Document wqY2joaEE0Q7N6a9ye0w2r5r6

PLAINTIFFS EXHIBIT GF-653 IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR DADE COUNTY, FLORIDA GENERAL JURISDICTION DIVISION CASE NO. 80-9227 JOHN L. GORDON, et ux. , Plaintiffs, vs. JOHNS-MANVILLE SALES CORPORATION, et al., Defendants. ) ) ) ' ) GAF CORPORATION ANSWERS TO PLAINTIFFS INTERROGATORIES COMES NOW, Defendant GAF Corporation by and through its undersigned attorney and files its answers to Plaintiffs Interrogatories filed March 6, 1981, as follows: CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing Defendant, GAF Corporation Answers to Plaintiffs Interrogatories was mailed this / / day of April, 1981, to all counsel on the attached mailing list. FOWLER, WHITE, BURNETT, HURLEY, BANICK & STRICKROOT, P.A. Attorneys for GAF Corporation City National Bank Building 5th Floor 25 West Flagler Street Miami, Florida 33130 (305) 358-6550 By: ^Uxrlin Thomas F. Martin A BCQFtS Ounces OF FOWLtP WHITE. BL'ON CTT. hurJe>. ban JCK & S"PiCKRO5T - ASSOCIATION. Fifth FlOCP CITv national Bank EcMLCins. viami.FLOFIDa 33130 PRELIMINARY STATEMENT GAF Corporation rejects the Preliminary Statement o the Plaintiff. GAF CORPORATION answers these Interrogatories in accordance with, and only in accordance with/ the Florida Rules of Civil Procedure. Proposed Answers; 1. On May 26, 1967, GAF merged with the Ruberoid Co., a New Jersey Corporation. Ruberoid began the manufacturer of industrial thermal insulation products containing asbestos in late 1920's or early 1930's. 2a, c and d. "Calsilite". A high temperature pipe covering and built-in block containing'approximately 10 percent amosite asbestos fiber and the remaining consisting of hydrous lime silicate and diatamaceous earth. Calsilite was manufactured at Gloucester, New Jersey, from the early 1940's until mid 1970 at which time GAF commenced the production of asbestosfree Calsilite ("Calsilite II"). Calsilite was intended to withstand up to 1,200 degress Fahrenheit. "115" and "214 Insulating Cements". Known generically as 7K and 7K cements, respectively, these insulating cements were composed entirely of chrysotile asbestos fibre. These cements were manufactured at Hyde Park, Vermont, from 1936, through September 1975. "T/NA-100" Insulation Jacketing. A two-ply, laminated product consisting of a layer of asbestos paper in which chrysotile asbestos fibers were bonded with Neoprene and a layer of polyvinyl fluoride (Tedlar) plastic film attached by adhesive on one side. T/NA-100 was manufactured at South Bound Brook, New Jersey, from 1962 to September 1971. TNA-100 was designed to withstand temperatures of 100 to 200 degrees Fahrenheit. Asbestos Paper and Millboard. Chrysotile insulating paper, used as a jacketing or pipe wrap; manufactured at Erie, Pennsylvania, from approximately 1928. Millboard was used primarily as an industrial fire barrier. Most Ruberoid and GAF industrial thermal insulation products were sold in corrugated cardboard boxes bearing the companies' respective names or "logos". The insulating cement was sold in heavy duty bags. For warning language; See Answer to Interrogatory No. 7. The specific descriptive language, if any, appearing on the package is unknown, except to the extent that the trade name of the product did appear thereon. I t .. 2b. Calsilite, 10% amosite and 2% chrysotile fiber; 115 and 214 Insulation Cements, 100'. chrysotile fiber; T/NA-100 Insulation Jacketing, 40% chrysotile fiber; Asbestos Paper and Millboard, asbestos fiber content varies from 20% to 40% chrysotile. 