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1953 Directory of Memberships and Representatives Name of Association Division Membership Position of Gompeiiy Representative Renre ssr.-Uvtl'va In Organization Academy of Political Science E, & C. Div. C. D. Ulmer Advertising Club of Baltimore Metal Products J. L, Tunstead Advisory Council on Federal Reports Aircraft Owners & Pilots Assn Air Pollution & Smoke Prevention Assn, of America Washington Off. G. W. Naylor Metal Products S, H, Fedan W, F. Perkins Metal Products Edward Salner Akron Rubber Group Chemical Division.!. W. Pool, Jr. Alabama Lumberman's Club Wood Preserving S, L. Taylor Alabama Road Builders Assn. Tar Products F. G. Owen, Sr. H. A. Van Orman Allegheny County Bar Assn. i Law Dept. ' . C, M. Crick J. M. Crimmins T. H. Hamilton B. A. Horn, Jr. E, S, Ruffin, Jr. Templeton Smith Allegheny Regional Advisory Board Traf. & Trans, J. F. Haley Members of the John B. Keeler Exec. Committee Allied Railway Supply Assn Metal Products J. E. Onnen American Arbitration Assn Koppers General V. H, Viot American Assn, for the Advancement of Science Tar Products E. & C. Div. E. 0. Rhodes C. D. Ulmer American Assn, of Textile Chemists and Colorists Chemical Div. J. F. Corwin Indiv. M'brship. American Bar Assn. Research Dept. Law Dept, Dr. Monacelli C. M. Crick Also member of Tax Section, J. M. Crimmin3 Also member of Anti-Trust Sect, T. H, Hamilton Also member of Corp., Banking & Business Law Sec, B,. A. Horn, Jr. E. S. Ruffin, Jr. SC-BE-01025 Name of Association American Bureau of ShipDing American Ceramic Society American Chemical Society American Chemical Society, Div. of Gas & Fuel Chemistry. American Coke S: Coal Chemicals Institute. Division Membership Company Representative Position of Representative In Organization E. St C. Div. Research Dept.' R. L. Cuthbert C. R, Austin Certified Marine Chemist. Chemical Div, Era & Cf Gas St Coke Div. Metal Products Research Dept. Tar Products Wood Pres. Div. 0. F. Winans Indiv. M*brship. A. J, Abrams F. A. B?-:idre J. L. Bradley c. V, Clsrke R. L. Irvine R. E. Petty E. V. Schulte w. E1. Simmat B, Smith B. F. Tatterson C. D. Ulmer H. J. Meredith F. R..Winter Dr . D'Alelio Dr . Thiessen Rubber Chemistry Division. E. C, Rhodes Local & National W. H. Carter National R. C. Stroraquist 11 R. H, Bescher Tar Products E. 0. Rhodes Chemical Div. ] fic C Div 4 Gas St Coke Div, (Brooklyn) (Pittsburgh) (Minnesota) (Seaboard) Law Department Sales Dept. Tar Products Traf. & Trans. D. M. Rugg Indiv, M'brship. J. H. Taussig, Jr. C. D. Ulmer G. P. Wilson, Jr. H. F, Fisher L* C. Biery M. T, Herreid J. E. Spears A. W. Lundquist H. R. Wesenberg K. R. Hare P, C. McConnaughey, Member of Domestic Coke Committee. . Member, Joint Anthracite & Bituminous Coal St Coke Committee. J, M, Spees J. M. Crimrains D. feeArthur Indiv. M1 brahip. H. B, Cummings T. H. Bartholomew J. D. Saylor C. R. Willetts CoalChemi Comm. J. B. Keeler TrafficCommittee -2 - Name of Association Division Membershid Position of Company Representative Reoresentative In Organization American Concrete Assn. E. & C. Div. R. A. Jewett American Economic Assn, Sales Dept., E. & C. Div. F, M. Garfield Indiv. M'brship. G. T) _ [iijTvJ American Electroplaters Society Metal Products R, -- o American Forest Products Industries Wood Pres. Div> R, H F'-iloy P,. r,-iA American Forestry Assn. Wood Pres. Div. R, K, L'.llev American Foundrymen's Society Gas St Coke Div. (Minnesota) (Seaboard) (Pittsburgh) Metal Products Production A, W. L.vcdouist H- R, Fr-aak Parsons, Jr,, Committee, M: rUv Twin Gity Chapter J. E, Spsars F, Aj Nevhart Educational Comm R. Di Biagio s. r.' itur.p J- v? r Srcusa J. K, Redmond American Gas Association Chemical Div. D,, K,, Rigg Indiv. M'brship. E. & C. Div. Wo Mo Africa Josspli Becker R. Berg E. N. Button G. E. Hake S. H. Klmmel W, A. Leech Hr V, Nelson E. Preston J. A. Slater J. H, Taussig, Jr. J. van Ackeren C. D. Ulmer Gas & Coke Div. M. T. Herreid (Pittsburgh) J. E. Spears M- W Gaylord (Seaboard) H: J,, Meredith j, M- Spore,. Chairman, Carboni zation & Coke Comm. Metal Products .G, C, i-faff. Builders sub-comm. J.. L. Tunstoaa Production Dept, Fred DerJ.g Research Dept A, R; FcWfeTl Sales Dept, M. W. C-reene Indiv. M'brship. Tar Products H, 3, Cummings r?. H. Bartholomew J. D. Saylor H. E. Crane J. E. B. Gibbons W, R. T. Thornhill G. E. Boyd -3- Maine of Association Division Membership American Institute of Accountants E. & C, Div. Position of Company Representative Representative In Organization H. A, Semler American Institute of Chemical Engineers Chemical Div, B7J,,C, van der Hoeven, Indiv, M'brship. E, & C, Div, A, J ,, Ahr'Sjjio J> M, A\rg'od Jr. Member C.. \i, C:,arjce C i W, y-j.a har E,, J. ^.xi Mi Joser.i-.ans Jo O ? u.'o XpU Jr. Rfember, Treasurer, Pgh. Section. R. L- Irvine , H, i\ Maurice . G, A, Onehuuidro E; Prsstion National & Pgh. Section. E, V, Schulte B. Smitn.. Jr.. Member Production Dept. Richard S, Rhodes, Member and on National Program ' Committee. Research Dept. D'Alelio Tar Products E, 0, Rhodes American Institute of Electrical Engineers Chemical Div. E. & C. Div. A. A, Sellers Indiv. Mforship, G. T, Bruun J. B, Castellano, Student Mbr. H, H. Douglass Gordon Fox Daniel Hemmander, Asso, Kbr. J. L, Hewett E. H. Lehman, Assof Mbr. Buel McNeil G. A. folio R. 0. Parker, Asso, Mbr. G. F; Ross P.A.3. Sg':u3 Hi W, R.-,r.vol J, W. White Av J. Whiceromb American Institute of Management Control Section T: J, pfc.Gin.ils E. & C. Div, R. L.. Irvi.ve Gas & Coke Div, J, E. Spears American Institute of Mechanical Engineers E. & C, Liv. Cv;en Rice .J 4- - Mama of Association Division Membership Position of Company Representative Representative In Jrganizatlon American Institute of Mining & Metallurgical Engineers E. fit C. Div. Research Dent A, J, Abrams Gordon R. 9aer R. A. Blackburn W, B. Clemmitt R. E. Nagel H. Naismith V. A, Leech Dr. Mathesiua F. W. Rys Dr. A, R. Powell American Iron and Steel Institute Chemiaal Div. D. M. Rugg E. fit C. Div. Joseph Becker R. Berg G. M. Carvlin L. A, Kraemer J. van Ackeren Production Dept. Fred Denig Research Dept. C, R. Austin Indiv. M'brship. American Leather Chemists' Assn. Chemical Div. J. F. Corwin Research Dept. Dr. Thiessen Indiv, M'brship. American Legion wood Pres. Div. J. H. Bade, Finney R. M. Killey, Charleston American Management Association Finance Dept, E. A. Berry Finance Council Insurance SecticnH. H, Hook Ins urance Div, Industrial Rela. Gen, Somervell N. L. Scanlon A. C. Tolson V. H. Viot M. S, Griffith Sales Dept. Cooke Bausman, Jr. Amerioan Junketing Association Sales Dept. B. J. Korb M. W. Greene F. M. Garfield R. E. Garvin T. C. Parker L. W. Adams Director Chairman, Co, M'brship Comm. Indiv. M'brship ii n ii ii ii ii American Materials Handling Soc. Matal Products R. C. Wetter E. E. Seibert Pres. Balti.Chap. I^feetings Comm. American Mining Congress Wood Pres. Div. D. C. Smith American Ordnance Association E, fit C. Div. Gas & Coke Div. Hoppers Gen. Metal Products R. Berg M. T, Herreid J. H, Redmond J. L, Tunstead Name of Association Division Membership Position of Company Representative Re oresentative In Organization American Patent Law Association Research Dept. Dr- W. J, Pbiiacelli American Petroleum Institute E, & C, Div. G, M- Cejvlin American Petroleum Institute- Tar Products Ht E. Crane Member Advisory Council. JcE.B. Gibbons American Plant Food Council Tar Products American Ptilp & Paper Mill Super-* Metal Products intendents Assn. J. K. Carpenter C., G. Franklin E. A. Salner A, Swanson J. L. Tunstead American Railway Bridge & Building Assn0 Wood Pres. Div. R,, H, Bescher American Railway Engineering Assn. Tar Products J. N, Roche E, 0, Rhodes Wood Pres. Div. R,, H. Bescher American Road Builders Assn, Tar Products American Society of Ceramics ' E, & C. Div. F. C, Foy E. 0. Rhodes M. D. Chamberlain P. F. Phelan E. F, Bennett Chairman, Comm, on Soil Compac tion. R. A. Taylor Director, Chair- man-Comm. on Tar Stabilized Roads W. Mathesius,Jr. American Society of Civil Engrs. E. & C. Div. American Society of Corporate Secretaries Franki Founda tion Company Law Dept. American Society of Engineering Education. E, & C. Div. J, M. Durfee Jr. Member C. J, Gialdini J, R. Hess L. J, Jolmson R. D,, Loadman Jr. tfember L. L. Murray Jr. Member T. M. Osborne W. P, Eckert Arthur J. Bulger E. S, Ruffin, Jr., also member of Securities Committee. T. H. Hamilton (Alternate) Pgh< R, A. Jewett Hame of Association American Society of Heating and Ventilating Engineers. American Society of Lubrication Engineers American Society of Mechanical Engineers Division MembershiD Position of Company Representative Representative In Organization E, fie C. Div. R. A. Merck- Frank! FoundationR. A. Biggs Chemical DivisionH. F, Seubert Indiv. M'brship - '- Chemical Div, A. A. Sellers Indiv. M'brship E. & C, Div. H, R. Bartlebaugh C. W. Clarke W, B. Clemmitt R. P. Dodds, Exec. Comm., Pgh. R. L. Irvine 4. A. Morally . C. E. Mielke F. W. Rys Metal Products J. L. Worthington, Exec. Comm., Chairman, Meetings & Pap ers Comm.-Oil fit Gas Power Division. F. W. Cooke Production Dept. Fred Denig Research Dept, Dr. Powell American Society for Metals E, & C. Diy. Mstal Products Dr. ffethesius W. Mathesiu3, Jr. J. P. Colleran J. W. Pennington G. F. Hyde , American Society of Naval Engrs. Metal Products J. A, Worthington American Society for Quality Control Metal Products W, J. Aring Membership Comm. Local Chapter, American Society of Safety Engineers E. fit C, Div, F. R. Griffin H. B, Wallace Gas fit Coke Div. E. C.. Riplinger (Seaboard) I. Trimmer Tar Products R, C. Bauer Chairman, M1 br- ship. Committee Wood Pres. Div, D. C. Smith R. M. Killey, Charleston American Society of Testing Materials Chemical Div -7 - E. E. Kimmel E. T. Wolford Sub-comra, Plastics T. H. Insinger, Jr., Sub-comra. Plastics, Phthalic Anhydride. O.K.M. Winne Sub-comm, - Ad hesives . R. F, Seubert Sub-comm. - In sulating Oile and Lubricating Oils. Name of Association American Society of Testing I'&terials (continued) DIvision tfembership Position of Company Representative Representative In Organization E. & C. Div, R P, Dodds Franki FoundationR, A. Biggs Metal Froducts G, V. Middaugh Gj Fc Hyue Production Dept J. G. Bradshaw Research Dept. Dr.- Thiesseu Coram. Member Tar Products E- 0. Fr.odes, Committee D~4, Road and Paving Materials. M., Gc 5turrock - Committee D-4, Road and Paving Materials. Subcommittees of D-4; B--5 Softening Pointy B-6Exiraction and Recovery of Constituents from Bituminous Mixtures} B-7 Viscosity and Float Tests; B-17 Emulsion Tests; B-19 Accelerated Tests for Durability of Bituminous M&terials;B-21 Solubility Tests; B-26 Effect of Water on Bituminous Coated Aggregates; C-2 Tar Pro ducts ; C-ll Road-Mix Bituminous Surfaces and Bases; C-13 Bituminous Paving Plant ODerations Subcommittee of D-7, Wood VI Timber Preservatives Subcommittee of E-l, Methods of Testing 9 Rheological Properties. Task Group on ffethods and Apparatus for Absolute Viscosity Measurements; D-16, In dustrial Aromatic Hydrocarbons Subcommittees of D-16: A Monocyclic Aromatics B Polycyclic Aromatics C Phenolic Compounds D Nitrogen Heterocyclics W, F. Fair, Jr.- Committee D-l, Paint, Varnish, Lacquer and Related Products Subcommittees of D-l III Bituminous Emulsions XXIX Painting of Metals Committee D-8, Bituminous Waterproofing and Roofing Materials. Advisory Committee, Sub committees of D-8. IV tfembrane, Waterproofing and Built-Up Roofing, V Bituminous Cutback Coatings for Cold Applications (Chairman) VIII Accelerated Tests on Roofing Materials. ' IX Bituminous Emulsions XIII Stain Properties of Bituminous Materials; Committee E-l Methods of Testing Subcommittees of E-I. 9 Rheological Proper ties- Cno.irman (Rep D-8) Task Group on Soft ening Po 'r.t, Task Group on Nfethods and Apr.-." rat us "or Absolute Viscosity ^asure- mcrt:- Name of Association Division Membership Position of Company Representative Representative In Organization American Society of Testing Materials (continued) Tar Products (continued) E. F. Bennett Committee D-18 Soils for Engineering Purposes Subcommittee of D-18. R-4 Chairman-Physical Proper ties of Soils. R-8 Special and Construction Control Test3 Section B Subgrades for Highways and Airports, R-9 Dynamic Properties of Soil Group S--Specifications and Me thods of Tests, P. F. Fhelan Committee D-18 Soils for Engineering Purposes Subcommittee H--3 Jtiysical Characteristics of Soil Section C. Moisture Content and Density. R-5 Structural Properties of Soil Section B Direct Shear Rr8 Special and Construction Control Tests Section D Stabil ization with admixtures Group S^pecifications and Methods of Tests Wood Pres. Div. R. H, Bescher American Society of Tool Engineers Metal Products B. Hamilton E, L, Russell Production Dept, J. H. Redmond Chairman Consti tution and by laws Committee. American Society of Traffic and Transportation Traf& Trans, J, F. Haley J. B. Keeler E. A. Gorges American Society of Training Directors ' Tar Products R. B. Weidlein Indus, Relations L, A. Allen D. D. Hicks J. R. Blair E, J. Martin R. F. Dean S, Hobbs Secretary American Standards Association,Inc.Koppers General K, E, Miller Gas St Coke M, W. Gaylord Production Dept. K. E. Miller Co. membership Name of Association Division Membership Position of Company Representative Representative In Organization American-Turkish Society Ko ppe rs-Ge ne ral T. M. Quito mo American Water Works Assn, Tar Products H, E. Crane G, E. Boyd S. J. Ka'.;3 M. G. Starrock Steel Water Pipe Manufacturers Technical Advis ory Committee. American Welding Society E, St C. Div. Matal Products J. L. Lynd3 J. H. Burnley F. Scharf E. Wirth American Wood Preservers Assn. A.W.P.A. Expense - Convention Research Dept. Tar Products Wood Pres. Div. (Texarkana) (Kansas City) {Philadelphia) (Newport) (Houston) (Ruseell) (Finney) (Baltimore) (New York) (Pittsburgh) (Charleston) (Orrville) (Mantgomery) Dr. Goldstein F, C. Foy J. C. Macon D, S. Snow M. G. Sturrock M. D. Gill J. N. Fencil D. D. Hamilton S. J. Katz E. 0. Rhodes J. T. Tierney F. G, Owen J. N. Roche, Special Committee on Fundamental Research on Hydro Carbon Oils as Wood Preservatives. Member of the Board of the Service Bureau. E. J, McGehee, Chairman, Comm. of Specifications. M. F. Cravey Comm. 12. C. F. Seyer R. H. Devine C, C. Calvin M, A. Hamrick J. W. Sullivan R. A. Piepho J. H. Bade M. R, Clifton D. F, Taylerson D. C. Smith R. M, Killey R. H, Bescher S. L, Taylor E. J. McGehee Anthracite Club of Suburban Essex Gas & Coke A-- J. Dressel F. L. Demraert Area Contractors Assn, Port Arthur,E, & C. Div. W, S. Scherffius Name of Association Division Membership Position of Company Representative Representative In Organization Armed Forces Chemical Association Chemical Div. T, C. Keeling,JrIndiv.M'brship Ashland Toastmasters Club Wood Pres. Div. R. A. Piepho Asphalt Roofing Industry Bureau Tar Products D. D. Hamilton, Coram. Built-up Roofing OPS Advisory Coram. J, A. Seifert Associated Industries of Alabama Tar Products F. G. Owen, Sr. Associated Industries of Missouri Tar Products T 0. Thiebes Assn, of Commerce, Superior Wood Pres, Div. S, G. McGla3son Assn, of General Contractors of America Tar Products H. E, Crane Assn, of Highway Officials of North Atlantic States Tar Products No one person designated Assn, of Iron and Steel Engineers E. & C. Div. Assn, of Iron and Steel Engineers Metal Products G. T, Braun F. W. Barrett D. Carle 0. C. Callow W. B, Ferguson A. B, Fisher, Jr. Gordon Fox L. J, Hough Daniel Lillemoen Dr. fcfethesius R. K. Matthews J. F. Mieler J. M* Orris W. G. Schofield D. C. Skinner J, A. Slater L. F. Staubitz A, J. Whitecomb, Dist, Sec. H. C. Monroe Assn, of National Advertisers,Ino. Public Relations Ralph Winslow Baltimore Assn, of Commerce Metal Products W. F. Perkins Director Baltimore Jr. Assn, of Commerce tfetal Products R. W. Dorsey Bergen County Fuel Merchants Assn, Gas & Coke Div. T. J. Leather T. Dodds Bibliographical Society of America E, & C. Div,; C. D, Ulmer Public Relations Committee, Blacktop Roads Assn. Tar Products T. G. Nicholson - li - 4285 Name of Association Division MomhorshiD Company Rfioresentative Position of Representative In Organization Blast Furnace and Coke Oven Assn. (Chicago district) E. & C. Div. Metal Products Gas & Coke Div. Gordon Baer Joseph Becker G, M. Carvlin C. W, Dillman Gordon Fox A. B. Fisher, Jr. H. W, Fricke S. H. Kimmel L, A. Kraemer R, K. Matthews H. W. Maurice Dr,. Mathesius W, W, McWhorter E, Preston Owen. Rice ' R. J. Sprott R, B. Stannard R. W. Vollmer 0. P. Wilson, Jr, F. F. Wise E. V. Harlow M. T. Herreid M. W Gaylord Boston Better Business Bureau Tar Products M. D, Gill British Assn, for the Advancement of Science E. & C. Div. C. D. Ulmer British Institute of Fuel,London E, & C, Div. R. Berg British Institute of ffetals Metal Products J. J, Brenza British Wood Preservers Assn. Tar Products F. C. Foy R. R. Holmes E, 0, Rhodes Building Owners & Managers Assn. of Pittsburgh Finance Dept. J. B, Sellers J. L, Ralston H. A. Biber Rental Committee Business & Professional Lecturer Wood Pres. Div, J, H, Bade Oroup 4285 ' Canadian Gas Association Tar Products W. F. Croft E. & C. Division J. H. Taussig, Jr., Delegate Canadian Manufacturing Assn. Tar Products W. F. Croft R. A. Munson Canadian Water Works Assn. Tar Products W. F. Croft Carolina's Roofing & Sheet Metal Salesmen's Assn. Tar Products - 12 - F. G. Gwen, Sr W. R. Hawkins Name of Association Division Membership .. Position of Company Representative Representative In Organization Central N. J. Fuel Exchange Gas & Coke A. J. Dressel Alexandria Wood Pres, Div, E. L. O'Neill Bergen County Gas St Coke T. J. Leather Birmingham Tar Products Boston Tar Products F. G. Curen, Sr. M. D. Gill Brooklyn Gas St Coke H. F, Fisher L. C. Eiery W, J, Brandenburg Buffalo Tar Products J. N. Curry Butler Chemical Div, C, D. Burton California Tar Products G. E. Traut Berkeley Hts. (Chemaoo Plant) Chera. Div. H, M. Hartong Charleston Wood Pres. Div,' R. M. Killey . Chicago Tar Products W, E, Cunningham Clifton Gap St Coke T. J. Leather V, P, Indus,Div. Denver Wood Pres. Div. R. C, Johnson Elizabeth Gas & Colce A. J. Dressel Everett Tar Products H. W. Thistlethwaite Follansbee Tar Products F. M. Smith Fontana Tar Products G. E. Traut Hamilton Tar Products J. T. Smith Houston Tar Products R. M, Smith Wood Pres. Div. J. W, Sullivan . Illinois Wood Pres. Divf R, P, Jackson Jersey City Gas St Coke K, R, Hare H, L, Francis Mbr.,Trans.Comm Kearny Gas & Coke Tar Products P. C, McConnaughey, Vice Pres. J. V, Ferris W. H. Carter hbnaca Chemical Div, B. R. Sarchet Name of Association Division Membership Position of Company Representative Representative In Organization Chambers of Commerce Nashua Newark Wood Pres. Div. G. F. Affeldt Gas & Coke K. R. Hare H. L-. Francis, Chairman,Rivers & Harbors Comm. Mbr.Trans. Comm. Newport Wood Pres. Div. M, A. Hamrick New Jersey Gas & Coke I. R, Hare H. L. Francis, Mbr. Indus.Traff, Committee H. J, Meredith, Mbr.Air Pollu- Tar Products , tion Committee J. V. Ferris, Seaboard W, B. Jackson, Garwood W. H, Carter, Meadows No.Little Rock Wood Pres. Div. P. I. Gibson Oil City Chemical Div. C. G. Youngquist Orrville Wood Pres. Div. R. H. Bescher Pa. State Koppers General Cooke Bausman Tar Froducts F. C, Foy Pa. Jr. Chamber Koppers Gen. Pgh. Jr.Chamber Koppers Gen. R. A. Harper R. A, Harper Wood Pres. Div. D. C. Smith Member, Comm.on Nat.Legislation Sales Dept. J. R. Rumisek Indiv. M'brship Pittsburgh Finance Dept. Tar Froducts F. W, Finney F. C. Foy H. B', Cummings V. P. & Director Vice Chrman, National Affairs Comm. Member, Salary Comm., Member, Ed.Comm, Traffic & Trans. J, B, Keeler J. F. Haley E, A. Gorges Freight Traffic Committee E, & C. Div. Finance Dept, R. Berg G. M. Carvlin J. B, Sellers J. L. Ralston Name of Association Division Merabershio Company Reoresentative Position of Representative In Organization Chambers of Commerce, Pittsburgh Production Port Arthur Tar Products J. H. Redmond R. A, Munson Vice Chrman,, Plant & Internal Security Comm. Providence Tar Products K. D, Gill Queens " Gas & Coke H. F, Fisher Richmond Wood Pres, Div. D. L. Skelkey Salida Wood Fres. Div. R. P. Williams Steubenville Tar Products - F. M. Smith St. Louis Tar Products J. T. Tierney Texarkana Wood Pres. Div, C. F, Seyer Tulsa Tar Products R. C, Kenan Union County J H. J. Tar Products W. B. Jackson United States Kbppers General F. C. Foy Production J. H. Redmond Tar Products F. C. Foy , Member Advisory Comm, on Mainte nance of Post Attack Produc. Member, Comm., Gov. Expenditures Washington Off. G, W. Naylor Utica Tar Products W. R. Jones Warren Tar Products J. Little Youngatoun Tar Products M. D, James Charleston Industrial Supervisor Wood Pres. Div. R. M. Killey Chemical Club of New England Chemi.cal Div, J. W. LaBelle Indiv, M'brship Chemical Vkrket Research Assn, Chemical Div, Sales Dept. ' C. B. Wagner 3, J, Korb T. C. Parker L. W. Adams Indiv. M'brship 11 11 rf ir ii it Chemical Specialties Ifenufacturers Assn., Inc. Tar Products J, H. Carpenter, Tar Acid Comm, on Disinfectants M. W, St, John Name of Association Division Membershio Company ReDresentative Position of Representative In Oreanization Chemists Club of New York Metal Products G. C. Pfaff Tar Products E. 0. Rhodes Chicago Assn, of Commerce and Industry Chicago Engineers Club Chicago Railroad Diesel Club Christiana Hundred Cicero Manufacturing Assn. Cincinnati Lumbermans1 Group Tar Products J, T. Tierney, Jr. E* & C f Div Gordon Fox fetal Froducts J. E. Onnen Wood Pres. Div. M. A, Hamrick Tar Products W, E. Cunningham . Wood Pres. Div. J. H. Bade Civic Club of Allegheny County Civic Engineers of Pittsburgh Clam) Laboratories Finance Dept. J. B. Sellers E, & C, Div R. F. Ross Wood Pres. Div. W. P, Arnold Cleveland Engineering Society Metal Froducts R. R. Day Coal Consumers Protective Assn,, Inc,Gas & Coke Div . H. F. Fisher, Sec. of Coal Con sumers . Coke Oven Ammonia Research Bureau, Inc. Sales Dept. Gas & Coke Cooke Bausman, Jr., Board of Dir. M. T, Herreid J. E. Spears Coke Oven Managers Assn.