant ever provide any warning concerning the hazzards of asbestos to any of the following companies: Monsanto, East St. Louis, Illinois, -50- -r Marathon Oil Refinery. Robinson, Illinois Shell Oil Company Refinery, Wood River, Illinois Amoco Refinery, Wood River, Illinois Clark Oil Company Refinery, Wood River, Illinois Granite City Steel, Granite City, Illinois Illinois Power Company (Alton Powerhouse) Central Illinois Power Service (Coffeen Powerhouse) Commonwealth Edison (Kinkaid Powerhouse) Illinois Power Company (Portage Des Sioux Powerhouse) Central Illinois Power Service (Meredosia Powerhouse) Illinois Power Company (Grant Fork Powerhouse) Owens-Illinois Glass Co., Alton, Illinois Central Illinois Power Service (Baldwin Powerhouse) Central Illinois Power Service (Pearle Powerhouse) ,, Central Illinois Power Service (Marion Powerhouse) Central Illinois Power Service (Newton Powerhouse) Texaco Oil Company Refinery, Lawrenceville, Illinois American Steel Company, Granite City, Illinois Cerro Copper, Granite City, Illinois Consolidated Aluminum Company, Granite City, Illinois Olin Corporation, East Alton, Illinois Laclede Steel, Alton, Illinois Sinclair Oil Refinery, Hartford, Illinois Apex Oil Refinery, Hartford, Illinois If so, identify what the warning was, how the warning was delivered and when the warning was delivered. Provide copy of warning and correspondence concerning the warning. ANSWER: ' See previous Answers to Interrogatories. See Notice of Compliance. INTERROGATORY 95* Has this defendant ever had any -51- I * correspondence with any of the following companies or facilities concerning products containing asbestos: Mon sant o , East St. Louis . I 11inois Mar athon Oil Refinery, R ob i nson , I Hi noi s She 11 Oi 1 Company Refine ry, Wood R iver, Illinois Amo co Re finery, Wood Riv er , I11ino i s Cla rk 0i 1 Company Refine ry , Hartfo rd, 11 1inois Gra nite City Steel, Gran i te City , I11ino is 111 inois Power Company ( Alt on Powe rhouse ) Cen t ral Illinois Power S erv ice (Co f f een Powerhouse ) Commonwealth Edison (Kinkaid Powerhouse) Illinois Power Company (Portage Des Sioux Powerhouse ) Central Illinois Power Service (Meredosia Powerhouse) * Illinois Power Company (Grant Fork Powerhouse) Owens-Illinois Glass Co.., Alton, Illinois Central Illinois Power Service (Baldwin Powerhouse) Central Illinois Power Service (Pearle Powerhouse) Central Illinois Power Service (Marion Powerhouse) Central Illinois Power Service (Newton Powerhouse) Texaco Oil Company Refinery, Lawrenceville, Illinois American Steel Company, Granite City, Illinois Cerro Copper, Granite City, Illinois Consolidated Aluminum Company, Granite City, Illinois Olin Corporation, East Alton, Illinois Laclede Steel Company, Alton, Illinois Sinclair Oil Refinery, Hartford, Illinois Apex Oil Refinery, Hartford, Illinois If so provide copy of any correspondence with any of the above companies concerning asbestos containing products. ANSWER: None known at this time. . continuing. Investigation ANCHOR PACKING COMPANY 8 East Washington Street Belleville, Illinois 62220 1-618-235-2020 -53-