2e. Dry ingredients, principally asbestos fibers, silica sand and Portland cement, are measured and mixed with water. The mix or slurry is piped to a series of vats, in each of which a cylinder covered with wire mesh rotates slowly. As the cylinder turns, a layer of fibers and cement is deposited onto the wire mesh face, and, in turn, is pressed onto an endless felt cloth belt moving above the cylinder; the belt travels from cylinder to cylinder picking up a layer of slurry from each to give a lamination of several layers. When the moving belt has passed over all cylinders, the sheet clinging to it is partially dried by suction and then is pressed onto an accumlator drum. On this revolving drum, the sheet is further laminated up to desired thickness and then is cut off, after which it is conveyed under a series of gas burners which remove more water'. 3. GAP recalls that Ruberoid packaged 8-S for Johns-Manville in 1948 or 1949. 4. 8-S, an asbestos waste product, was a gray sand. 5. Neither Ruberoid Corporation nor GAF Corporation had facilities or equipment designed for medical research and therefore conducted no tests or studies of the nature specified. 6. GAP Corporation sold Calsilite. to the following entities in Florida as follows: COMPANY JOBSITE YEAR A . C St S . Merritt Island 1964 Adamo Insulation Tampa 1965 Davidson Chemical Ridgewood 1965 Ebasco Services Pt. Everglades 1965 George L. Simonds Tampa 1965 Foster Wheeler Tollsom 1965 A C. St S . Jacksonville Merritt Island 1965 Riley Stoker East Tampa 1965 Bighan Insulating & Supply Ft. Lauderdale 1965 Lakeview Siding Ft. Lauderdale 1965 Coleman Insulation Lake Worth 1965 U.S. Sugar Corp. Canal Point 1965 National Cork Pensacola 1965 Adamo Inc. Occidental 1966 l Abamo Insulation Occidental Corp. Hudson Pulp & Paper Bigham Insulating & Supply Lakeview Siding Pratt & Whitnev Aircraft National Cork Bigham Insulating & Supply Lakeview Siding Adamo Insulation Gulf & Western American Corp. Western 'Electric A.C. & S. Tompkins & Beckwirth Rec Off Direct Turn over Lakeview Siding Florida Power Corp. A.C. & S . Bigham Insulating & Supply Eagle-Picher Indus. Babcock & Wilcox Great Barrier Insul. T _tmpa Fort St. Joe Crystal River Occidental /' Palatka Ft. Lauderdale . Ft.Lauderdale * Ft. Lauderdale Pensacola Ft. Lauderdale Ft. Lauderdale Tampa Tampa Florida CityJ acksonville Savannah i Jacksonville Yukon Ft. Lauderdale Red Level Junction Jacksonville Pensacola Ft. Lauderdale Cincinnati Gainesville Tallahassee 1966 1966 1966 1966 1966 1966 1966 1969 1969 1970 1970 1970 1970 1970 1970 1970 1970 1971 1971 1971 1971 1971 In approximately 1965 Ruberoid began placing warning notice on the packaging of its industrial products which contained asbestos. * ft have reed the foregoing Answers tc Interrogatories end'dc swsar thai fey are true anc correct to the best of my knowledge anc belief. STATE Os <J l_ COUNTY CT/Z-a-t-s who swears and deposes that he has read the Answers to Interrogatories and that same are true and correct to the best of his knowledge and belief. to and subscribed before me this 19 ol ^ day of tv Commission Exoires: SEAL CIRTIFICATE or SERVICE I HEREBY" CER7IEY that a true copy of the foregoing Answers tc Interrogatories was mailed this ______________ day of 19 to: FOWLER, WHITE, BURNETT, HURLEY, BANTCK & STRICKROOT, P.A. CITY NATIONAL, BANK BUILDING 5 th'"Floor" Miami, Florida 33130 (305) 358-6550 By Thomas F. Martin Attornevs for GAJ Corocration High, Stack, Lazenby, Bender, Palahach & Lacasa PENTHOUSE, SUITE 3000 IOO NORTH BISCAYNE BOULEVARD Miami, Flohida 33133 ATTORNEYS AT LAW vid 1204 NORTH HARBOR CITY BOULEVARD Melbourne, Florida 3203s ROBERT KING HIGH 0924*1967) CHARLES R. STACK ROBERT A. LAZENBY GEORGE C. BENDER MICHAEL PALAHACH, ZH ARMANDO E. LACASA G. KIRK HAAS R. SCOTT BOUNOY STEPHEN S. NUELL RICHARD E. TEJERA April 28, 1981 OF COUNSEL ALVIN S. CAWN MIAMI TELEPHONE (305) 377*3351 CABLE ADDRESS ROBHI MELBOURNE TELEPHONE (305) 254-2123 Please Reply to: y Rodger Wilson, Esq. Johns-Manville Corp. Ken Caryl Ranch Denver, Colorado 80217 rr> t^3 f*-' ro |i te ,, 'i,*' i 4 n * yr> **->, f r- > r MAY 4 1931 Re: Gordon v. Johns-Manville Dear Rodger: Enclosed is a copy of the Answers to Interrogatories which were filed by GAF Corporation in the above captioned matter. y yours. GCB/dkt Enclosure cc: Lively Wilson, Esq. Elizabeth Slack Ronald J. Sheeran For the Firm