-England E & C 4 Div C. D, Ulmer Colorado Engineering Society Wood Pres. Div. R. C. Johnson Colorado Society of C.P.A.'s E. & C. Div. H. A, Semler Commerce for Transportation T, & T. Dept. Commercial Chemical Development Assn., Chera. Div. Research Commission of Governmental Efficiency and Economy Metal Products J. F, Haley C. F. Winans Dr; Thiessen W. F. Perkins Consultant to the Under-Sec, Indiv, tPbrship Committee for Economical Development,Sales Dept. Cocke Bausman, Jr. Committee for Major Group 28 Review of Standard Industrial Classification Manual Washington Off. G. W, Naylor Name of Association Division Membershio Company Reoresentative Position of Representative In Organization Comptrollers Institute of America Metal Products Finance Dept, Treas.& Acct. Connecticut Highway Assn. Tar Products J, E, Tellman Publicity Comm, E. A. Berry J. M, Veeder Program Comm, E', B, Shuck R. E. Gray Member of spec- ial Research Comm, on Cen tralization vs. Decentraliza tion of Controller functions. M. D. Gill Corporation Aircraft Owners'1 Assn, T &. T Dept. B. ,Q. Van Cott Country Club of Charleston Wood Pres, Div. R. M, Killey Dept, of the Array T, & T. Dept, Diesel Engine Manufacturers Assn, Metal Products J. B. Keeler Consultant, Spec. Assignment J. A, Worthington East Providence Better Business Assn., Tar Products M. D. Gill Eastern Industrial Traffic League Gas and Coke H. L. Francis Vice Pres, Eastern States Blast Furnace and Coke Oven Assn, Chemical Div. E. & C. Div. D. M. Rugg Indiv. M'brship Gordon Baer Joseph Becker R. Berg; R. A, Blackburn J. D. Bradford. G. M. Carvlin 0. FI. Chambers H. A. Denny C. W. Dillman T. A. Donehoo .A, B. Fisher, Jr. H, W, Fricke Member, Board ' of Directors J. W. Greene H, A, Grosick J. A. Hartzell E. J. Helm 0. L, Henry J. H. Kromer S. Ht Kimmel L. A. Kraemer W. A, Leech, Jr. H. B. .Lose R, K. Matthews H. W. Maurice D. J. McFarlin H. V, Nelson E. Preston - 17 - Name of Association Division Ambershio Position of Company Representative Representative In Organization Eastern States Blast Furnace and Coke Oven Assn.(continued) E, & C, Div. "' Oven Rice R. F. Ross M. F. Soherr W, S. Scherffius E. V. Schulte F. M. Schweinberg R. J. Sprott G. M. Sturgeon C. K. Waibel G. P. Wilson, Jr. C, D. Ulmer Gas & Coke Div, Metal Products M. W. Gaylord Jt Ei Spears E.' V. Harlow ElkS Club Wood Pres. Div* R. M. Killey Engineers Civic Club of Pittsburgh Metal Products E. F. Cary Engineers Clubs Baltimore Finney Engineers Society of Western Pa. Wood Pres, Div, M. R, Clifton J. H. Bade E. & C. Div, Metal Products R. A, Blackburn R, P. Dodds, Board of Dir M. Josenhans B. L. Keim W. A. Leech, Jr, G, F, Ross R. F, Ross R. W. Vollmer G. P, Wilson, Jr, E. F. Cary Mech, Exchange Club of Charleston Wood Pres. Div, R, M. Killey Exchange Club of Orrville Wood Pres. Div. R. H. Bescher Exchange Club of St. Paul Tar Products F. S, Franks Executives Club of Charleston Wood Pres. Div. R. M, Killey Faraday Society Research Dept. Dr, A. R. Powell Farm Fencing Assn. Federation of Sewage Works Assn. Foreman's Club of New Haven Wood Pres. Div, R. H. Devine Tar Products M. K. Cox Tar Products C, L. Farnsworth - 18 - Name of Association Division Membership Position of Company Representative Reoresentative In Organization Forest Products Research Society Chemical Div, Research Dept. J. F. Corwin (Research Fund) Dr. I. Goldstein Dr. G, Thiossen Tar Products J. N. Roche Wood Pres. Div, R. H. Bescher 40 and 8 Club Wood Pres. Div. J. H. Bade Freight Car Efficiency Committee Wood Pres. Div. R. C. Johnson Fuel Merchants Association of N.J. Gas & Coke Div. P. C. McConnaughey, Member of Finance Comm. T. J. Leather Member, Legis lative Comm. A. J, Dressel Gas Appliance Manufacturers Assn. E. &. C. Div. J. H. Taussig, Delegate Gas & Coke Div. M. T, Herreid Georgia Highway Contractors Assn. Tar Products F. G. Owen, Sr, H. A. Van Orman ' Harvard Engineering Society Pranki Foundation Comoany A. J. Bulger R. A. Biggs Highway Research Board, National Research Council Tar Products . A. R. Taylor P. F. Phelan E. F. Bennett* Dopt, of Soils Investigation* Chairman Granual Road Bases and Sub bases. Chairman-Frost Heave & Frost Action in Soils Sur veying and Classifying Soils in place for Engineering Pur poses Committee# E. 0. Rhodes, Division of Engin eering and Industrial Research E. W, McGovern History of Science Society E, & C, Division A. J, Abrams Hospital Board Wood Pres. Div.. R. H. Bescher Houston Retail lumber Dealers Assn. Wood Pres. Div. J. W. Sullivan Hudson Coal Credit Assn. Gas and Coke DivT, A. J. Dressel,Trustee W. W. Oeters Illinois Independent Telephone Assn. Wood Pres. Div, G. C. Rosenquist Name of Association Illinois Manufacturers Assn. Division Membership Position of Company Reoresentative Representative In Organization Wood Fres. Div. R. P. Jackson Improvement of the Poor Finance Dept. J. B. Sellers Director Indiana Independent Telephone Assn.Wood Preserving G. C. Rosenquist Industrial St Iknufacturing Assn. Tar Products " F. P, Schlax, Carrollville F. M. Smith, Follansbee W. R, Jones, Utica Industrial Assn, of the Mohawk Valley Tar Products W. R, Jones Industrial Club of Baltimore Metal Products M. S. Griffith Industrial Commission of Colorado Wood Pres. Div. R. C. Johnson Industrial Hygiene Foundation of America, Inc, Indus, Relations V, H, Viot A. K. Black III H. F. Ebken M. S. Griffith W, S. Scherffius N. L, Scanlon ... O. E. Stewart J. S.. Magee Industrial Management Club Wood Pres. Div. C. F. Affeldt, Nashua R. M. Killey, Charleston Industrial Research Institute Research Dept. Dr. A, R. Powell, Committee for Legislation Information. Dr. G, F. D'Alelio Industrial Safety Alumni Finance Dept, H. A. Biber, Vice President I.C.C. Fractitloners Assn. T, & T. Dept, J. B, Keeler, Comm, on Legisla tion. R, E, Spatz Industrial Relations Assn, of Chicago E, & C. Div. R, H. Jackson J. B, Christerson Industrial Smoke Abatement Assn, Gas & Coke J. M. Spees W. P. Dittmar Industrial Traffic Managers Assn. Metal Products L. J. Canter H. V, Kraft Institute of Aeronautical Sciences ,Pfetal Froducts S. H. Fedan - 20 - Name of Association Division Membership Company Representative Position of Representative In Organization; Instrument Society of America E, & C, Div. H, J, Exec. Chairman C. R. "Williamson H. P, [Jevhcuse G. E- nVsudin F. Revell Insulation Society of Pittsburgh E. & C. Div, R, P, Dodds , Board of Directors A. J. Pepper, President Insurance Buyers of Pittsburgh Finance Dept. H. H, Hook, Ex-officio member of Board Direc tors as past-pres, T.M.T, MoKennan, Director Kentucky Assn, of Highway Contractors Tar Products D. D. Hamilton F, B. Long J. 0. Fovrer Kiwanis Club of Brooklyn Gas & Coke H. F. Fisher lake County Contractors Assn, E. & C. Div. F, F, Wise Lions Club Woed Pres, Div, M. A. Hamrick ...... -. _ _ .. R, R. Keister R. M, Killey Long Island Coal Merchants Assn, Gas & Coke Div. H. F. Fisher J, F. Graham Fhcadam Pavement, Inc, Tar Products D, D. Hamilton F, B. Long A, R, Taylor, Technical Comm. R, G, Palmer Raines Good Roads Assn. Tar Products M. D. Gill P, E. Bennett Maine Water Utilities Assn. Tar Products E, J. Tilsworth Manufacturers Assn, of Canada Manufacturing Chemists' Assn, Tar Products Chemical Div. Tar Products T. & T, Dept, K - 21 - W, F. Croft R, A, Munson D. M. Rugg, Member of Board of Directors, Plasties Comm,', FUblic Rela tions Conan, B.J.C. van der Hoeven serves as alternate for W'.Bugg F, C, Foy R. R, Holmes J. B. Keeler, Chrman,Traffic Comm J. F, Haley, Safety Committee E, A. Gorges, Plastics tfeterial.s Committee T. ?. Reynolds, Tank Car sub . Committee. Name of Association Division Membershiu Position of Company Representative Representative In Organisation ffenufacturers Club of West Hudson Gas & Coke Div, K. R. Hare P. C. McConnaughey Maryland Industrial Marketers Mstal Products R. W. Dorsey Maryland Society of Training Directors Massachusetts Selectmen's Asan. Pfetal Products Tar Products J, M. Bell, Jr, Treasurer M. D. Gill G, W. Dean Michigan Independent Telephone Aasn. Wood Pres, Div, N, P, Matro Middle Atlantic Conference of Bldg Owners and Managers Finance Dept. J. L, Ralston Director Mississippi Economic Council Wood Fres. Div, D, L, Wagner M3A Research Fund for Physical Properties of Plastics Chemical Div. W. J, Fitzgerald Montgomery Traffic & Transportation Club Wood Pres. Div. S. L. Taylor National Assn, of Corrosion Engrs, Tar Products W, F. Fair, Chairman, N.Y. Sec tion; Chairman,Nom inating Committee M, G, Sturrock R. C. Stromquist E. 0, Rhodes J. G. Brich ' H, E. Crane National Association of Cost Accountants , Chemical Div, E, & C. Div, Tar Products Finance Dept, Metal Products R. J. Hein C. E. Lindberg H. A, Semler J. D, May F. R. Stoveken C, J. Stewart J. A, Stemole National Association of Credit Men Finance Dept, W, G. Hunt National Assn, of Foremen Wood Presf Div, D. C. Smith National Association of Manufacturers 4 /US EC i rK^ C? Sales Dept. Cooke Bausman, Jr* Indus. Relations V, H. Viot, Member of Industrial Relations Committee Tar Products F. C. Foy, Director-Chairman, Distribution Committee Keepers-General F. C. Foy Cooke Bausman - 22 - Name of Association Division MsmbershiD Position Company Representative Reoresentative In Orsanization National Assn, of Purchasing Agents Procurement Dept .R.D. King, Pittsburgh P. D. Sholiar, Pittsburgh A, E. Jones, Chicago National Constructors Assn. E, & C. Div. W. S. Scherffius, Labor Comm. & Chairman, Great Lakes Reg ional Committee F. R, Griffin R. E. Atkinson, Alternate Mbr. National Council of Private Motor Truck Owners T, St T, Dept. J.F. Haley, M'brship Committee National Defense Transportation Assn, T * it T Dspt J, B. Keeler, Life Member J, F. Haley, Pres., Pgh. Chap. & Regional Vice Pres, of National Chapter. E. A. Gorges National Farm Chemurgic Council Research Dept, Dr. D'Alelio National Fertilizer Assn. National Fire Protection Assn, Tar Products J. H, Carpenter C. G. Franklin Chemical Div. E. J. Dean . Finance Dept. H. H. Hook, Member of Industri al Committee Koppers-General H. K. Hook Gas & Coke I. Trimmer Production Dept, A. N. Harrison Wood Fres. Div. R. H. Bescher National Foreman's Institute National Freight Traffic Assn. Gas & Coke Div. J. E. Spears T. & T. Dept. J. B. Keeler, Exec, Comm. J. F. Haley E. A, Gorges ' National Hardwood Lumbermans' Assn. Wood Pres. Div. M. F. Cravey National Industrial Advertisers Association (Pgh. Chapter) Riblic Relations R. B, Johnston National Industrial Conference Board Gas & Coke Div, Finance Dopt. Sales Dept, , 'Kbppers-General M. T. Herreid E, A. Berry, Council of Finan cial Executives. B. J, Korb Advisory Council of Marketing Re search Directors. Gen, Somervell Cooke Bausman - 23 - Name of Association Division femhcrship Company Representative Position Representative In Organization National Industrial Traffic League fetal Products T, &. T. Dept, _. ' L. J. Canter J. B. Keeler, Mbr, Board of Dir ectors. Chairman, Ex Parte 104,fert 2 Comm. Special Commi on Transpor tation. Outlook & Policy, Member of Special Comm, on Ex Parte 175* J. F. Haley, Chairman: Area Membership Comm. E. A. Gorges Rate Construction & Tarriffs Conm. Admin, Comm, of 'Railroads and Cooperating Comm, of National Indus trial Traffic League for Rail roads' Tariff Re search group. National Security Industrial Association Production J. H, Redmond Kbppers-General J* H. Redmond National Office Management Assn, Finance Dept, E, B, Shuck R. E. Gray, Advisory Committee and Nominating Comm. National Rifle Assn, Safety Councils Baltimore Buffalo E. & C, Div, * fetal Products Tar Products P. G. Shanor W. F, Parkins M, S. Griffith, Jr J. N. Curry Industrial Committee Chicago Delaware Garwood Tar Products W. E, Cunningham Wood Pres, Div. M, A.. Hamrick Tar Products W. B. Jackson Hamilton Tar Produots J. T. Smith Illinois Aye., Chicago Tar Products L. Cherrone New Jersey State Gas & Coke Div. K, R. Hare F. C. McConnaughey National Safety Council Koppers-Gencral A. N, Harrison Tar Products R. C. Bauer 4285 - 24 - Name of Association Division Membership Position of Company Representative Representative In Organisation National Safety Council (continued) Gas & Coke Div. M. W. Gaylord L. C. Biery F, A, Pucskowski E. & C. Div. H. 3. Wallace Chemical Div. E. J. Dean Wood Pres. Div. D. C, Smith Production Dept. A. N. Harrison Western Pa.. Safety Council Wood Pres. Div, D. C, Smith Chemical Div. E. J. Dean Production Dept. J. H. Redmond Director Safety Counoil, Youngstown Tar Products M. D. James ' National Sales Executives, Inc. Sales Dept. Cooke Bailsman, Jr. National Society of Professional Engineers ' E. & C. Diy, W. S. Scherffius.. P. G. Shanor R. 3, Stannard Frank! Foundation, R. A. Biggs National Society of Sales Training Executives Sales Dept. Natural Gasoline Supplymen's Assn. Tar Products Robert Gopel R. C. Keenan New England Council Tar Products M. D. Gill Wood Pres. Div. C. F. Affeldt New England Gas Assn. Metal Products Tar Produots G, C. Pfaff H. B. Cummings E. J. Titsworth New England Paint & Varnish Chemical Div. J. W. LaBelle New England Railroad Club New England Road Builders Assn. New England Roofing Contractors Assn. Efetal Products Tar Products Tar Products C. Kessler M, D, Gill M. D. Gill G. H. Persch Now England Water Works Assn. Tar Froducts E. J. Titsworth New Hampshire Federation of Taxpayers Wood Pres. Div. C. F, Affeldt - 25 - Name of Association Division Membership Position of 1 Company Representative Representative In Organization New Hampshire Good Hoads Tar Products M, D. Gill T, A. Mulvanity New Hampshire Mfrs. Assn. Wood Pros, Div. C, F, Affeldt New Jersey Coal .Dealers Association Gas & Coke Div. A, J. Dressel . F. L. Deramert New Jersey Gas Association fetal Products G. C,. Pfaff New Jersey Industrial Traffic League Gas and Coke Div. H. L. Francis New Jersey Motor Truck Association Gas and Coke Div. H, L. Francis New Jersey Self-Insurers Association, Finance Dept. H. H. Hook New York Good Roads Tar Products J. N. Fencil E. F. Crosetto New York Railroad Club fetal Products R. J. Green New York State Bituminous Concrete Association Tar Products J. N. Fencil. . E. F. Crosetto New York Fuel Merchants Assn., Inc. Gas and Coke Div. H. F. Fisher New York State Highway Superintend dents Assn. Wood Pres, Div. Dt F, Taylerson New York State Independent Tele phone Assn. New York State Sewage Assn. Wood Pres. Div. D. F, Taylerson Tar Products Research Dept. G, E, Boyd Dr. Powell New York State Telephone Assn. Wood Pres, Div. D. C. Smith New York State Town Superinten dents Assn. Tar Products J. N, Fencil E. F. Crosetto Northeastern Wood Utilization Council, Research Dept., Dr. D'Alelio North Jersey Coal Dealers Assn. Gas and Coke Div. T. J. Leather Northwest Good Roads Assn. Tar Products J, T. Tierney H. G. Nicholson Ohio Florists' Assn. Wood Pres. Div. R. H. Bescher Ohio Forestry Association Wood Pres. Div. R, H. Bescher Ohio Independent Telephone Assn, Wood Pres, Div. D, C, Smith Name of Association Division Membershid - Position of Company Representative ReDresentative In Organization Ohio Manufacturers Assn, (Warren) Organized Business (Charleston) Tar Products Koppers-General Wood Pres. Div. J. Little J, C. Macon, Jr, D. Grymes and J. Irvine R. M, Killey Pacific Coast Gas Association Research Dept. Dr. Powell Tar Products S. J, Katz F&terson Fuel Dealers Assn. Gas and Coke T. J. Leather H. Williamson Pennsylvania Bar Association Pennsylvania Constructors Assn, Law Dept, Tar Produots C, M. Crick, Also member of Tax Section E. S. Ruffin, Jr. Templeton Smith F, B. Long F. V. Oler Pennsylvania Counties Supervision and Auditors Association Tar Products D. D. Hamilton F. B. Long F. V. Oler ' J, H. Conlson G. W. Sanner - Pennsylvania Economy League Koppers-General C, M. Crick Pennsylvania Gas Association E. fit C. Div. J. H. Taussig, Jr., Delegate Pennsylvania Self-Insurer3 Assn. Finance Dept* H. H. Hook , Pennsylvania Society of Professional Engineers E. & C. Div, R. A. Blackburn E. J. Helm V, M. Africa G. F. Ross, Msmbership Committee Personnel Association Metal Products M, S. Griffith Petroleum ELectric Supply Assn. Wood Pres. Div. J. W. Sullivan Petrolia Volunteer Firemen's Assn. Chemical Div. D, Stroup, Indiv. M'brship Pipeline Contractors Assn. Tar Products H. E, Crane Pittsburgh Advertising Club ftiblic Relations Ralph Winslow Pittsburgh Builders Exchange Tar Products J. A. Seifert Pittsburgh Chemists Club Pittsburgh Civic Business Council E, & C. Div. A. J. Abrams Koppers-General F. C. Foy If8 5Pittsburgh Ordnance Society__ E. fit C. Division G. M. Carvlin - 27 - Name of Association Division Membership ' Position of Company Representative Representative In Organizatio: Pittsburgh Paint and Varnish Pro duction Club Chemical Div, E, E. Kimmel Research Dept, Dr. Thiessen Pittsburgh Personnel Association E & C Div R, E, Atkinson, Hfember Wage ant ' Salary Adm. Coi Industrial Relations ' Van H. Viot L. A., Allen, Member of Steerin; Coramittee-Rssearc! R. E. Brick B. Rf Sheddan H. P, Clifton J, S. Magee R- R, Montgomery, Vice Chairmai Wage & Salary Comr G, W, Colburn ' D, J. Newman Pittsburgh Regional Planning Association G. M. Carvlin Koppers-General Plastic Engineer's Assn, (N. Y,) Plastio Nfaterial Credit Assn, Chemical Div. Finance Dept, D, B. Hunter W, G, Hunt H, E. Crawford A. G, Wilson ftractical Refrigeration Engineering Mbtal ft*oducts J. E. Onnen Professional Engineers License Metal Products G. C. Pfaff Professional Engineers Society Franki Foundation, A. J, Bulger R. Af Biggs E. & C. Division A. B. Fisher, Jr, F. M. Schweinberg Propeller Club Wood Pres, Div, R. M. Killey Riblic Relations Society of America Publiq Relations Ralph Winslow Hire has ing Agents Ass'n, of Baltimore ffetal Products J. M, Kalista, Director Rirehasing Agents Assn, of Chicago E, fie C, Division A, E. Jones Purchasing Agents Assn, of N, Y. Gas and Coke Div.C, E. Marquardt Railway Business Association Railway Supply t&nufacturers Assn, Tar Products Wood Pres. Div.i Wood Pres. Div. Rt .R, Holmes F. C. Foy W. P, Arnold R. P. Jackson - 28 - Name of Association Railway Tie Association Division Membership Position of Company Representative Representative In Organization Tar Products Wood Fres. Div. J, N. Roche, Committee on check ing and splitting of cross ties. Chairman, sub-comm, on coatings for ties E. J, McGehee W, D, Jetton R, H. Beschcr The Refractories Institute Researoh Dept. C. R. Austin Registered Professional Engineers Georgia Illinois Indiana New Jersey New fork Ohio E. & C. Div. E, & C, Div. E. & C. Div. E. & 0. Div, E, & C. Div. E, & C. Div. Pennsylvania E. & C Div* Texas West Virginia E, iSc C. Div. E, & C * Div * W. S. Scherffius P, E. Lundquist R. Berg R. A, Blackburn R. Berg R. Berg R. Berg R. A, Blackburn C. F. Schuman L. Silverblatt R, A. Blackburn H. A. Denny, Civil E. j. Helm T. M. Osborne A. H. Stubee R. A. Blackburn Rhode Island Highway Association Tar Products M. D. Gill Rhode Island Truck Owner's Assn. Tar Products M. D, Gill A. L. Nickerson Rifle Club Wood Pres. Div R. M. Killey Rotarv Clubs Boston Chemaco Plant Charleston Chicago Everett Fontana Grenada Nashua North Little Rock Oil City Orrville Providence Russell Superior Texarkana Tar Products Chemical Div, Wood Free, Div Tar Products Tar Products Tar Products Wood ft*es. Div Wood Pres, Divi Wood Fres. Div Chemical Div. Wood Pres. Div, Tar Products Wood Frcr. Pi.T Wood Pr- s, : 1 v, Wood Div, M. D. Gill H. M. Hartong R. M, Killey W. E. Cunningham H. W. Thistlethvaite O. E, Traut V. L, Wagner C, F. Affeldt P, I. Gibson C. G. Youngquist, Serves on Program Comm, R. H. Bescher V. H, McClurg A. Piepho S. G. McGlasson C. F. Seyer 4285 V - 29 - Namfi of Association Safety Engineers Club Division Membership Metal Products Tar Products Position of Company Representative Representative In Organization N. D. Tucker, Visual Aid Coram. R. C, Bauer Sales Executives Club of Pittsburgh Sales Dept. Tar Products Cooke Bausman, Jr. F. C. Foy Sales Executive Council of the Baltimore Assn, of Commerce - fetal Products J. L. Tunstead, Education Conan. Society for the Advancement of Management Industrial Rela- tions Dept. L. A. Allen, Chairman, Industrl ' al Relations Round table. V. H. Viot . D. D. Hicks R. F, Dean E. J. Martin S. Hobbs J. R. Blair