Document v1Rpe5jVy8Lx3YJkoDOoXOOjZ

'OCk^- <B 6* - "C- V 3PARA DID #* . AH ____ ri ; ' P.eCEiVf^ PATRICK J. HAGAN, ESQ. (State Bar #68264) E. JANE WELLS, ESQ. (State Bar #112178) DILLINGHAM & MURPHY 225 Bush Street, Sixth Floor San Francisco, CA 94104-4207 (415) 397-2700 JUL 2 3 1997 BRAYTON HARl~ ' -"--c _ HAND___OVERNion i ___ Attorneys for Defendant 3" POS, KAISER GYPSUM COMPANY, INC. VERIF -^Sv. LDF _ rrsrr^c ____ SUPERIOR COURT FOR THE STATE OF CALIFORNIA 9 FOR THE COUNTY OF SAN FRANCISCO PLAINTIFF'S EXHIBIT 10 IN RE: SAN FRANCISCO COUNTY COMPLEX ASBESTOS LITIGATION CASE NO. 828684 KG-386 KAISER GYPSUM COMPANY, INC.'S RESPONSES TO PLAINTIFFS' STANDARD INTERROGATORIES TO ALL DEFENDANTS PROPOUNDING PARTY : Plaintiffs ' RESPONDING PARTY : Defendant Kaiser Gypsum Company, Inc. SET : Standard . DATE : COMES NOW defendant Kaiser Gypsum Company, Inc. (hereinafter "Kaiser Gypsum"), and provides the following responses to Plaintiffs' Standard Interrogatories To All Defendants propounded pursuant to San Francisco County Complex Asbestos Litigation General Order No. 129: KAISER GYPSUM'S PRELIMINARY STATEMENT Kaiser Gypsum submits this preliminary statement to memorialize certain steps taken to implement the standard discovery regime adopted pursuant to the revised General Orders filed November 15, 1996 governing asbestos-related personal injury q-l- II Additionally, Kaiser Gypsum Technical Bulletins 5703-A, dated October 1973, 2 and 5707, dated October 1973 and November 1976, prescribed the use of respirators 3 during spray application, 4 B. Yes. 5 C. Beginning in 1972; exact date unknown. 6 D. This caution label remained the same during the remaining time the products 7 upon which it was used continued to use asbestos 9s a component. 8 E. Joseph R. Hobby, Vice President, 2680 Bishop Drive, San Ramon, 9 California. 10 RESPONSE TO INTERROGATORY NQ.-38: 11 Most of Kaiser Gypsum's products were sold in the form of a powder or paste; 12 therefore, the name of the company was on the packaging of the product. However, 13 Kaiser Gypsum's 2-hour fire-rated ceiling tiles and suspended ceiling lay-in board 14 products (in which asbestos was used as a component were specially marked because 15 they looked similar to other Kaiser Gypsum mineral fiberboard ceiling tiles and lay-in 16 boards (that did not contain asbestos as a component) and building inspectors wanted 17 to be able to check to make sure that 2-hour fire-rated products actually were being 18 used by the building contractor when those had been specified. It is believed that each 19 piece of 2-hour fire-rated ceiling tile and suspended ceiling lay-in board was stamped 20 on the back with either the initial "KG" or the word "Kaiser Gypsum." Such marking was 21 employed during the entire period that the 2-hour fire-rated products were 22 manufactured by Kaiser Gypsum. 23 RESPONSE TO INTERROGATORY NO, 39: . 24 Kaiser Gypsum has no knowledge that it ever purchased or otherwise acquired 25 an asbestos-containing product line from another person or entity. 26 RESPONSE TO INTERROGATORY NQ._4Ql 27 j Kaiser Gypsum has no knowledge that it ever sold an asbestos-containing 28 product line to another person or entity. -49-