Society of American Engineers fetal Products -- J. Dennis D, R, Tarallo H. C. Lancaster Wood Pres. Div. M, F. Cravey Society of American Military En gineers E. & G. Div. J. R. Clarke C, F. Schumann P. G, Shanor K. Yaromey R. Berg Society of Automotive Engineers Metal Products B. W. Deringer T. F. Maylor S. H. Fedan R. D. Taber T. & T. Dept, J. F. Haley, Transportation and Maintenance Activ ity. Society of Automotive Engineers Technical Board fetal Products J. W. Pennington Society of Chemical Industry Society of Gas Lighting 4285 E, & C, Div. Research Dept. Tar Products C. D, Ulmer Dr. A. R. Powell E, 0, Rhodes Gas and Coke Chemical Div. Gas & Coke Div. Production Metal Products K. R. Hare D. M. Rugg M. T. Herreid Fred Denig G. C. Pfaff - 30 - Name of Association Division Membership Position of Company Representative Representative In Organization Society of Military Engineers Franki Foundation Company A, J, Bulger Society for Non-Destructive Testing, Inc. Metal Products E. A. Hale Society of Plastic Engineers Chemical Div, 1- W, J. Fitzgerald J. W. LaBelle, Serves as National Secretary of this organization. Society of Flastic Industry Chemical Div. D, M. Rugg T, C. feeling, Jr., Injection Holders Comm, for National Defense. C, H. Pottenger, Adhesives. Society of Rheology Tar Products W. F. Fair S. C. Society of Safety Engineers Wood Pres. Div. R. M. Killey Southern and Southwestern Railway Club Metal Products A. F, Brown .. Southern Gas Assn. Tar Products H. E. Crane, Member Advisory Council. J.E.B, Gibbons Southern Seedmen's Association Wood Pres, Div. R. M, Killey Southwest Shippers Advisory Board Wood Pres. Div. C, F. Seyer Special Libraries Association E. & C. Div. C. D, Ulmer St, Andrew's Society of Charleston Wood Pres. Div. R. M. Killey St, Clair County Taxpayers Assn, Tar Products L. Cherrone St. Paul Engineers Society Ga3 & Coke Div. J. H. Brown (Minnesota Plant)W. D. Levie T. H. Rauen, on Committee St. Paul Association of Commerce Gas & Coke Div. A, W. Lundquist (Minnesota Plant)R. J. Wheeler St. Paul Association of Credit Men Gas & Coke Div.' (Minnesota Plant)R. J, Wheeler Steel Club of Baltimore Pfetal Products J. M, Kalista, Entertainment Comm, Suburban Fuel Dealers Assn, Gas & Coke Div. (Seaboard Plant) T. J, Leather R. Williamson Name of Association Synthetic Organic Chemical Man ufacturers Association Systems and Procedures Assn, of America Division Membershio Position of Company Representative Representative In Oreanization Chemical Div. D. M. Rugg . Chemical Div. W, T. Gibson Control Section W. H, Donohue Tax Foundation Koppers-General C. M. Crick Technical Assn, of Pulp and Paper Industry Chemical Div. Tennessee Road Builders Aasn, Tar Products J. F. Corwin F. G, Owen, Sr. Tennessee Valley Electric InstituteWood Pres, Div, W, D. Jetton Texas Manufacturers Assn. Tar Products R, M. Smith Wood Pres. Div. C, F. Seyer Traffic and Transportation Assn, Traffic and Various personnel of of Pittsburgh Transportation T. & T, Dept. Traffic Clubs Baltimore Metal Products L, J. Canter, Chairman, Nomin ating Committee H. V. Kraft Chicago Wood Pres Div. C. E. Masini Charleston Wood Pres. Div. R. M. Killey Jersey City Gas & Coke Div, H. L. Francis New York Gas & Coke Div. H, L. Francis . Newark Gas & Coke Div, H. L. Francis Pittsburgh T. & T. Dept. J. B, Keeler, Chairman, Reception Committee J, F; Haley, Annual Dinner Comm. E, A, Gorges, Board of Governors Vice Chairman, House Committee H. B. Wilson, Membership Comm. J. D. Counahan R, E. Spats Texarkana Wood Pres. Div. C, F. Seyer 4285 - 32 - I Name of Association Division Mi.mbershio Position of Company Reoresentativ- Reorescntative In Orsanizati Transportation Association of America T. fit T. Dopt. J, B. Keeler, Alternate for Gen. Somervell. Transportation Club of St, Paul Gas & Coke Div, George Sack, On Committee (Minnesota) Transportation Council to the Sec. of Commerce T. & T. Dept. J. B. Keeler, Member (Special Assignment) United Roofing Contractors Assn. Tar Products J. A. Seifert D. D, Hamilton J. T. Tierney F. G. Owen, Sr. U. S. Indeoendent Telephone Assn. Virginia Manufacturers Assn. Wood Pres. Div. J, M. Irvine Wood Pres, Div. D. L. Skelky Water & Sewage Manufacturers Assn. Tar Products G. E. Boyd H. E. Crane West Coast Manufacturers Assn. Tar Products G. E. Traut ' West Coast Wood Preservers Assn. Tar Products S. J. Kat z West Hudson Kivanis Tar Products J. V. Ferris Western Railway Club Mstal Products J. E. Onnen Wood Pres. Div. H. C. Busch Western Society of Engineers E. & C, Div. 4285 G. G, Bigelow W, B, Ferguson A, B. Fisher. Jr. Gordon Fox E, A. Lejeck R, K. Matthews E, J. McCormick H, W. Peterson W. C, Schofield E, J. Westcott M. F. Young Western States Blast Furnace and Coke Oven Association, E. fit C. Div. F. M, Schveinberg West Tennessee Electric Institute Wood Pres. Div. W. D. Jetton West Virginia Contractors Assn. Tar Products F. B. Long West Virginia Independent Tele phone Association Wood Pres. Div. D, C. Smith West Virginia Sewage and Indus trial Wastes Assn. Tar Products _ ri _ W, M. Lee Name of Association Division Membershi n Position of Company -Representative Representative In Organization Wisconsin Independent Telephone Association Wood Preserving Industry Traffic Conference Wood Pres, Div. A. R. Nickel Traffic and Transportation , Dent. E. A. Gorges, Socretary m - 34 - IN THE CIRCUIT COURT . THIRD JUDICIAL CIRCUIT MADISON COUNTY, ILLINOIS IN RE: ALL ASBESTOS LITIGATION FILED BY THE SIMMONS FIRM, LLC, Plaintiffs, vs. A.W. CHESTERTON, et al., Defendants. ) ) ) ) ) ) ) ) ) ) PROOF OF SERVICE The undersigned certifies that the foregoing Memorandum for Clerk was served upon Counsel to the above cause by enclosing the same in an envelope addressed to such attorney at their business address as disclosed on the attached service list with postage fully prepaid and by Plaintiff Amoco Oil Atlantic Ritchfield (successor to Sinclair Oil) Sinclair Oil A. P. Green / Harbison Walker Anchor Packing / Chicago Fire Brick Foster Wheeler / Garlock Weavexx / Treesdale (Pittsburgh Metals) Viking Pump, Inc. Albany International A. W. Chesterton Congoleum Durabla / Plibrico Riley Stoker Sears, Roebuck & Company Abex Corporation AcandS Bowater Simmons Law Finn LLC 707Berkshire Blvd. East Alton, IL 62024 . 618-251-2222; fax: 618-251-2251 Alan Zelkowitz/John v. Smith Pretzel and Stouffer Oiie South Wacker Drive, Suite 2500 Chicago, IL 60606-4673 312-578-7456; fax: 312-346-8242 Wm. Mahoney/ Cameron Turner/ Lawrence Finn Segal, McCambridge . One IBM Plaza, 330 North Wabash, Suite 200 Chicago, IL 60611 .. 312-645-7800; fax: 312-645-7711 clumer@smsm.com John Kurowski Kurowski & Bailey, P.C, 24 Bronze Pointe Swansea, IL 62226 . 618-277-5500; fax: 618-277-6334 Robert Scott Swain, Hartshorn & Scott 411 Hamilton Blvd., #1806 Peoria, IL 61602 309-637-1700; fax: 309-637-1708 Nicole Behnen / Andrew Cross Polsinelli Shalton & Welte 100 South Fourth Street, Suite 1110 St. Louis, MO 63102 314-231-1950; fax: 314-231-1776 e-mail: across@pswlaw.com Kurtis Reeg Leritz, Plunkert & Bruning, P.C. One City Centre, Suite 2001 St. Louis, MO 63101 314-231 -9600; fax: 314-231 -9480 Asten Group Big River Zinc Corp. Borg-Wamer / Certain-Teed A. T. Callas / C.E. Thurston Maremont / National Gypsum . Shook & Fletcher Union Carbide / Amchem / Montello, Inc. Sinclair Oil / Atlantic Richfield (co-counsel) Southern IL Power Coop / Amoco Oil TH Agriculture / Harcross Chemicals D&F Distributing / Flexitallic / T&N PLC Ford Motor Company (co-counsel) Missouri Diywall Supply, Inc. Bombardier Capital, Inc., Bombardier Capital Rail, Inc., Bombardier Transit Corporation and Bombardier, Inc, Reynolds Metals Company Stacey Steneczko Hinshaw & Culbertson (Waukegan) 110 North West Street Waukegan, IL 60085-4330 847-244-0551; fax: 847-249-4755 David A. Nester Nester & Constance, P.C. 123 West Washington Street Belleville, IL 62220-2021 618-234-4440; fax: 618-234-6193 Kent L. Plottner / Jennifer Johnson Heyl, Royster, Voelker & Allen P. O. Box 467 Edwardsville, IL 62025 618-656-4646; fax: 656-7940 Beazer East, Inc. Quigley Pfizer Eric C. Young Dunham, Boman & Leskera 208 North High Street Belleville, IL 62220 618-235-7222; fax: 618-236-2800 e-mail: dbI103@mvp,net William Lucco Lucco, Brown & Mudge 224 St. Louis Street Edwardsville, IL 62025 618-656-2321; fax: 656-2363 B.F. Goodrich Company Brandon Drying Fabrics Inland Steel l Ispat Inland, Inc. Southern Illinois Power Coop (SIPCO) Bondex / Georgia Pacific Georgia Pacific (Hudson Pulp & Paper) Carborundum / Lockport Dryer Felts Marathon Oil / Ameren UE / CIPS Grays Harbor Paper / Dow Chemical Hollingsworth & Vose / Marcal Paper Illinois Power / Swift & Co. Commonwealth Edison (co'counsel) . Union Electric Company, a/k/a ameren UE Brauer Supply AEROJET Sprinkman Sons Corp. Marley Cooling Tower Co. Sprinkman Sons Corporation ofIllinois H. Patrick Morris / Kevin Owens Johnson & Bell, Ltd. 55 East Monroe Street, Suite 4100 Chicago, IL 60603 312-372-0770; fax: 312-372-9818 Jeffrey S. Hebrank Burroughs, Hepler, et al. P. O. Box 510 Edwardsville, IL 62025 618-656-0184; fax: 618-659-9277 e-mail: mkw@ilmolaw.com Francis Duda / Joel Monson Anderson & Gilbert 200 South Hanley Road, Suite 710 St. Louis, MO 63105 314-721 -2777; fax: 314-721-3515 . Robert J, Brummond Foley & Mansfield POB 56580 St. Louis, MO 63156 .. 314-367-7060; fax: 314-367-9945 Cathy Molchin Cathy Molchin, P.C. 4909 Sir Lionel Court Mapleton, IL 61547 309-633-0935; fax: 309-633-0936 Abex Carlisle Corporation General Dynamics Westvaco / Weyerhauser Longview Fibre Nestel Purina Petcare Cerro Copper Products Company Ray Foumie/ Anita, Kidd Armstrong Teasdale One Metropolitan Square, #2600 St. Louis, MO 63102-2740 314-621-5070; fax: 314-621-5065 Thomas Ducey Ducey & Associates, P.C. 20 Bronze Pointe Swansea, IL 62226 618-233-1358; fax: 618-234-9560 Combustion Engineering Triangle Insulation Westinghouse Electric Wise El Santo Mallinckrodt Commonwealth Edison (ComEd) Corhart, Ingersol1-Rand, Sidener Supply Halliburton Technical Services Electric Engergy, George P. Reintjes Ferro Enginnering / Ogelbay Aurora / Hydromatic Pumps Crown Cork & Seal CSR, Ltd. Nooter J-M A/C Pipe Corporation Consolidated Aluminum Cupples Products, Inc. Nooter (co-counsel) Delco-Moraine (GM) Daniel G. Donahue / Ann Hatch Herzog, Cregs & McGhee 1 City Centre, 24th Floor 515 North 6th Street St, Louis, MO 63101 314-231-6700; fax: 314-231-4656 Michael Freeborn / Michael Franz Freeborn & Peters 311 South Wacker Drive, Suite 3000 Chicago, IL 60606 312-360-6000; fax: 312-360-6520 Susan Gunty / Paul VanLysebettens Gunty & McCarthy 150 South Wacker Drive, Suite 1025 Chicago, IL 60606 312-541-0022; fax: 312-541-0033 Stephen Maassen Hoagland, Fitzgerald, Smith & Pranaitis 410 Market Street, P O Box 130 Alton, IL 62002 618-465-7745; fax: 618-465-3744 David Coffman Lewis, Rice & Fingersh 500 North Broadway, Suite 2000 St. Louis, MO 63102 314-444-7600; fax: 314-241-6056 W. Jeffrey Muskopf / Jim Mendillo Freeark, Harvey, Mendillo, et al. 115 West Washington, POB 546 Belleville, IL 62222 618-233-2686; fax: 618-233-5677 John D. Warner, Jr. Gault & Warner, LLC 222 South Central, #500 Clayton, MO 63105 314-863-2230; fax: 314-863-2348 * Genera] Motors Daimler Chrysler Ford Motor Company Doyle Equipment Company Kimberly - Clark Scott Paper . . Dresser Industries Halliburton Company Halliburton Energy Services Worthington Pump Flintkote General Electric ASARCO, Inc. Gregory Cerulo Quinn, Johnston, Henderson & Pretorius 227 N.E. Jefferson Street Peoria, IL 61602 309-674-1133; fax: 309-674-6503 Maureen McGlynn McGlynn & McGlynn, L.L.C. .222 South Central Avenue, Suite 1101 St. Louis, MO 63105 314-727-1000; fax: 314-727-2960 John A. Krivicich Donohud, Brown Mathewson & Smyth 140 South Dearborn Street, Suite 700 Chicago, IL 60603 312-422-0900; fax: 312-422-0909 David T. Butsch Green, Schaaf & Jacobson, P.C. 7733 Forsyth Blvd., Suite 700 Clayton, MO 63105 314-862-6800; fax: 314-862-1606 Bryan Skelton Reed, Armstrong, et al. P. O. Box 368 Edwardsville, IL 62025 618-656-0257; fax: 618-692-4416 Bart Sullivan Sandberg, Phoenix & von Gontard One City Centre, 15th Floor St. Louis, MO 63101 , . 314-231-3332; fax: 314-241-7604 Ronald L. Hack Gallop, Johnson & Neuman 101 South Hanley, Suite 1600 St. Louis, MO 63105 . 314-615-6000; fax: 314-615-6001 * . General Gasket Azrock/Domco, Inc. Harwick Standard Distribution AlliedSignal/Bendix Honeywell International General Refractories Young Insulation Boise Cascade Corp. American Biltrite / LaSalle Steel Sprinkmann Sons Dow Chemical Illinois Bell Telephone Company IREX J. P. Bushnell Packing A. J. Bronsky Brown & James, P.C. (St. Louis) 1010 Market Street, 20th Floor St. Louis, MO 63101 314-421-3400; fax: 314-421-3128 Beth Kamp Veath Brown St, James, P, C, (Belleville) 120 West Main Street, 2nd Floor Belleville, IL 62220-1502 618-235-5590; fax: 235-5591 e-mail: bveath@bjpc.com Thomas Kemell Roberts, Penyman One USBank Plaza, Suite 2300 St. Louis, MO 63101 314-421-1850; fax: 314-421-4346 Gerard T. Noce / W. Allan Murray NOCE & BUCKLEY, LLC 515 Olive Street, Suite 800 St. Louis, MO 63101 314-621-3434; fax: 314-621-3485 Timothy Hayes & Associates 120 South Central Avenue, #1880 St. Loouis, MO 63105 314-726-6767; fax: 314-726-6765 Steven W. Celba Celba & Des Rochers 4493 North Prospect Avenue Milwaukee, WI 53211 414-906-0626; fax: 414-906-0631 Michael Noakes / Gregory Dioneda Moser & Marsalek, P.C. 200 North Broadway, Suite 700 St. Louis, MO 63102-2730 314-421-4364; fax: 314-421-5640 . * . .. John Crane, Inc. Kaiser McDonnell Aircraft & Missile Systems American Standard (of counsel) McDonnell Douglas/Boeing Gardner Denver Metropolitan Life 3M (Minnesota Mining & Manufacturing) Norfolk Southern / Norfolk & Western Illinois Central Railroad A. 0. Smith A. 0. Smith Edward M. Bums Law Office of William M. Koziol One Kemper Drive Long Grove, IL 60049-0001 - . fax:847-320-4347 Becky Jackson / Dennis O'Connell Bryan, Cave 211 North Broadway, Suite 3600 St. Louis, MO 63102-2750 314-259-2000; fax: 314-259-2020 Charles L. Joley Donovan, Rose, Nester 8 East Washington Street Belleville, IL 62220-2190 * 618-235-2020; fax: 618-235-9532 Ed Crane Skadden, Arps, Slate, Meagher & Flom 333 West Wacker Drive Chicago, IL 60606-1285 fax: 312-407-0411 Richard Boyle / Tom Peters / Curtis Picou Gundlach, Lee, Eggmann, Boyle & Roessler 5000 West Main Street, Box 23560 Belleville, IL 62223 618-277-9000; fax: 618-277-4594 James R. Niquet Crivello, Carlson, Mentkowski & Steeves, S. C. 710 North Plankinton Avenue Milwaukee, WI53203 fax:414-271-4438 Lorillard Sherwin-Williams Bunge Corporation Mt. Vernon Mills, Inc. Monsanto Olin Union Oil Company of California (Unocal) PolyOne Occidental Peavey Paper Mills Tracy Jonathan Cowan Thompson Cobum (St Louis) One Firstar Plaza St. Louis, Mo 63101 314-552-6040; fax: 314-552-7597 e-mail: tcowan@thompsondobum.com Kurt Reitz / Thomas Alvey Thompson Cobum (Belleville) 525 West Main Street, POB 750 Belleville, IL 62222-0750 618-277-4700; fax: 618-236-3434 , Jerome Duchowicz O'Hagan, Smith & Amundsen, LLC 150 North Michigan Avenue., #3300 Chicago, IL 60601 ' 312-894-3200; fax; 312-894-3210 Mark Zellmer Husch & Eppenberger 190 Carondelet Plaza, #600 St Louis, MO 63105-3441 314-480-1500; fax: 314-480-1505 William Schopf Schopf & Weiss 312 West Randolph, Suite 300 Chicago, IL 60606 312-701-9300; fax: 312-701-9335 e-mail: swedenborg@sw.com (Lisa Swedenborg) Soctt A. Nielson . . Henson & Efron 400 Second Avenue South, Suite 1200 Minneapolis, MN 55401-2496 , 612-339-2500; fax: 612-339-6364 e-mail: snielson@hensonefron.com PPG Rapid American Premcor Refining Group Clark Oil Sager Corporation Anheuser-Busch Caterpillar Shell Goodyear Tire Kraft Foods, Inc. Simkins Industries, Inc. Surface Combustion Dennis J. Graber Hinshaw & Culbertson (Belleville) 521 West Main Street, Suite 300, POB 509 Belleville, IL 62222 618-277-2400; fax: 618-277-1144 , Craig Liljestrand / Daniel McGrath Hinshaw & Culbertson (Chicago) 222 North LaSalle Street, Suite 300 Chicago, IL 60601-1081 fax:312-704-3001 Jaimy Hamburg / Susan Cowell Mayer Brown Rowe & Maw 190 South LaSalle Street Chicago, IL 60603-3441 312-782-0600; fax: 312-701-7711 e-mail: jhamburg@mayerbrown.com James Carter Carter Law Offices 416 Main Street, Suite 529 Commerce Bank Bldg., 15th Floor Peoria, IL 61602 . 309-673-3517; fax: 309-673-3318 Thomas Oms Williams, Venker & Sanders . 10 South Broadway St. Louis, MO 63102 314-345-5000; fax: 314-345-5055 Martin M. Ruken Meltzer, Purtill & Stelle LLC . 1515 East Woodfield Road Second Floor Schaumburg, IL 61073-5431 . 847-330-2400; fax: 847-330-1231 e-mail: www.mpslaw.com Richard R. Malone Malone, Ault & Fared 405 Madison Avenue, Suite 2300 Toledo, OH 43604 419-242-6066; fax: 419-242-1605 ,,, ' , Texaco Thermic Refractories, Inc. Uniroyal (O'Hara) John Deere & Co. (Fischer) Mobil Corp./Socony (Burke) Owens-Illinois Westinghouse Air Brake American Standard, Inc. , Wheeler Protective CSX Transportation, Inc, Michael Trucco Stamos & Trucco Ten North Dearborn, 5th Floor Chicago, IL 60602 312-630-7979; fax: 312-630-1183 Stephen J. Potter / James Corrigan Behr, McCarter & Potter, P.C. 7777 Bonhomme Avenue, #1810 St. Louis, MO 63105 . 314-862-3 800; fax: 314-862-3953 Joseph O'Hara, Jr. / Matthew Fischer / Fiona Burke Schiff, Hardin & Waite *. 6600 Sears Tower 233 South Wacker Drive Chicago, IL 60606-6473 312-258-5500; fax: 312-258-5700 e-mail: mfischer@schiflhardin.com Robert Riley Schiff, Hardin & Waite 7200 Sears Tower Chicago, IL 60606 . 312- ; fax: 312-258-5600 James Toohey / Joseph Janatka Ross & Hardies 150 North Michigan Avenue Chicago, IL 60601-7567 312-558-1000; fax: 312-750-8600 Robert W. Wilkinson Dogan & Wilkinson, P.L.L.C. 726 Delmas Avenue, P. O. Box 1618 Pascagoula, MS 39568-1618 228-762-2272; fax: 228-762-8246 Richard F. Nash Brasher Law Firm, L,C. 211 North Broadway, Suite 2300 St. Louis, MO 63102 314-621-7700; fax: 314-621-1088 Consolidated Rail United States Steel (USX) SCAPA . , Hammermill Paper Company International Paper Company/Champion International Paper Company/Hammermill International Paper Company/Nicolet Champion Intemation Corporation Donald J. Dahlman Walker* Williams, P.C. 4343 West Main Street Belleville, IL 62226 618- Thomas W. Alvey, Jr. Thompson Cobum (Belleville) 525 West Main Street, P. O. Box 750 Belleville, IL 62222-0750 618-277-4700; fax: 236-3434 Tad Armstrong 101 West Schwartz Street P. O. Box 565 Edwardsville, IL 62025 ... ' fax: 656-6808 Joseph Ostrowski Baughman & Associates 55 Public Square, Suite 2215 Cleveland, OH 44113 216-687-1244; fax: 216-621-4066 Edward J. Matushek / David A. Nilles Matushek & Associates One North LaSalle Street, #3210 Chicago, IL 60602 312-750-1215; fax: 312-750-1273 e-mail; danilles@matushek.com Dan O'Connell / John O'Sullivan / John Tammes O'Connell & O'Sullivan 217 N, McLean Blvd., Suite 2-C Elgin, IL 60123 847-741-4603; fax: 847-741-4692 Michael J. Kanute / Michael L. Volin Holland & Knight, LLP 55 West Monroe, Suite 800 Chicago, IL 60614 312-263-3600; fax: 312-578-6666 International Harvester Company Ashland, Inc. Marcal Paper Mills, Inc. ACME Steel Company DuPont Technical Products, Inc. Lear Siegter (Thomas & Betts) Martin H. Katz Katz Huntoon & Fieweger, P.C. 1705 Second Avenue, POB 3250 Rock Island, IL 61204-3250 309-788-5661; fax: 309-788-5688 Larry J. Chilton Chilton, Yambert, Porter & Coghlan 150 South Wacker Drive, Suite 2400 Chicago, IL 60606 312-460-8000; fax: 312-460-8299 Robert J. Luddy Windels Marx Lane & Mittendorf 156 West 56th Street New York, NY 10019 212-237-1000; fax: 212-262-1215 e-mail: rluddy@windelsmarx.com James Dobeus Cremer Kopon Shaughnessy & Spina LLC 180 North LaSalle, Suite 3300 . Chicago, IL 60601 312-726-3800; fax: 312-726-3818 Russell W. Baker, Jr. Spence Fane Britt & Brown (Kansas City) 1000 Walnut Street Suite 1400 Kansas City, MO 64106-2140 816-474-8100; fax: 816-474-3216 e-mail: rbaker@spencerfane.com Leo W. Nelsen Holtkamp Liese Childress & Schultz 217 North 10th, Pennsylvania Bldg., #400 St. Louis, MO 63101-2003 314-621-7773; fax: 314-231-4384 e-mail: lnelsen@holtkampliese.com Erin L. Alexander McBride Baker St Coles 500 West Madison, 40th Floor Chicago, IL 60661 312-715-5700; fax: 312-993-9350 *. Reynolds Metal Co. Air Products & Chemicals LTV Steel Co. Lever Brothers Company Emmerson Electric Merck & Co., Inc. Gulf Coast Marine Supply Company Richard L. Miller, n Butler Rubin Saltarelli & Boyd 70 West Madison, Suite 1800 Chicago, IL 60602-4257 312-444-9660; fax: 312-444-9287 Stephen Rovak Sonnenschein Nath & Rosenthal One Metro Square, Suite 3000 St. Louis, MO 63102 314-241-1800; fax: 314-259-5959 Ezio Listati 200 Public Square, #40-104 Cleveland, OH 44114 216-622-5701; fax: 216-642-7062 Cory D. Anderson Connelly Roberts & McGivney LLC One North Franklin, Suite 1200 Chicago, IL 60606-3401 . 312-251-9600; fax: 312-251-9601 Daniel G, Nienhuls von Briesen, Purtell & Roper 735 North Water Street Milwaukee, WI53202 414-273-7000; fax: 414-273-7897 e-mail: dnienhut@vonbriesen.com Jennefer K. Fardy Seyfarth Shaw 55 East Monroe, Suite 4200 Chicago, IL 60603-5803 . 312-346-8000; fax: 312-269-8869 e-mail: jfardy@seyfarth.com Marcy Bryan Forman Perry Watkins Krutz & Tardy PLLC One Jackson Place, Suite 1200 188 East Capitol Street (POB 22608) Jackson, MI 39225 601-960-8600; fax: 601-960-3241 e-mail: ctownsend@fpwk.com *. 1 J.S. Alberici Construction Co. Missouri Drywall Supply, Inc. Lisa M. Warrer Rabbitt, Pitzer & Snodgrass, P.C. 800 Market Street, Suite 2300 St. Louis, MO 63101 314-421-5545; fax: 314-42L3144 e-mail: waner@rabbittlaw.com Sona Rewari / Alexandra Brisky Hunton & Williams 1751 Pinnacle Drive, Suite 1700 McLean, VA 22102 703-714-7000; fax: 703-714-7410 e-mail: abrisky@burton.com CENTRAL RECORDS DEPOSITORY 203 West High Street Edwardsville, EL 62025 r I IN THE CIRCUIT COURT THIRD JUDICIAL CIRCUIT MADISON COUNTY, ILLINOIS IN RE: ALL ASBESTOS LITIGATION FILED BY THE SIMMONS FIRM, LLC, Plaintiffs, vs. A.W. CHESTERTON, et al., Defendants. ) ) ) } ) ) ) ) ) BEAZER EAST. INC., AS SUCCESSOR IN INTEREST TO KOPPERS COMPANY. INC.'S OBJECTIONS AND ANSWERS TO INTERROGATORIES Now comes Beazer East, Inc,, Individually, and as Successor to Koppers Company, Inc., and Incorrectly Identified as Successor in Interest to Thiem Corporation and Universal Refractories Company, and for its objections and answers to interrogatories submitted by The Simmons Firm, L.L.C., states as follows: PRELIMINARY STATEMENT AND GENERAL OBJECTIONS 1. Defendant objects to the overly broad and burdensome nature ofthese interrogatories. They are overly broad and unduly burdensome insofar as they request information and documents covering over 50 years and information which might be contained in over 27,000 boxes of material which are not indexed in any way relevant to this litigation. Many of the individuals who might have . had personal knowledge of the matters to which these interrogatories relate are either deceased or otherwise unavailable to this defendant. Various divisions of this defendant were sold in the 1980's and information and/or documents which are in control of the acquiring companies are no longer available for review by this defendant. Investigation and discovery into the matters requested in these interrogatories is ongoing and this defendant states that it will make available to the plaintiffs for inspection and copying non-privileged documents related to the products described which it has gathered to date and reserves the rights to supplement the responses as additional information becomes available. This preliminary statement and general objections apply to all of the discovery .. requests and responses. Notwithstanding this objection, Defendant believes that it has exercised due diligence to secure the information and refers Plaintiff to the response to Interrogatory #2 which sets forth the efforts made to respond. Defendant further objects because at this time it is unknown whether any individual Plaintiffs' alleged exposure was to roofing products or to products used in the steel making process and, therefore, the discovery requests are not limited to products relevant' to this litigation. PLAINTIFFS* INTERROGATORIES Please take notice that pursuant to Illinois Supreme Court Rule 213(d), you are required to serve sworn answers upon the undersigned to the following interrogatories within twenty-eight (28) days after service hereof. The defendant corporation or company shall designate an officer or agent who will 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. PLAINTIFFS* INSTRUCTIONS 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, then state and answer to the fullest 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 acquire the information. .. . You are to answer the following interrogatories by placing your answers, when possible, in the spaces provided. DEFINITIONS A. "Defendant," as used herein, includes the above-named defendant. B. "Predecessor" or "predecessor entity or company" as used herein means any entity which owned any assets or owner's equity of this defendant at any time prior to and including the present. The term predecessor or predecessor entity or company as used herein specifically includes any parent entity which now owns or has in the past owned ten percent or more of the named defendant either directly or indirectly through another entity. C. "Related company" is as defined in Judge Byron's Order of April 14, 2000, D. "Asbestos-containing product" as used herein means any product which included any form of asbestos as any part of its composition or ingredients. This term shall also mean any equipment or machinery, including but not limited to, boilers, generators and turbines, in or on which an asbestos-containing product as defined above was incorporated, added, utilized or applied prior to being sold, distributed or installed by.this Defendant. . E. "Documents," as used herein, include, without limitation, books, records, notes, letters, correspondence, memoranda, writings, invoices, purchase orders, contracts, sales ledgers, recordings, journals or books of account, 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 every means. % "Documents" also includes the content of any applicable computer database. F. Where used with respect to documents, "identify" means to give the date, title, origin, author and addressee ofthe document and 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, Defendant may respond by attaching a copy of the responsive document to the answers to these interrogatories. Where used with respect to a person, "identify" means to give the person's name, employer, title or position with that employer, and business address and last known home address if the person' is no longer so employed. If the person identified is, or has been, an employee, officer, director or agent of Defendant, also state the period of time during which he/she has been employed by Defendant, and all positions, titles or jobs that person has held with the Defendant and the years each position was held. G. Where appropriate, the singular includes the pleural and vice-versa, INTERROGATORIES INTERROGATORY NO. 1: Identify the person answering these interrogatories on behalf of Defendant. ANSWER: Jill Blundon, former Vice-President and General Counsel of Thiem Corporation only. on the issues of the corporate relationships of Thiem, Universal, Koppers and Beazer and Mary D. Wright, Esquire, Litigation Manager of Beazer East, Inc., in consultation with counsel. INTERROGATORY NO. 2: Has the person answering these interrogatories made reasonable inquiry of all available sources of information such that Plaintiff may rely upon these answers as the truthful and complete answers made on behalf of Defendant? List any and all such sources of information relied upon, including, but not limited to, identifying any and all records or documents reviewed and persons providing information. . ANSWER: . See the General Objections. Since there is no current employee with knowledge concerning all of the information requested, Mary Wright bases her knowledge upon corporate information, corporate documents and prior discovery responses and depositions including the depositions produced which are: Charles Flickinger Donald McGraw, M.D. Drew Bachman Duane W. Caves Edwin J. Davidson Walter Richard Sylvester Byron Lee Allison, III Elizabeth Lyle Mary Dombrowski Wright, Esq. Jill Blundon, Esq. - Regis Frederick 06/11/98 06/23/97 06/24/97 06/20/97 06/28/84 07/21/94 10/27/93 10/07/83. 05/09/88 01/19/94 06/24/97 06/23/97 06/27/97 04/13/94 01/19/94 10/07/83 06/07/88 07/21/94 She is also familiar with the corporate history based upon her employment with the defendant since 1985 and based upon her review of the following documents: ,. Annual Reports: 1944 - 1988; Material Safety Data Sheets on roofing; Universal hot top product information; State and SEC filing regarding the acquisition of Thiem and merger into Koppers subsidiary; Sale of Thiem to National Starch; Dissolution of Thiem Corporation, 1991; Asset Purchase Agreement for Sale of Universal to Walt Sylvester; Labels for rolled roofing; Sweets Manuals fiom 1964 to 1985; 1953 Memberships and Representatives for Koppers; Koppers Company and Beazer East, Inc. Insurance Coverage Information; Thermal Insulation Manual by Koppers, 1952; Subscriptions listing from Monroeville library; . EPA documents and EPA/roofing related information; . In-house memos re: OSHA/NIOSH regulations; Information re: Aluminum Roof Coating 435; Koppers Company Asbestos-Containing Roofing Products Listing; Price List for some products including some asbestos roofing products; Articles/memos from outside sources re: asbestos and asbestos in roofing materials; Internal memo re: worker health and safety product liability claim; INTERROGATORY NO. 3: State the following concerning this Defendant: (a) Full and correct name; (b) The form in which Defendant presently conducts business (i.e. corporation, partnership, proprietorship, etc.); (c) Identify any and all predecessors and related companies as defined above; (d) Any and all other forms in which defendant has conducted business at any time, and the date(s) when business was conducted in each form; (e) Any and all names by which Defendant has been known or has conducted business, at any time, and the date(s) during which Defendant has been known by and/or conducted business, under each such name; (f) Defendant's principal place of business; . (g) Defendant's present state of incorporation or state in which Defendant is registered as a partnership, association, etc., whichever is applicable; if Defendant has, at any time, been incorporated or registered in a different state, identify which state and when; (h) Most recent date of incorporation or reincorporation, and any and all prior date(s) of incorporation or reincorporation; (i) Whether this Defendant is authorized to transact business in the State of Illinois and, if so, the date such authority was first issued and last renewed; (j) If this Defendant has an agent, representative or place of business in Illinois, identify such agent, representative, or place of business; and, (k) If this Defendant has an agent for service in the State of Illinois, identify the registered agent. , ANSWER: (a) Beazer East, Inc.; (b) Corporation; (cj See response to number 10; (d) Koppers Company, Inc. was incorporated as a Delaware corporation in 1944. On June 16, 1988, BNS, Inc. ("BNS"), a Delaware corporation, and an indirect wholly owned subsidiary of Beazer PLC, acquired indirectly more than 90% of the outstanding common stock of Koppers Company, Inc. On November 14,1988, BNS acquired indirectly the balance of the common shares. On January 26, 1989, the name of Koppers Company, Inc. was changed to Beazer Materials and Services, Inc, On April 16,1990, Beazer Materials and Services, Inc. changed its name to Beazer East, Inc.; (f) Defendant does not have a principal place of business; (g) Delaware; (h) see Interrogatory 3(d); (i) yes, November 24, 1944; (j) no; (k) yes, CT Corporation System, 208 South LaSalle Street, Chicago, IL 60601. INTERROGATORY NO. 4: Has Defendant been sued under its correct legal name? If not, state the correct legal name of Defendant and provide the information requested in No. 3 above concerning the defendant as correctly named. ANSWER: Its correct name is Beazer East, Inc., formerly known as Koppers Company, Inc. INTERROGATORY NO. 5: Identify any and all persons or entities which own, or at any time have owned, more than a ten percent (10%) interest in this Defendant, and for each such person or entity identified, state the date(s) during which said person or entity owned more than a ten percent (10%) interest in Defendant and the specific type and amount of interest owned. ANSWER: Because Koppers Company, Inc. was in business from 1944 until 1988 and continued in business as Beazer East, Inc, until the present time, these Interrogatories are overly broad, burdensome and impossible of response. However, in an attempt to respond to the Interrogatories and pursuant to Illinois Supreme Court Rules, Defendant attaches copies of its annual reports from 1944 until 1988. INTERROGATORY NO. 6: Identify any and all companies, businesses, corporations, and/or joint ventures in which this Defendant owns, or at any time has owned, more than a ten percent (10%) interest and which engaged in the design, manufacture, selling, distributing, applying, installing or re-labeling of products containing asbestos. ANSWER: Defendant attaches copies of its annual reports from 1944 to 1988. At this time it is believed that only Thiem Corporation had asbestos .products and only knew that its products contained asbestos at a time before Beazer had its interest in Thiem Corporation. In addition see response to number 10. INTERROGATORY NO. 7: With respect to each corporation, company, business or joint venture identified in response to Interrogatory No. 6 state: (a) The type of business, conducted by such related company; (b) The past and present business relationship(s) between said related company and Defendant; (c) The nature of the products or services which Defendant has sold to, or purchased from, said related company; (d) Whether or not said related company advertises or has advertised products or services supplied by Defendant; (e) Whether or not said related company sells or has sold Defendant's products or services within the State of Illinois and, if so, the approximate value of those sales ' from 1930 to date; (f) Whether or not said related company pays taxes of any type to the State of Illinois or to any political subdivision thereof and, if so, the type of taxes paid; (g) Whether or not Defendant controls or has controlled, directly or indirectly, in whole or ip part, said related company's advertising; and, . (h) The identity of any past or present officer or director of Defendant who, at any time, served as an officer or director of said related company. ANSWER: Because Koppers Company, Inc. was in business from 1944 until 1988 and continued in business as Beazer East, Inc. until the present time, these Interrogatories are overly broad, burdensome and impossible of response. However, in an attempt to respond to the Interrogatories and pursuant to Illinois Supreme Court Rules, Defendant attaches copies of its annual reports from 1944 until 1988. In addition see response to number 10. INTERROGATORY NO. 8: List all directors and officers of Defendant from 1940 to date and for each state all positions held and the date(s) during which each position was held. . ANSWER: Because Koppers Company, Inc. was in business from 1944 until 1988 and continued in business as Beazer East, Inc. until the present time, these Interrogatories are overly broad, burdensome and impossible of response. However, in an attempt to respond to the Interrogatories and pursuant to Illinois Supreme Court Rules, Defendant attaches copies of its annual reports from 1944 until 1988. INTERROGATORY NO. 9: State whether any of Defendants' present or former officers or directors ever served (whether before, during or after becoming Defendants' officer or director) as an officer or director of any other company, corporation or business which manufactured, sold or distributed asbestos or asbestos- containing products and, if so, please: ' (a) Identify each officer and director of Defendant, who served as such other company's officer or director; and (b) Identify each company, corporation or business for which each such officer or director served, each position held by such officer or director for such other company, corporation or business, and the time periods each position was held. ANSWER: Ifany officer or director of the Defendant acted as an officer or a director of any other company, that person conducted that business beyond the scope of his or her capacity with this defendant. Thus, Defendant would have no information to allow it to respond to Interrogatory No. 9. The names of the officers and directors are included in the annual reports from 1944 until 1988 which are produced. INTERROGATORY NO. 10: Has Defendant ever acquired, through purchase, reorganization or merger, another company,' corporation or business which manufactured, sold, processed, distributed or contracted to apply, asbestos and/or asbestos-containing products? ANSWER: Koppers Company, Inc. acquired the stock of Thiem Corporation. Thiem was an existing corporation having been incorporated in 1947. Thiem Corporation was merged into Koppers Subsidiary Company, a subsidiary corporation of Koppers, on March 4,1977, and the surviving corporate entity was Thiem Corporation. Koppers owned the stock of Thiem as a wholly owned subsidiary corporation from 1977 until late 1988. The assets of Thiem Corporation were sold to National Starch and Chemical Company, now known as Henkel Surface Technologies, on December 28, 1988. Thereafter, Thiem existed only as a shell corporation until it was officially and legally dissolved on June 7,1991 in Delaware. Universal Refractories Corporation was incorporated in Wisconsin on October 23, 1957, as a wholly owned subsidiary of Thiem Corporation, and continued to operate as such until it was merged into Thiem on December 21,1976. Universal's assets were sold to Walter R. Sylvester, an individual who had been employed as Vice President ofthe Universal Division of Thiem, on December 27,1983. At that point, Universal Refractories ceased to have any relationship with Koppers Company, Inc. or Thiem Corporation. INTERROGATORY NO. 11: If the answer to Interrogatory No. 10 is "Yes," with respect to each such predecessor: (a) State its full and correct name; (b) State its principal place of business; (c) State its State of incorporation; (d) State its date and manner of acquisition by Defendant; (e) Whether this predecessor was, at any time, authorized to transact business in the State of Illinois; and (f) Identify any and all documents referring to, relating to or reflecting the acquisition. ANSWER: a-d. See the information provided in interrogatory # 10 and see the documents produced. e. Investigation continues. f. See the documents produced as follows: State and SEC filing regarding the acquisition of Thiem by Koppers subsidiary; Sale of Thiem to National Starch; Dissolution of Thiem Corporation, 1991; Asset Purchase Agreement for Sale of Universal to Walt Sylvester. INTERROGATORY NO. 12: Has Defendant ever acquired from another corporation, company, or business, by any means other than those specified in Interrogatory No. 10, assets or rights to manufacture, sell, distribute or apply asbestos or asbestos-containing products? ANSWER: No. ' . :_ INTERROGATORY NO. 13: If the answer to Interrogatory No. 12 is "Yes," with respect to each such acquisition: (a) State the full and correct name of the company from which such assets or rights were acquired; (b) State the principal place of business of the company from which said assets or rights were acquired; (c) Describe the assets or rights acquired, including the specific asbestos-containing products to which said assets or rights related; and (d) Identify any and all documents referring to, relating to or reflecting the transaction. ANSWER: Not applicable. INTERROGATORY NO. 14: Other than any transaction identified in response to Interrogatories Nos. 10-13, has this Defendant ever been involved, in any capacity, including but not limited to, seller, transferor, grantor, franchisor, licensor, buyer, transferee, grantee, franchisee or subject of the transaction, in any transaction, of any kind, concerning any of the following: (a) the purchase/sale or transfer of ownership of a company, corporation or business which manufactured, sold, processed, distributed or contracted to apply asbestos and/or asbestos-containing products; pr (b) the purchase/sale or transfer of ownership of the assets or rights to manufacture, sell, distribute or apply asbestos or asbestos-containing products; or (c) the purchase/sale or transfer of liabilities arising out of the manufacture, sale, processing, distribution or application of asbestos or asbestos-containing products. ANSWER: No. INTERROGATORY NO. 15: ... If the answer to any sub-part of Interrogatory No. 14 is "Yes," with respect to each such transaction: (a) Identify all parties to the transaction; (b) Identify the subject matter of the transaction; (c) State the date of the transaction; and, (d) Identify any and all documents, referring to, relating to or reflecting the transaction. ANSWER: Not applicable. INTERROGATORY NO. 16: State the first and last dates on which any asbestos-containing product was manufactured by: (a) Defendant; (b) each and every predecessor; and, (c) each and every related company. ANSWER: *. * (a) Beginning sometime in the mid to late 1960's when certain assets of Addex Company were acquired until sometime between 1984 and 1986, Beazer East, Inc. formally known as Koppers offered for sale certain asbestos containing roofing products. Koppers Company, Inc.'s roofing division offered for sale asbestoscontaining felts saturated with either tar or asphalt from approximately 1964 until 1985. These products were sold as Koppers No. 15 Tar Saturated Asbestos Roofing Felt or Koppers No. 15 Asphalt Saturated Asbestos Roofing Felt, Koppers did not actually manufacture the felt, but merely saturated the felt purchase from third parties with tar or asphalt. In addition, see attached list of asbestos-containing roofing products manufactured by Koppers Company, Inc. and the Sweets Manuals which are produced. Further listing is contained in document entitled Koppers Company Asbestos Containing Roofing Products listing which has been produced. Finally, Koppers believed that for a brief period of time around 1980-1982, a roofing product named Exeltherm was produced which incorporated asbestos-containing paper. However, Defendant is continuing its investigation into this matter. As to the E and C division, see answer #22.; (b) Defendant has no predecessor company; and (c) during the time it was a wholly owned subsidiary of Thiem Corporation, Universal Refractories, Inc. manufactured asbestos containing products from 1969 until 1975 or January 1976 at the latest. Universal Refractories, Inc., while a wholly owned subsidiary of Thiem Corporation, manufactured foundry products called hot tops for the steel making industry. These products contained asbestos from approximately late 1969 until January 1976 at the latest. In late 1975, Universal substituted the asbestos in its product with Hedmanite that was purchased from a company called Hedman Mines. In 1979, Hedman began labeling its products "may contain asbestos." The Hedmanite was then removed from Universal's products. As to the Beazer products, see the Sweets Manuals from 1964 to 1985, the information regarding Aluminum Roof Coating 435, the Koppers Company Asbestos-Containing Roofing Products Listing. For a more complete description of the Universal Products, see the depositions of Davidson, Sylvester and Frederick and the Universal Hot Top Product information which have been produced. INTERROGATORY NO. 17: State the first and last dates on which any asbestos-containing product was specified, sold, distributed, applied and/or installed within the United States by: (a) Defendant; (b) each and every predecessor; and, (c) each and every related company. ANSWER: See Interrogatory No. 16. INTERROGATORY NO. 18: State the last date on which Defendant or any related company specified, sold, distributed, applied and/or installed any asbestos-containing product outside the United States and identify by brand or trade name the products so specified, sold, distributed, applied and/or installed. ANSWER: It is not believed that any of the roofing products were sold outside of the United States. It is not believed that any of the Universal hot top products were sold outside of the United States. The E & C Division was sold in 1984. Investigation continues as to locations outside of the United States where steel making facilities may have been constructed. . .. INTERROGATORY NO. 19: Identify by full and complete trade name, any and all asbestos-containing products as defined above, which this Defendant, any related company, or any predecessor(s) has, at any time: (a) Designed; (b) Manufactured; (c) Processed; (d) Sold; (e) Distributed; (f) Applied; (g) Installed; (h) Patented; (i) Specified; or (j) Re-labeled. ANSWER: (a-e) See No. 16.; (1) None; (g) None. See No. 22; (h-j) None. INTERROGATORY NO. 20: With respect to each asbestos-containing product listed for each subpart of Interrogatory No. 19: (a) Identify the specific company (Defendant, predecessor, related company) which designed, manufactured, processed, specified, sold, distributed, applied, installed, patented or re-labeled such product; (b) State the year in which Defendant, its related company or its predecessor first designed, manufactured, processed, specified, sold, distributed, applied, installed, patented or re-labeled such product; and, (c) State the year in which the Defendant, its related company or predecessor last designed, manufactured, processed, specified, sold, distributed, applied, installed, patented or re-labeled such product. ANSWER: See Interrogatory No. 16. INTERROGATORY NO. 21: Were any of the products, which were listed in response to Interrogatory No. 19 as having been specified, sold, distributed; applied or installed by Defendant, its predecessor or related company(ies), purchased from another company and relabelled for sale or distribution by Defendant, its predecessors or related companies? If so, identify those products, and with respect to each: (a) Identify the company from which Defendant, its predecessor or related company purchased the product; and, (b) Identify the company which manufactured the product; and, , .. (c) State the date(s) during which said re-labeled product was sold, distributed or applied. ANSWER: No. Products were not re-labeled. Koppers did not actually manufacture any asbestos-containing felts, but merely saturated the felt purchased from third parties. The third parties were Carey, Celotex, GAF or Nicolette, INTERROGATORY NO. 22: Has this Defendant, at any time, applied, contracted to apply, installed or engaged in the business of applying or installing, asbestos-containing products? If so: (a) State the date(s) on which or during which Defendant applied, contracted to apply, installed or engaged in the business of applying or installing asbestos-containing products; (b) Identify any and all sites within the State of Illinois at which Defendant applied, installed or contracted to apply or install asbestos-containing products, and for each such site: (i) State whether the products you applied, installed or contracted to apply or install were included as part of the project's contract price or whether you applied the products that were provided at the work site; (ii) Identify by manufacturer and trade name each and eveiy asbestos-containing product applied or installed; (iii) State the date(s) during which said application or installation took place; (iv) Identify the employee(s) of Defendant who was (were) in charge of the job; (v) Identify the person or entity for which the products were applied or installed; and ' (vi) Identify all documents relating to such contract, application or installation. ANSWER: The remainder of the interrogatory is objected to on the basis that it is overly broad and duly burdensome and not reasonably calculated to lead to the discovery of relevant information. Koppers Company, Inc.'s Engineering and Construction Division designed and constructed steel making facilities. Koppers E & C Division did not manufacture asbestos-containing products. Typically, the owners of facilities purchased the necessary material for projects from third parties who delivered these materials to the construction site. However, this practice varied with each customer and each contract. These materials may have included asbestos-containing products. Defendant is unable to identify all sites in Illinois, but if a specific plaintiff identifies the name of the location or job site, this defendant will make every reasonable effort to. try to identify whether the E & C Division had any involvement with such facility. INTERROGATORY NO. 23: Has this Defendant, any predecessor or any related company, ever engaged in the business of mining asbestos? If so: (a) Identify which company(ies) whether (Defendant, predecessor or related company) engaged in said business; (b) State the date(s) during which each said company engaged in such business; (c) State each and every location at which such mining was done; (d) Identify each and every officer, employee and/or agent of said company who, at any time, was in charge of each mining operation; and, (e) Identify each and every entity, if any, to which said company sold the asbestos which was mined. ANSWER: No. INTERROGATORY NO. 24: Has this Defendant, any predecessor or any related company ever purchased and resold raw asbestos? If so, with respect to each such purchase and resale: (a) State the date(s) of the transaction; (b) Identify any and all parties from which the raw asbestos was purchased; and, (c) Identify any and all parties to which the raw asbestos was sold. ANSWER: No, INTERROGATORY NO. 25: Identify each and every source from which Defendant, any predecessor or related company, obtained raw asbestos and/or asbestos-containing material used by Defendant, any predecessor or related company, to manufacture or process any product listed in response to Interrogatory No. 19, ANSWER: To date, Defendant has been unable to identify any documents which would provide it with information regarding the companies from whom raw asbestos was purchased. As to Koppers and the roofing felts, see response to interrogatory #21. As to Universal and the hot tops, North American Asbestos, McCann Shields in Pittsburgh, Carey Canada, and perhaps J.M., and as to the lizardite which may have contained asbestos, Hedman Mines. Defendant will continue its investigation and will supplement this Interrogatory if and when any additional information is discovered. INTERROGATORY NO. 26: Is Defendant or any related company, as of the date of answering these interrogatories, still manufacturing, specifying, selling, distributing, applying or installing any asbestos-containing product? If so, give the brand/trade names of such products, type and percentage of asbestos in such product, and the date on which Defendant or any related company first manufactured, specified, sold, distributed, applied or installed said products. ANSWER: No. INTERROGATORY NO. 27: With respect to each and every product listed in response to Interrogatory No. 19, provide a full and complete description of the package in which the product was sold, including, but not limited to, type of package, size, color and writings thereon. ANSWER: Koppers' Roofing felts were sold in rolls with a paper wrapper around the roll and the labels are produced. In addition, see the Sweets Manuals which have been produced for a description of packaging. With respect to Universal Refractories, the hot top materials were shipped on palettes and wrapped with "shrink wrap." A label was placed on the shrink wrap identifying Universal as the manufacturer. There was a ladle hanging from a crane and the word UNRECO. For further descriptions ofthe Universal products, see the depositions of Sylvester, Frederick and Davidson. As to the E and C division of Koppers, see response 22. . , INTERROGATORY NO. 28: For each siibpart below, state whether or not, to Defendant's knowledge, any items as described therein presently exist and, if so, identify any and all such existing items and state the present location of each: (a) any product listed in response to Interrogatory No. 19, including, but not limited to, any sample, part or piece thereof; (b) any package of the type in which any or all of the products listed in response to Interrogatory No. 19 were or would have been sold, including, but not limited to, any partial package; (c) any catalogue, brochure, sales literature or like item referring to, relating to or reflecting any or all of the products listed in response to Interrogatory No. 19; (d) any picture, drawing, photograph or like representation of the items described in subparts (a), (b) and/or (c) of this Interrogatory. ANSWER: (a) Defendant is not able to provide any samples or parts or pieces thereof of any product identified in Interrogatory No. 19; (b) As to the roofing products, see attached copies of labels; (c) see attached Sweets catalogs for roofing materials and attached copies,of Universal Refractory brochures; (d) see (c). .. INTERROGATORY NO. 29: Did Defendant, any related company or any predecessor ever stamp or otherwise place (including affixing tags or labels) a company name, initials, or any identifying logo on any of the products listed in response to Interrogatory No. 19? . .. ANSWER: As to the Beazer roofing products, see the labels which are produced, and see the Sweets catalogs to the extent they contain photographs of the packaging. As to Universal and the hot tops, see the depositions of Sylvester, Frederick and Davidson. INTERROGATORY NO. 30: . If your answer to Interrogatory No. 29 is "Yes," identify each and every such product upon which such name, initials or identifying logo appeared and for each such product identified: (a) Describe each and every name, initials or identifying logo appearing on said product, at any time, by stating the wording, lettering, symbols, size, color and manner in which it was stamped, placed or affixed to said product; (b) State the date(s) during which each such name, initials, or identifying logo appeared on said product; and (c) Identify any and all documents referring to, relating to or reflecting the stamping, placing or affixing of names, initials or logos to said product, including, but not limited to, any pictures, photographs or like representations of such names, initials or logos ANSWER: See answer 29. INTERROGATORY NO. 31: Was each of the asbestos-containing products listed in response to Interrogatory No. 19 generally expected to reach, or was each packaged to reach, the consumer or user, without substantia] change in the condition in which it was sold? ANSWER: Yes. INTERROGATORY NO. 32: 'm If your answer to Interrogatory No. 31 is "No" with respect to any produces), explain in whatmanner Defendant claims said produces) were altered or substantially changed after sale or distribution and before reaching the consumer or user. ANSWER: Not applicable. INTERROGATORY NO. 33: With respect to each product listed in response to Interrogatory No. 19, state whether, based upon the material contents, the method of manufacturing, and the method of application, such product could generally be applied or installed without liberating asbestos fibers? ANSWER: Yes. INTERROGATORY NO. 34: With respect to each product listed in response to original Interrogatory number 19, could it be expected or anticipated that the product might have to be removed, stripped or replaced at any time after application or installation? ANSWER: Yes. INTERROGATORY NO. 35: Identify each person who participated in the design and/or preparation of manufacturing specifications for each product listed in response to Interrogatory No. 19. ANSWER: As of this time, defendant has been unable to determine who participated in the design and/or preparation of manufacturing specifications for roofing products. As to the hot tops, the deposition testimony ofUniversal employees, Sylvester, Davidson and Frederick describes the Universal employees involved in developing hot top products. INTERROGATORY NO. 36: Identify any and all documents, including, but not limited to, written. memoranda, specifications, blueprints, formulas, patterns and designs, referring to, relating to or reflecting the design, preparation, application and/or installation of each product listed in response to Interrogatory No. 19. ANSWER: Defendant has been unable to locate any such documents except those listed in this interrogatory. As to the roofing products, the Sweets Manuals would contain information regarding the application or installation of the product. In addition, the information regarding aluminum roof coating 43,5 contains information regarding. installation. As to the Universal hot top products, defendant is attempting to locate, the document referred to in the deposition of Edwin Davidson taken July 21,1994, which is referred to as a legendry for a 31" x 35" x 88" ingot mold. In addition, see the Universal hot top brochures. INTERROGATORY NO. 37: With respect to each product listed in response to Interrogatory No. 19, state: (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; (c) Any modification 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) Any and all other names under which the product was sold, at any time; (g) The number and date of each patent or patent application for each product; (h) Ifthe product continued to be produced after the deletion of asbestos, all reasons why the asbestos was deleted, the identity of the person(s) who made the decision to' delete the asbestos, and the date the product was first produced without the asbestos; (i) If the product is no longer produced, all reasons it was discontinued, the identity of the person(s) who made the decision to discontinue the product, the brand name of the replacement product, and the date the replacement product first went into production; and (j) The reasons why asbestos was used as an ingredient in each such product. ANSWER: With respect to roofing felts as follows: (a-e) felts were purchased from either Carey, Celotex, GAF or Nicolette, and this Defendant does not know the percentage of asbestos contained in the asbestos felt or the type. As to other roofing products see a document entitled Asbestos containing Roofing Products which contains percentages of asbestos. The asbestos felt was coated with either tar or asphalt resulting in a dark brown to black color to the felt.; (f) See the labels which are produced.; (g) None.; (h and i) Roofing felts without asbestos were manufactured and sold during the same period of time from the time of acquisition of Addex to a time between .1984 and 1986. Asbestos felts comprised a small. portion of the sales and were sold by special order. There were discussions involving Drew Bachman, Ken Brozowski and others who are unidentified at this time who generally became aware of the health concerns involving asbestos, and it was decided to stop selling asbestos felts between 1984 and 1986. They were eliminated from the catalog in 1981. Further information is contained in the depositions which are produced.; (j) Unable to determine at this time, but investigation continues, but Jill Blundon stated that if a customer wanted asbestos felts they would specify so, As to roof coatings, liquid asphalt and other products referred to on the list which is produced as follows: (a, b, c and d) Unknown; (e) aluminum or black; (f) see the Sweets Catalogs and Roofing Product Listing; (g) none; (h) for financial reasons, but it is unknown who made the decision or ifthe decision making process was between 1984 and 1986; (i) see the commercial roofing announcement dated 1/10/86 signed by James Weideman which is produced in the category of EPA documents and EPA/roofing related information; (j) Unable to determine at this time, but investigation continues. As to hot top products, (a) chiysotile at first and then a mixture of chrysotile and amosite with more amosite being used than chiysotile in the mix; (b) the side board was 11% asbestos and the ring, 18 to 20% asbestos; (c) none; (d) North American Asbestos and McCann Shields; (e) gray and tan; (f) see the hot top brochures and the depositions of Regis Frederick, Walter Sylvester and Ed Davidson; (g) see the depositions of Regis Frederick, Ed Davidson and Walter Sylvester; (h) see the depositions of Regis Frederick, Ed Davidson and Walter Sylvester; (i) see the depositions of Regis Frederick, Ed Davidson and Walter Sylvester; (j) see the depositions of Regis Frederick, Ed Davidson and Walter Sylvester. INTERROGATORY NO. 38: * ' Identify any and all facilities at which Defendant, any predecessor or any related company, at any time, manufactured or processed asbestos-containing products, or processed raw asbestos. For each such facility identified: (a) State the date(s) which said facility was owned and/or operated by Defendant, any predecessor or any related company; (b) State the date(s) during which asbestos-containing products and/or raw asbestos were manufactured or processed, at said facility; and, (c) Identify each person serving as the manager or supervisor of said facility during any time which the facility has been owned and/or operated by Defendant, any predecessor or any related company, and state the date(s) of the tenure as manager or supervisor for each. ANSWER: . ., With respect to Universal Refractories, manufacturing was conducted in Wampum, Pennsylvania and Greenville, Pennsylvania, and Oak Creek, Wisconsin. Defendant, Beazer East, Inc., never owned the operating facilities of Universal Refractories. Universal Refractories manufactured asbestos-containing products during the years 1969 to probably Januaiy 1976 at the latest, when it was a wholly owned subsidiary of Thiem Corporation. Walter Sylvester was the general manager of Universal Refractories Corporation while it was a wholly owned subsidiary of Thiem Corporation and manufactured asbestos-containing products. Hedmanite may or may not have contained asbestos when it was used from 1975 to 1979. With respect to roofing products, manufacturing was conducted at Youngstown, Ohio; Cicero, Illinois; Woodward, Alabama; and Wickliffe, Ohio between 1964 and 1987, Charles Kraynik was plant manager at Youngstown, Ohio, when it closed. Jeny Morris was at Woodward. Investigation continues as to the others. INTERROGATORY NO. 39: Identify any and all entities to which the defendant, any predecessor or related company, sold, distributed or otherwise provided any type of asbestos-containing product, including but not limited to, the products listed in response to original Interrogatory number 19, and which the defendant has any reason whatsoever to suspect, believe, think or otherwise conclude that said asbestos-containing product was installed, applied, stored, or anyway made use of at any site listed in Exhibit "A", at any site located in Madison County, Illinois, or at any site within a 200 mile radius of Madison County, Illinois. ANSWER: This defendant is unaware of any category or any lists which would give such information. If individual plaintiffs provide job site information on Exhibit A and products on Exhibit B, Defendant will make a good faith effort to identify whether it sold products identified in Interrogatories 19 and 42 to said employer or job site identified. INTERROGATORY NO. 40: Identify any and all persons known by you to have any knowledge concerning the manufacture, sale, distribution, possession, application, installation or use of the products listed in response to Interrogatory No. 19. ANSWER: This interrogatory is overly broad and could encompass any individuals in the plants where the products were made and, notwithstanding the objection, Koppers has identified and located the following. As to the roofing division materials of Koppers the following: Drew Bachman, Andrew Noble, Swen Swenson, Frank Moore, Joe Nusbaum, Tom Isaj, Jim Weideman, Mary Dombrowski Wright and other identified in the documents produced by this defendant. As to the E & C Division, it would depend upon the facility being constructed and the time of construction. As to Universal Refractories: Walter Sylvester, Regis Frederick, Edwin Davidson and numerous others identified in the depositions of Sylvester, Davidson and Frederick. INTERROGATORY NO. 41: .. Has Defendant, any predecessor or any related company, at any time, designed, manufactured, processed, sold, distributed, supplied, applied, installed or contracted to apply or install any product which contained vermiculite? ANSWER: To the best of Defendant's knowledge, information and belief, no. INTERROGATORY NO. 42: Ifyour answer to Interrogatory No. 41 is "Yes," identify by brand/trade name any and all such products which contained vermiculite and for each: (a) State the date(s) during which said product contained vermiculite; (b) State, in percentage terms, the amount of vermiculite contained in the product; (c) Identify the source of the vermiculite used in the product; (d) Identify the specific company (Defendant, predecessor, related company) which designed, manufactured, processed, sold, distributed, applied, installed or patented such product; (e) State the year in which Defendant, its related company or its predecessor first designed, manufactured, processed, sold, distributed, applied, installed or patented such product; . ', (f) State the year in which the Defendant, its related company or predecessor last designed, manufactured, processed, sold, distributed, applied, installed or patented such product; (g) State whether any sample, part or piece of such product is still in existence; and (h) Identify all documents relating to such product, including but not limited to any package, brochure, catalog, picture, photograph or like representation of the product or packaging. * ANSWER: Not applicable. INTERROGATORY NO. 43: With respect to the products listed in response to Interrogatory Nos. 19 and 42, did Defendant, any predecessor or related company or the manufacturer of the products ever conduct tests of any kind on any or all of said products concerning possible of potential health hazards involved in its use ot in the use of materials contained therein? ANSWER: "*' With respect to interrogatory #42, this is not applicable. With respect to the products listed in 19 and limiting response to tests regarding asbestos, as to the roofing products any asbestos would have been encapsulated and the answer is no. Furthermore, with respect to the roofing division, the United States EPA and OSHA exempted asbestos-containing roofing products ffom regulation because the asbestos . incorporated into such products was completely encapsulated and the potential for the release of friable asbestos did not exist. Thus, Defendant did not conduct any such tests. With respect to Universal Refractories products, Beazer East, Inc. did not have an interest in Thiem Corporation when Thiem's wholly owned subsidiary. Universal Refractories, was aware it manufactured asbestos-containing products. Thus, no such testing could have been conducted by the Defendant. INTERROGATORY NO. 44: If your answer to Interrogatory No. 43 is "Yes," with respect to each product test: (a) State the location where the test was performed; (b) Identify each and every individual who conducted or participated in said test; (c) Describe the results of said test; (d) State the date or dates upon which said test was conducted; (e) Identify any and all documents referring to, relating to or reflecting said test or the results thereof; and (f) Identify each and every individual who received a copy of any document referring to, relating to or reflecting the results of said test. ANSWER: See Interrogatory No. 43. INTERROGATORY NO. 45: Did any person, including but not limited to, an officer, agent or employee of Defendant, any predecessor or related company recommend any design changes as a result of any test referenced in your response to the preceding interrogatory? ANSWER: . .. Because no such tests were conducted, this Interrogatory is not applicable to this Defendant. *. '' INTERROGATORY NO. 46: If your answer to Interrogatory No. 45 is "Yes," with respect to each such recommended design change: . ,. (a) State the product or products involved; (b) State the test or tests involved; (c) State the nature of the change recommended; (d) Identify the person(s) making the recommendation; (e) State the nature and effective date of any change made; and (f) Identify each and every person who participated in the decision to make or not make the recommended design change. . ANSWER: Not applicable. INTERROGATORY NO. 47: Identify any and all persons employed by Defendant, its predecessor or related company at any time from 1940 to date as an industrial hygienist or in a similar position. ANSWER: Charles Flickinger, who is no longer employed by this defendant; David Williams, who is no longer employed by this defendant. INTERROGATORY NO. 48: Identify any and all persons or entities, other than the employees listed above, which provided industrial hygienic or similar services or information to, or for the benefit of, this Defendant, at any time from 1940 to date, including, but not limited to, employees of, or anyone retained by, any predecessor or related company. .. . ANSWER: Dr. Anna Baetjer who is deceased. INTERROGATORY NO. 49: Does Defendant have, or has Defendant, any predecessor or any related company ever had, a Research Department? If so: (a) State when such department was established, and whether or not such department has operated continuously since being established; (b) State how much Defendant, its predecessor and/or related company expended each year on research; and (c) State the percentage of said expenditure which was for research concerning the health affects of asbestos; (d) Identify the person(s) in charge of such department throughout its existence; and (e) Identify the person(s) in charge of any asbestos-related research conducted by such department throughout the years. ANSWER: Yes, Defendant has been unable to determine, based upon the documents available to it, information to respond to Interrogatory No. 49. Defendant will continue its investigation in this regard and will supplement this Interrogatory upon the discovery, if any, of additional information. This defendant produces the subscriptions listing from the Monroeville library which contains information about a research department. INTERROGATORY NO. 50: Did Defendant, any predecessor or any related company, or. any medical department or industrial hygiene division thereof, maintain a medical and/or scientific library at any time from 1940 to the present? If so; (a) State the dates such library existed; (b) State the number of volumes maintained therein; . (c) State the number of employees, part-time or full-time, assigned to the maintenance of said library; and (d) Identify the person(s) within the corporate structure to whom said library employees reported throughout the existence of the library. answer; Based upon the documents available to it, defendant has been unable to determine whether there was a library for the medical department or any industrial hygiene division thereof, however, this defendant responds as follows: (a) It is uncertain when any such library began, but it was dismantled in 1989; (b) unknown, but see the subscriptions listing from the Monroeville Library for information on the library; (c) see the deposition of Elizabeth Lyle where she states at one point and time 6 employees; (d) Eugene Meckley at some point in time as further described in the depositions of Elizabeth Lyle. INTERROGATORY NO. 51: Identify any and all scientific or medical periodicals to which Defendant, any predecessor or any related company, or any medical department or industrial hygiene division thereof, subscribed from 1940 to the present, and for each periodical state the dates of such subscriptions. ANSWER: See answer 50. INTERROGATORY NO. 52: Has Defendant, any predecessor or any related company, at any time since 1940: (a) been a member of a medical and/or scientific library or library association? (b) been a member ofany organization or association which maintained a medical and/or scientific library? (c) been a member of any organization,or association through which members obtained the use of, or access to, a medical and/or scientific library? ANSWER: Defendant refers plaintiff to the 1953 memberships and representatives listing and subscription listing from Monroeville Library which it has produced. This defendant does not know the extent to which any ofthese organizations are considered medical, scientific or library associations or to the extent which those organizations maintained libraries. INTERROGATORY NO. 53: If your answer to any subpart of Interrogatory No. 52 is "Yes": (a) Identify the library(ies) involved and state the years during which Defendant, its predecessor or related company was a member of, or otherwise had use of or access to said library; and (b) If applicable, identify the organization or association through which Defendant, its predecessor or related company, obtained the use of or access to, such library(ies). ANSWER: . See answer 52, . INTERROGATORY NO. 54: Has Defendant, any predecessor or any related company, or any person or entity acting on behalf thereof, including but not limited to, any insurance company, at any time, conducted any industrial hygiene surveys concerning any product identified in response to Interrogatory No. 19, including, but not limited to, surveys concerning the manufacture, processing, application, installation, use and/or removal of said products? ANSWER: . Universal Refractories was not aware it manufactured an asbestos-containing product during the years that Koppers Company, Inc. had an interest in Thiem Corporation. Therefore, no such surveys could have been conducted by this Defendant. With respect to the roofing division, the Defendant is unaware of any such surveys being conducted. As to Thiem, see the depositions of Sylvester, Frederick & Davidson. Also, see deposition of Regis Frederick wherein he testified that at some point after the Koppers acquisition of Thiem there was some monitoring conducted by Koppers personnel from Monroeville. As to the roofing division, see the 1997 deposition of Charlie Flickinger wherein he testified that some testing was done inside one of the plants. No such documents have been located regarding any testing so it is unknown whether this information is responsive to this interrogatory. Investigation continues, INTERROGATORY NO. 55: If your answer to Interrogatory No. 54 is "Yes," with respect to each such survey: . (a) Identify the produces) which was used in the survey; (b) Identify any and al1 person(s), firm(s) or entity(ies) conducting or participating in the conducting of said survey; (c) State the date(s) of said survey; (d) Describe the methodology, results and conclusions of said survey; (e) Identify any and all documents referring to, relating to, or reflecting said survey or the results and conclusions thereof; and, (f) Identify any and all persons to whom such document may have been sent. ANSWER: . Not applicable. . INTERROGATORY NO. 56: Has Defendant, any predecessor or any related company, or any person or entity acting on behalf thereof, including but not limited to any insurance company, at any time, gone into any area where any product identified in response to Interrogatory Nos. 19 and 42 was being manufactured,. used, applied or installed to perform a dust level count or similar test? ANSWER: This defendant has been unable to locate any such documents and does not have information at this time. INTERROGATORY NO. 57: Ifyour answer to Interrogatory No. 56 is "Yes," identify each such count or test performed, by stating when and where it was conducted, and with respect to each count or test so identified: (a) Identify the product being manufactured, used, applied or installed; .. . (b) Identify each and every person who conducted, participated in conducting, or analyzed the results of, said count or test; (c) State the purpose of said count or test; (d) State what, if any, actions were taken in response to the results of said count or test; and . (e) Identify any and all documents referring to, relating to or reflecting said count or test, including, but not limited to, any actions taken in response to the results of such count or test. ANSWER: Not applicable, INTERROGATORY NO. 58: , Has Defendant, any predecessor or any related company, or any person or entity.acting on behalf thereof, at any time, conducted any study(ies), of any kind, concerning the effects of the inhalation of asbestos dust or asbestos fibers on one using or being exposed to asbestos or any asbestos-containing product, including, but not limited to, those identified in response to Interrogatory Nos. 19 mid 42? ANSWER: See Interrogatory No. 54. INTERROGATORY NO. 59: If your answer to Interrogatory No. 58 is "Yes," with respect to each such study: (a) Describe the nature of said study, including, but not limited to, the purpose and objectives of the study, the produces) involved, the date(s) conducted, the methodology employed and the results reached, both raw data and conclusions; (b) Identify any and all entities and/or persons conducting said study or participating in the conducting of said study; . (c) Identify any and all documents referring to, relating to or reflecting said study, including but not limited to reports (both interim and final), notes, memoranda, work papers, data compilations and surveys; (d) Identify any and all directors, officers, agents or employees of Defendant who participated in the decision to have the study conducted; and, (e) Identify any and all entities and/or persons who received a copy of any document referring to, relating to or reflecting the results or conclusions reached. ANSWER: Not applicable, INTERROGATORY NO. 60: Did Defendant, its predecessor or related company, take any action as a result of any study or studies set forth in response to Interrogatory Nos. 56 and 58? If so, identify each and every study which resulted in some action being taken, and: (a) Describe the actions taken, including the effective date of said actions; (b) Identify any and all persons, including, but not limited to, directors, officers, agents and employees of Defendant who participated in the decision to undertake said actions; and (c) Identify any and all documents referring to, relating to or reflecting said actions, or any subsequent modification or discussion of the same. ANSWER: Not applicable. INTERROGATORY NO. 61: Has Defendant, any predecessor, or any related company, or any person or entity acting on behalfthereof, at any time, conducted any study(ies) designed to minimize or eliminate the inhalation of asbestos dust and fibers by those using, handling or exposed to any product listed in response to Interrogatory Nos. 19 and 42? ANSWER: - . * Universal Refractories manufactured asbestos-containing products while it was a wholly owned subsidiary of Thiem Corporation, during years when this Defendant had no interest in Thiem Corporation. Thus, no such studies could have been conducted by this Defendant. In addition, see answer 54. With respect to the roofing division products of Koppers Company, Inc., because the U.S. EPA and OSHA exempted asbestos-containing roofing products from regulation because of the belief that the asbestos was completely encapsulated and not susceptible to the release of friable asbestos, no such studies were conducted. INTERROGATORY NO. 62: If your answer to Interrogatory No. 61 is "Yes," with respect to each such study: (a) Identify the product involved; (b) Identify the person(s) and/or entity(ies) conducting said study; (c) State the date said study began and the date on which it was completed;. . (d) Identify any and all persons, including, but not limited to, directors, officers, agents or employees of Defendant, who participated in the decision to have said study conducted; (e) Describe the nature of said study; (f) Describe the nature ofany action to eliminate or minimize inhalation of asbestos dust or asbestos fibers undertaken as a result of said study; (g) Identify any and all documents referring to, relating to or reflecting said study or the. results thereof; and, (h) Identify any and all persons receiving a copy of any document referring to, relating to or reflecting the results or conclusions of said study. . .. ANSWER: Not applicable. INTERROGATORY NO. 63: Did Defendant, any related company, or any predecessor at any time, give to persons, who . . would be applying and/or removing any of the products listed in response to Interrogatory Nos. 19' and 42, any instructions or guidelines concerning precautions, warnings, procedures, and/or methods to use, in order to safely apply or remove such products? If so, describe such instructions, state to whom they were given, state the dates they were given, and describe the manner in which they were given. ANSWER: Please see attached labels from Koppers Company's roofing division. In addition, see the Sweets Manuals, which is the product catalog in the 1980, 1981 and 1982 manuals which contain the following warning regarding Exeltherm II Roof Insulation. The warning stated: Warning: The facers of this product contain asphalt saturated asbestos fiber. The Occupational Safety and Health Administration (OSHA), an agency of the United States government, believes that repeated inhalation of asbestos fiber is a health hazard and may cause various diseased including asbestosis and cancer. This Defendant is unaware of any warnings being placed on Universal Refractories asbestos-containing products manufactured at a time when this Defendant, did not have an interest in Thiem Corporation or at any time thereafter. INTERROGATORY NO. 64: Did Defendant, any predecessor or any related company, at any time, place any warning signs or labels on the containers in which any of the products listed in response to Interrogatory Nos. 19 and 42 were packaged? ANSWER: No as to the roofing division. Please see attached labels from Koppers Company's roofing division. This Defendant is unaware of any warnings being placed on Universal Refractories asbestos-containing products manufactured at a time when this Defendant did not have an interest in Thiem Corporation or at any time thereafter. INTERROGATORY NO. 65: If your answer to Interrogatory No. 64 is "Yes,'1 identify each and every product upon which such a warning was placed, and with respect to each such product identified: (a) State the date on which any order directing that a warning be placed on said product first issued; (b) Identify any and all persons participating in the decision to issue that order; (c) State the first date on which such warning was actually placed on said product; (d) State the first date on which such product accompanied by such warning was first sold, distributed or installed; (e) State the exact wording of this first warning; (f) State the exact location and size of this first warning as it appeared on said product; (g) Identify any and all persons who participated in any phase of the drafting or design of said first warning, including, but not limited to, those who performed the actual drafting and design work, those who reviewed the work, those who edited the work and those who approved the warning; (h) State why you placed such warning on said product, including, but not limited to, whether you placed such warning on said product 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; and (i) Identify any and all documents referring to, relating to or reflecting, said warning, its drafting, and/or the decision to place the warning on said product, including, but not . limited to, any communication as described in subpart (h) of this Interrogatory. ANSWER: Not applicable. INTERROGATORY NO. 66: With respect to each product identified in response to Interrogatory No. 65 as having been accompanied by a warning, state whether, subsequent to the first warning described above, any different warning was ever placed upon said product. Any alteration, change or modification in the language, wording, capitalization, punctuation, style of type or printing, size, color, or location on the package or container, of the warning constitutes a different warning. ANSWER: Not applicable. INTERROGATORY NO. 67: With respect to each different warning which accompanied each product listed in response to Interrogatory No. 65: (a) State the date on which any order directing that such different warning be placed on said product first issued; .. (b) Identify any and all persons participating in the decision to issue that order; (c) State the first date on which such different warning was actually placed on said product; . (d) State the first date on which such product accompanied by such different warning was sold, distributed or installed; (e) Describe, with specificity, any and all changes, modifications or differences between the different warning and the prior wamings(s); (f) Identify any and all persons who participated in any phase of the drafting or design of such different warning, including, but not limited to, those who performed the actual drafting and design work, those who reviewed the work, those who edited the , work and those who approved the different warning; (g) State why you placed such different warning on said product;, including, but not limited to, whether you placed such different warning on said product 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; and (h) Identify any and all documents referring to, relating to or reflecting, said different warning, its drafting, and/or the decision to place the different warning on said ' product. . ... ANSWER: Not applicable. INTERROGATORY NO. 68: Prior to the date on which Defendant first directed that a warning accompany any product identified in response to Interrogatory Nos. 19 and 42, did any person, firm, organization or other entity, within or without your employ, suggest, recommend, counsel, advise, or otherwise indicate . in any manner, that a warning should accompany any or all such products or asbestos-containing products generally? ANSWER: Not applicable. INTERROGATORY NO. 69: If your answer to Interrogatory No. 68 is "Yes," with respect to each such suggestion, recommendation, counseling, advice or other indication: (a) Identify the person(s) and/or entity(ies) giving the same; (b) State the date(s) on which the same was given; (c) Identify any and all persons receiving notice ofthe same; (d) Describe what, if any, action Defendant took in response to or upon the same; and, (e) Identify any and all documents referring to, relating to or reflecting the.same, or any action taken thereon or in response thereto. ANSWER: Not applicable. INTERROGATORY NO. 70: Did Defendant, any predecessor, or any related company ever place any warning directly upon any of the products listed in response to Interrogatory Nos. 19 and 42? ANSWER: See answer 64. To the best of the Defendant's knowledge, information and belief, no markings of any type were placed on Beazer's products. This Defendant did not have an interest in Thiem Corporation when its subsidiary, Universal Refractories, was aware it manufactured asbestos-containing products. Based upon documents provided to it, Defendant does not believe that any stamp of any type was placed directly on the products. INTERROGATORY NO. 71: Ifyour answer to Interrogatory No. 70 is "Yes," identify each and every product upon which such a warning was placed and for each such product identified: (a) State, verbatim, each and every warning which ever appeared on said product; (b) State the size, color; and. location of each such warning and describe the manner in which it was placed upon the product; (c) State the dates on which each such warning first and last appeared in said product; and, (d) Identify any and all documents referring to, relating to or reflecting the placing of any warning directly upon said products, including, but not limited to, decisions not to place such a warning. ANSWER: Not applicable. INTERROGATORY NO. 72: Did any warning of any type concerning the products listed in response to Interrogatory Nos. 19 and 42 ever appear in any sales literature or other materials distributed or provided by Defendant, any predecessor or any related company, to the purchasers, consumers and/or users of such products? ANSWER: - ' ' See sales brochures for roofing products and MSDS sheet for aluminum roof coatings.'' Investigation continues. . INTERROGATORY NO. 73: If your answer to Interrogatory No. 72 is "Yes," identify each and every item of sales literature or other materials in which such a warning appeared, and for each item so identified; (a) State the date on which said item was first provided to distributors, sellers, purchasers, consumers or users; (b) List the products discussed in the literature; . (c) Identify any and all other sales literature concerning the products listed in response to Interrogatory Nos. 19 and 42 which was provided to distributors, sellers, purchasers, consumers or users after the above date and which contained no warning. ANSWER: See sales brochures for roofing products and MSDS sheet for aluminum roof coatings. Investigation continues.. INTERROGATORY NO. 74: Does Defendant or any related company have any of the following in its possession, custody or control: (a) any package, container, label or item of sales literature which Defendant claims constitutes or contains any warning which ever accompanies any product listed in response to Interrogatory Nos. 19 and 42? (b) any picture, photograph or like reproductive representation of any item described in subpart (a)? ANSWER: See attached labels and sales brochures for roofing products. INTERROGATORY NO. 75: State the year that Defendant or any predecessors) was first advised of either threshold limit values or maximum allowable concentrations of both asbestos dust and total dust, promulgated .by the American Conference of Governmental Industrial Hygienists, and identify the specific person(s) receiving such advise, and any and all documents communicating such advise. ANSWER: Based upon.records available to it, the Defendant is unable to determine exactly when it became advised of threshold limit values or maximum allowable concentrations or the person who was first so advised. However, Defendant believes that it became generally advised when such information was published to the public. INTERROGATORY NO. 76: State whether such threshold limit values or maximum allowable concentrations referred to in Interrogatory No. 75 involved TOTAL dust or just asbestos dust? ANSWER: Threshold limit values were not applied to Koppers Roofing products when it manufactured asbestos-containing roofing products, Thus, Defendant is unable to respond to Interrogatory No. 76 as it does not apply to Defendant's products. Because Defendant, Beazer East, Inc., had no interest in Thiem Corporation when its wholly owned subsidiary, Universal Refractories Corporation, was aware it manufactured asbestos-containing products, this Defendant is unable to .respond to Interrogatory No. 76 as it related to Universal Refractories' products. INTERROGATORY NO, 77: Describe, in detail, any and all tests, if any, conducted by Defendant, any predecessor or any related company, or anyone acting on behalf thereof, concerning the quantity, quality or threshold limit values of asbestos dust or particles to which applicators or consumers of asbestos-containing products were exposed while using any product identified in response to Interrogatory Nos. 19 and 42, including: (a) The product being used; (b) Identify any and all person(s), firm(s) or entity(ies) conducting or participating in the conducting of said test; (c) State the date(s) of said test; (d) Describe the methodology, results and conclusions of said test; (e) Identify any and all documents referring to, relating or reflecting said test or the results and conclusions thereof; and, (f) Identify any and all persons to whom any document referring to, relating to or reflecting the results or conclusions of said test was sent. ANSWER: Because the United States EPA and OSHA exempted asbestos-containing roofing products from TLV's, Koppers Company did not conduct such tests. With respect to Universal Refractories, it thought it had discontinued the manufacture of asbestos- containing products when the stock of Thiem Corporation was purchased by the Defendant. . INTERROGATORY NO. 78: Did Defendant, any predecessor or any related company, at any time, directly advise the owners or management employees of any work site in which it sold or applied any product listed in response to Interrogatory Nos. 19 and 42, of threshold limit values for exposure to asbestos dust recommended by the American Conference of Governmental Industrial Hygienist? If so, state the date or dates that you so advised each such owner or employees, the manner in which you advised such owner or employee and the name of each such owner or employee. ANSWER: Because the U.S. EPA and OSHA exempted asbestos-containing roofing products from threshold limit values for exposure to asbestos dust, no such advise was required of Koppers Company, Inc. With respect to Universal Refractories, this Defendant had no interest in Thiem Corporation when Universal Refractories was aware it manufactured asbestos-containing products. INTERROGATORY NO. 79: State the date on which any official of Defendant or its predecessor(s) first had knowledge',' notice, information or understanding that exposure to asbestos would, could or might cause each of the following diseases: (a) Pleural disease; (b) Asbestosis; . (c) Mesothelioma; (d) Lung cancer; (e) Any other forms of cancer. ANSWER: Defendant objects to this Interrogatory as calling for a medical opinion. Without waiving such objection, Defendant is unaware of any documents or other information containing the exact date upon which it became aware that certain levels of exposure in certain workers can cause the development of certain diseases. However, Defendant believes that it became generally aware in the 1970's when the public became generally aware that certain high level exposures to asbestos could cause various diseases in certain workers. See the documents produced for additional information. INTERROGATORY NO. 80: With respect to each disease set forth in Interrogatory No. 79: (a) Identify the official who first obtained the knowledge, notice, information or understanding to which the interrogatory refers; (b) Identify any and all documents referring to, relating to or reflecting such knowledge, notice, information or understanding; and, (c) Describe what, if any, action said official, Defendant, any predecessor or any related company took in response to such knowledge, notice, information or understanding. ANSWER: See Interrogatory No. 79. INTERROGATORY NO. 81: Is Defendant aware, or does Defendant possess knowledge or information concerning, a causal connection between exposure to asbestos or asbestos-containing products and: '' (a) pleural disease? (b) asbestosis? (c) lung cancer? (d) mesothelioma? (e) other cancer? ANSWER: See Interrogatory No. 79. INTERROGATORY NO. 82: For each subpart of Intenogatory No. 81 to which you answered "Yes": (a) Describe when and how Defendant first obtained knowledge, or information concerning such connection; (b) If such knowledge or information was obtained by. attendance at any conference, lecture, convention, symposium or meeting, identify such meeting, any and all persons attending, and any and all documents referring to, relating to or reflecting the meeting; (c) If knowledge was obtained from medical or scientific studies, or work, published or unpublished, identify the same. ANSWER: See Interrogatory No. 79. INTERROGATORY NO. 83: With regard to any knowledge or information obtained subsequent to that identified in your answer to Interrogatory No, 82 (a), identify any and all documents or communications (oral and/or written) concerning the causal connection between exposure to asbestos-containing or asbestos products and any disease, which were sent to, of received by, Defendant, and identify any and all persons conveying and/or receiving such communications. ANSWER: See the documents produced, ' INTERROGATORY NO. 84: As to any knowledge or information referred to in Interrogatories 79-83, did Defendant, at any time, educate or inform its employees, distributors, purchasers or any persons working in the vicinity where any asbestos-containing product was being applied or installed as to the hazards known to Defendant or about which Defendant had information, and as to the safety precautions necessary to guard against cancer and other diseases arising from the use and handling of the products identified in response to Interrogatory No. 19? ANSWER: Defendant objects to this Interrogatory in that it assumes facts not in evidence. It assumes that there was a hazard known to the Defendant about which the Defendant had information connecting its asbestos-containing products to a hazard. On the contrary, Defendant believes and therefore avers that because the United States EPA and OSHA exempted asbestos-containing roofing products from regulation. Defendant had no such knowledge and no such hazard existed. This defendant did not have an interest in Thiem Corporation when its subsidiary, Universal Refractories, was aware it manufactured asbestos containing products and therefore even using this defendant had any obligation or duty regarding Universal or Thiem products the answer is no. As to the E & C Division, this defendant is unaware of any such information at this time. INTERROGATORY NO. 85: If your answer to Interrogatory No. 84 is "Yes," identify each such occasion on which Defendant so educated or informed its employees, distributors or purchasers, as follows: . (a) Identify the persons or parties which you educated or informed; (b) State when, where and in what manner they were educated or informed; (c) Identify any and all documents referring to, relating to or reflecting the communication or other dissemination of such information; and . (d) Identify any and all persons who so educated or. informed said employees, distributors, purchasers or persons working in the vicinity of application or whcr participated in the same in any way, including, but not limited to, assembling, drafting, writing, rewriting, preparing or conveying such information in any format. ANSWER: Not applicable. INTERROGATORY NO: 86: Did Defendant or any predecessor entity perform, direct to be performed, finance in whole or in part, sponsor in whole or in part or receive the results of, any studies or tests concerning the relationship between asbestos exposure and asbestosis, cancer and/or mesothelioma? ANSWER: No. INTERROGATORY NO, 87: .. If your answer to Interrogatory No. 86 is "Yes," with respect to each such study or test: (a) State the nature of the involvement {performed, directed it to be performed, financed, sponsored, received results, etc.); (b) State when, where and at what intervals said study was performed; (c) Identify any and all persons, firms or entities which performed said study; 4 (d) Identify any and all documents referring to, relating or reflecting said study or the results thereof; and (e) State all means by which the results of said study were disseminated including, if applicable/publication; and identify any and all persons who received said results and any and all publications in which said results appeared. ANSWER: Not applicable. INTERROGATORY NO. 88: Did Defendant at any time during the period that the products listed in response.ato Interrogatory Nos. 19 and 42 were manufactured, sold, applied or installed, inform any purchaser or user ofsaid products that such products could cause cancer, asbestosis, and/or other serious diseases? ANSWER: Defendant refers the plaintiff to the 1980 Sweets Manual on roofing products which contains the warning that reference to the Exeltherm II roof insulation that states "the occupational safety and health administration (OSHA) (an agency of the United States Government, believes that repeated inhalation of asbestos fiber is a health hazard and may cause various diseases including asbestos and cancer". As to the E & C Division, this defendant is unaware ofany such information. This defendant did not have an interest in Thiem Corporation when its subsidiary, Universal Refractories was aware it manufactured asbestos containing products and therefore the answer is no. INTERROGATORY NO. 89: Did Defendant, any predecessor or any related company, or any workers' compensation insurance carrier thereof, ever have any claims for lung diseases or death from lung disease, whether directly or indirectly attributed to asbestosis, mesothelioma, lung cancer, or exposure to asbestos- containing products? ANSWER: Yes. INTERROGATORY NO. 90: If your answer to original Interrogatory number 89 was "yes", please provide the following information for each and every employee ofthe defendant, predecessor or related company with such a claim. If the claimant was a non-employee, please provide the information for the first 100 cases of which the defendant had notice. (a) Identity the claimant; (b) Identify the entity against which the claim was filed; (c) State the date upon which the claim was filed; . , >.* (d) List the locations(s) at which claimant was exposed to asbestos; (e) Identify each and every board, administrative body, commission or court which handled or reviewed said claim and state the state the style and cause number applicable to said claim before each such body; (f) Identify the disease alleged by claimant; (g) State the final disposition of the claim including any and all benefits paid, and the entity making such payments; (h) If different from the date on which the claim was filed, state the date on which defendant first had notice of the claim; and . (i) Identify any and all documents referring to, relating to or reflecting said claim, ANSWER: . Defendant objects to the overly broad and burdensome nature of this request and states that it has no document or other information that would contain all of the information requested. But notwithstanding the objection, defendant states that it did not keep a chronological list of the earliest law suits or worker's compensation claims. As to the worker's compensation claims defendant refers plaintiff to the document in the materials entitled Internal Memo Regarding Worker Health and Safety Product Liability Claim which appears to indicate a workers compensation claim filed around 1984 by Joseph Vantoso. Investigation continues as to worker's compensation claims. Also in the materials produced it appears that the earliest claims were in the early 1980's. A memo in the documents entitled EPA Documents and EPA/Roofing Related Information from Mary Ann Marino dated July 23,1980 references the case of Gardner v. Koppers. Memos in the file entitled Internal Memo Re: Worker Health and Safety Product Liability Claim dated February 25, 1985 seems to indicate litigation in Cleveland entitled Edward Vitu v. Armstrong Cork, et al.. and another memo in that file dated January 3,1985 indicates there may have been litigation involving Norfolk and Western. In addition, a letter from Koppers legal department to outside attorney, Robert Little, pertaining to a law suit entitled Sapp v. Universal Refractories seems to indicate the existence of litigation in 1981. This letter is further described in the privilege log. Investigation is continuing as to these law suits and as to other litigation that may have been pending in the 1980's. Depositions have been produced which give information on some of the law suits against Universal and Beazer East, Inc. Efforts are being made to obtain more information to the extent such information is available. INTERROGATORY NO. 91: How many past or present employees of Defendant, its predecessors or related companies are known by you to be suffering from, to have suffered from, or to have suffered deaths caused by: (a) asbestosis? (b) lung cancer? (c) mesothelioma? . ANSWER: Based upon records available to it, the Defendant is unable to determine whether any of its employees or former employees allege suffering from diseases listed in Interrogatory No. 91. INTERROGATORY NO. 92: For each employee referenced in your answer to Interrogatory No. 91, state the date that Defendant first knew, or had notice or information, that such past or present employee was suffering, or had suffered from: (a) asbestosis; (b) lung cancer; (c) mesothelioma. ANSWER: Not applicable. INTERROGATORY NO. 93: Identify any and all material safety data sheets concerning the products listed in response to Interrogatory Nos. 19 and 42 prepared, at any time, by, or on behalf of. Defendant, any predecessor or any related company. ANSWER: As to the roofing products see attached the material safety data sheets. As to any Thiem or Universal products, defendant is unaware of any such MSDS sheets. INTERROGATORY NO. 94: Identify any and all trade organizations, associations, or other entities, including but not limited to American Textile Institute (ATI), Asbestos Information Association (AIA), Industrial Health Foundation or Industrial Hygiene Foundation (IHF), National Insulation Manufacturers Assn. (NBVLA), National Insulation Contractors Assn. (NICA), National Safety Council (NSC), American Ceramics Society (ACS), National Building Materials Distributors Assn. (NIA), Sprayed Mineral Fiber Manufacturers Assn. (SMFMA), Thermal Insulation Manufacturers Assn, (TIMA), Quebec Asbestos Mining Assn. (QAMA), to which Defendant, any predecessor or any related company has belonged or in which any or all of the same have participated since 1925, and state the applicable dates of such membership or participation. .. ANSWER: - ...... . .. See the documents entitled 1953 Memberships and Representatives for Koppers which provides the information available to this defendant at this time on this subject. In addition other documents produced might indicate other memberships to which Koppers or its employees belonged. INTERROGATORY NO. 95: Identify any and all persons attending, on behalf ofDefendant, any predecessor or any related company, any meetings, seminars or symposiums held by the trade organizations, associations, or other entities identified in response to Interrogatory No. 94. ANSWER: See the answer to 94. INTERROGATORY NO 96: Did any officer, employee, agent or representative of Defendant, of any predecessor, or of any related company, serve, at any time, as: (a) an officer, director or official of any trade organization, association or entity identified in response to interrogatory No. 94? . ... (b) a member of any committee or subcommittee of any trade organization, association or entity identified in response to Interrogatory No. 94? (c) the chair of any committee or subcommittee of any trade organization, association or entity identified in response to Interrogatory No. 94? (d) the representative or liaison for any trade organization, association or entity identified in response to Interrogatory No. 94 to any other trade organization, association or entity, 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., N.A.C., N.S.C., A.C.S., N.B.M.D.A, N.I.A., S.M.F.M.A.? ANSWER: . Based upon records available to it, Defendant is unable to determine whether any of its officers, directors or employees was an officer, director or employee of a trade organization as outlined in Interrogatory No. 96, unless it is set forth in document referred to in interrogatory number 94. INTERROGATORY NO. 97: :^ For each subpart of Interrogatory No, 96 to which your answer is "Yes," identify each and eveiy person serving in such capacity and: (a) state the trade organization, association or entity for which such service was rendered; (b) specify the capacity of service, including identifying any specific committee, subcommittee or other trade organizations, associations or entities involved; and, (c) state the applicable dates of service. ANSWER: See Number 96. INTERROGATORY NO. 98: Identify any and all documents which Defendant, its predecessors) or any related company submitted to, or received from, the organizations listed in response to Interrogatory Nos. 94 and/or 97: (a) which refer to, relate to or reflect the subject of asbestos; ' (b) which refer to, relate to or reflect a relationship between asbestos exposure and any disease; and/or (c) which refer to, relate to or reflect the placement or providing of warnings with . respect to hazardous products. ANSWER: . Defendant is not in possession of any such documents therefore cannot identify any such documents, however, defendant refers plaintiff to the 1953 Membership list which is produced and the description listing to the extent that the information is contained herein. INTERROGATORY NO. 99: Identify any and all documents including, but not limited to, minutes, bulletins or reports, created by, or on behalf of, any trade organization, association or entity listed in response to Interrogatory No. 94 and/or 97 or any committee, subcommittee or subgroup thereof; (a) which refer to, relate to or reflect the subject of asbestos; (b) which refer to, relate to or reflect a relationship between asbestos exposure and any disease; or (c) which refer to, relate to or reflect the placement or providing of warnings with respect to hazardous products. ANSWER: See response to Number 98. INTERROGATORY NO. 100: Identify any and all documents including, but not limited to, minutes, bulletins or reports, received by, or on behalf of, any trade organization, association or entity listed in response to Interrogatory No. 94 and/or 97, or any committee, subcommittee or subgroup thereof; (a) which refer to, relate to or reflect the subject of asbestos; ** (b) which refer to, relate to or reflect a relationship between asbestos exposure and any disease; or (c) which refer to, relate to or reflect the placement or providing of warnings with respect to hazardous products. ANSWER: See the response to Number 98. INTERROGATORY NO. 101: Identify any and all agreements, oral or written, between or among Defendant, any of the other defendants in this lawsuit, any organization, association or other entity including, but not limited to. those identified in your answer to Interrogatory No. 94 and/or any 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 transport 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 ofdissemination of public relations information to 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: ; Defendant is unaware of any such agreements. INTERROGATORY NO. 102: Did Defendant, any predecessor or related company, direct to be performed, sponsor in whole or in part, finance in whole or in part, receive the results of, or become 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 health? ANSWER: No. ; , v . . - INTERROGATORY NO. 103: If your answer to Interrogatory No. 102 is "Yes": (a) Identify any and all documents received by Defendant, its predecessors), or a related company referring to, relating to or reflecting any findings or results of those studies or tests, and state the date upon which each was first received; (b) Identify any and all communications (oral or written), between Defendant, its predecessors) or a related company and Saranac personnel, including but not limited to Gerrit W.H. Schepers, M.D.; . . . (c) Identify any and all documents referring to, relating to or reflecting the Saranac studies received or submitted by Defendant, its predecessor(s) or a related company either directly, through related or predecessor companies, through other companies, or through any trade associations, organizations or other entities; and (d) Identify any and all documents referring to, relating to or reflecting 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, ANSWER: Not applicable. INTERROGATORY NO. 104: With respect to each subject listed below, state whether said subject was, at any time, discussed at a meeting of the board of directors of Defendant, any predecessor or any related company: ... (a) The sale and/or marketing of any asbestos-containing product, including, but not limited to, the products listed in response to Interrogatory Nos. 19 and 42; (b) The health hazards resulting from exposure to asbestos, including, but not limited to, exposure resulting from the use, application or removal of asbestos-containing products; (c) The placement or possible placement of warning labels on asbestos-containing products or their packages, or in sales literature, therefore including, but not limited to, the products listed in response to Interrogatory Nos. 19 and 42; and (d) Any test, survey, study or similar matter concerning asbestos or asbestos-containing, products, including, but not limited to, the products listed in response to Interrogatory Nos. 19 and 42. ANSWER: Based upon review of documents from the Board of Directors of the Defendant, no such discussions are reflected. . INTERROGATORY NO. 105 Ifyour answer to any one or more of the subparts ofInterrogatory No. 104 is "Yes," then with respect to each subpart for which you answered "Yes": (a) Identify each and every board meeting at which said subject was discussed by stating the date(s) on which, and the location(s) at which, each meeting was held; (b) Identify any and all persons present at each such meeting; and, (c) Identify any and all documents, including, but not limited to, minutes, referring to, relating to, or reflecting each such meeting. ANSWER: Not applicable. . INTERROGATORY NO. 106: Identify any and all seminars, symposiums, conferences or like gatherings attended by any officer, agent or representative of Defendant, any predecessor or any related company, at which the subject of asbestos, the health hazards of asbestos exposure, or the. placement or providing .of warnings was discussed. . ANSWER: This defendant has been unable to locate any such information at this time. INTERROGATORY NO. 107: Identify any and all documents, including, but not limited to, notes, reports, minutes or bulletins, which refer to, relate to or reflect any meeting identified in response to Interrogatory No. 106. ANSWER: This defendant has been unable to locate any such information at this time. INTERROGATORY NO. 108: . With respect to each job site within 200 miles of Madison County and/or identified by any plaintiff (who has asserted claims against this defendant) (i) identify any and all documents referring to, relating to or reflecting the purchase, sale, delivery, use, application or ordering, of any of the products listed in response to Interrogatory Nos. 19 and 42 by, for, to or at said site; and, (ii) identify any and all persons known by Defendant to have knowledge concerning the same: ANSWER: To the extent that such documents exist. Defendant will product documents at a mutually agreeable time. This defendant is unaware of any category or any lists which would give such information. If individual plaintiffs provide job site information on Exhibit A and products on Exhibit B, defendant will make a good faith effort to identify whether it sold products identified on Interrogatories 19 and 42 to said employer or job site identified. INTERROGATORY NO. 109: Identify any and all parties, located within a 200 mile radius of Madison County, Illinois, including, but not limited to, distributors, suppliers or contractors, known by you to have purchased, received, sold, distributed, applied or otherwise used, at any time, any or all of the products listed in response to Interrogatory Nos. 19 and 42. ANSWER: See interrogatory No. 108. INTERROGATORY NO. 110: Other than cases identified in Interrogatory numbers 89 and 90, has defendant, any predecessor or any related company, ever appeared as a party in any lawsuit involving a claim or claims based upon allegations of property damage or seeking recovery of the costs of abatement from the use, application, installation or presence of asbestos or asbestos-containing products? ANSWER: No. .. . ' INTERROGATORY NO. 111: If your answer to Interrogatory No. 110 is "Yes," identify each such lawsuit as follows: (a) Identify the plaintiff(s); (b) Identify all other defendants; (c) State when and where the case was filed; (d) Identify each court in which the case was heard or is pending, including appeals, and state the style and cause number of the case in each court; and, (e) State the current status ofthe case if it remains pending or, if the case has been disposed of, state the final disposition, ANSWER: Not applicable. INTERROGATORY NO. 112: In any lawsuit, as described in Interrogatory numbers 89, 9Q, 110 and 111, has Defendant' been subject to sanctions, a contempt citation or similar action for failing, or refusing to comply with, any court order, for discovery fraud, or for the failure to provide complete, accurate and truthful responses to discovery? ANSWER: No. INTERROGATORY NO, 113: If your answer to Interrogatory No. 112 is "Yes," with respect to each such occasion described: (a) Identify the lawsuit involved, the court which imposed the sanctions or issued the contempt citation, and any other court which reviewed the same; (b) Describe the violation for which sanctions or contempt was imposed; (c) If the violation involved the failure or refusal to produce any document(s), identify any and all such documents; (d) If the violation involved any failure to truthfully answer or to respond to interrogatories, identify any and all such interrogatories and your response thereto, including the person answering on your behalf; (e) State the present status or final disposition of the matter, which ever is applicable;, and, (f) Identify any and all documents referring to, relating to or reflecting said matter, including, but not limited to, pleadings, exhibits and court orders. ANSWER: Not applicable. . INTERROGATORY NO. 114: In any lawsuit involving a claim or claims based upon allegations of injury, impairment, disease or death allegedly caused by exposure to asbestos, has any document or conversation as to' which the defendant, any predecessor or related company, asserted the attomey/client privilege been held by any court to be not privileged on the basis of the crime/fraud exception? ANSWER: No. ' ' INTERROGATORY NO. 115: If your answer to Interrogatory No. 114 is "Yes,11 identify any and all such documents or conversations described, and with respect to each: (a) Identify all persons whose actions were held to constitute a crime or fraud; (b) State the current status of the court's determination; and, (c) State whether you assert the privilege with respect to disclosing the document or conversation in this case. ANSWER: Not applicable. INTERROGATORY NO. 116: Identify any and all expert witnesses who have testified on behalf of the defendant, any predecessor or related company, in the last ten years in any lawsuits involving a claim dr claims based upon allegations of injury, impairment, disease or death caused by exposure to asbestos, or a claim or claims based upon allegations of property damage from the use, application, installation or presence of asbestos or asbestos-containing products, or issues of insurance coverage for any claims of personal injury or property damage arising out of the exposure to, use of, application of, installation of, or presence of asbestos or asbestos'Containing products. ' ANSWER: Pursuant to Court Order this interrogatory is withdrawn. INTERROGATORY NO. 117: Identify any and all present or former directors, officers, employees, or agents of defendant, any predecessor or related company, who have testified in any manner whatsoever including a discovery or evidence deposition, or in a trial, in the last 20 years on behalf of or against the defendant, any predecessor, or related company, in any lawsuits involving a claim or claims based upon allegations of personal injury or property damage caused by exposure to, the use of, the application of, the installation of, or the presence of any asbestos or asbestos-containing product, other than persons who testified as plaintiffs in their own cases. Specifically included within the scope of this request are any suits involving the issue of insurance coverage for claims of personal injury or property damage resulting from the exposure to, the use, application, installation or presence of asbestos or asbestos-containing products. ANSWER: Pursuant to Court Order this interrogatory is withdrawn. INTERROGATORY NO. 118: Identify any and all present or former directors, officers, employees, or agents of the defendant, any predecessor or any related company, other than persons appearing as adverse parties, who have testified against the defendant, any predecessor, or any related company in the last 20 years, in any proceeding involving the subject of asbestos, including, but not limited to, workers' compensation hearings, or any hearing before any governmental body. ANSWER: Pursuant to Court Order this interrogatory is withdrawn. ' INTERROGATORY NO. 119: With respect to your answers to Interrogatory numbers 116,117, and 118, identify any and all documents, including, but not limited to, transcripts or notes of testimony, referring to, relating to or reflecting the testimony of such expert witnesses or employees, directors, officers, or agents. ANSWER: Pursuant to Court Order this interrogatory is withdrawn. INTERROGATORY NO. 120: Has Defendant, any predecessor or any related company, ever been cited, warned, fined, sanctioned or otherwise officially written up for, any violation of a federal, state or local statute, law, rule, ordinance, code, administrative order, executive order, or the like, by any federal, state or local governmental entity, which violation concerned asbestos in any way? ANSWER: No. INTERROGATORY NO. 121: If your answer to Interrogatory No. 120 is "Yes," with respect to each such violation: (a) Identify the governmental entity issuing the citation* warning, fine, sanction or write up; (b) State the date of the citation, warning, fine, sanction or write-up; (c) Describe the violation and state the date(s) during which it occurred; . (d) Identify the statute, law, rule, ordinance, code or order to which the violation related; (e) State what, if any, specific fine, penalty, or sanction was imposed; .. (f) State the date in which and the manner in which said violation was corrected; (g) Identify any and all officials of Defendant, its predecessor or its related company having knowledge or notice of said violation and state the date on which said knowledge or notice was received; and, , (h) Identify any and all documents referring to, relating to or,reflecting said violation. ANSWER: Not applicable. INTERROGATORY NO. 122: Has any federal, state or local government entity, at any time, conducted any inspection, test or survey concerning asbestos or asbestos exposure at any facility where the products listed in response to Interrogatory Nos. 19 and 42 were manufactured, processed, applied, used or removed? ANSWER: No. INTERROGATORY NO. 123: If your answer to Interrogatory No. 122 is "Yes," then with respect to each such inspection, test or survey: (a) Identify the governmental entity conducting the same; (b) State the date(s) on which the same was conducted; (c) Describe the nature of the inspection, test or survey including, but not limited to, the results or conclusions thereof; and, (d) Identify any and all documents referring to, relating to or reflecting the same. ANSWER: Not applicable. INTERROGATORY NO. 124: .. . Identify: (a) Any expert whom you intend to call as a witness; (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 field of expertise; (f) Identify and produce each treatise, article or text upon which the expert will rely in testifying. ANSWER: These will be revealed according to the standard Order or any additional Orders in . the case pertaining to the subject. .. INTERROGATORY NO. 125: Are there any policies of insurance which provide, or might provide, coverage on behalf of Defendant, any predecessor or any related company for the injuries alleged in Plaintiffs' complaints? ANSWER: Yes. INTERROGATORY NO. 126; If your answer to Interrogatory No. 125 is "Yes," identify each such policy of insurance as follows; (a) Identify the insurers); (b) Identify the insured(s); (c) State the date on which the policy was first purchased and the date on which the policy expired or was terminated; (d) Describe the coverage provided, including, but not limited to, the time period oyer which the policy applied, the nature of the acts, omissions and injuries covered, and whether the policy provides primary or excess coverage; and (e) State the dollar limits of the coverage provided, including, if applicable, the "per person" limitations and "per occurrence" limitation. ANSWER: As it relates to Koppers Company, Inc., please see produced list of insurance providers and policy information. With respect to Universal Refractories, (a) Travelers Insurance Company; (b) Thiem Corporation and its wholly owned subsidiaries; (c) 1975; (d) this policy has been referred to as a "1975-CUP policy." It is a general liability policy. This is a primary insurance policy; (e) Defendant is unaware of the per-occurrence or per-person limitation on the policy. However, Defendant believes that there is approximately $25,000 remaining in policy limits, after which this insurance will be exhausted. Carrier Travelers Travelers Travelers Travelers Travelers Travelers Travelers Policy Term 3/31/61 to 3/31/62 3/31/62 to 3/31/63 3/31/63 to 3/31/64 3/31/64 to 3/31/65 3/31/65 to 3/31/66 3/31/66 to 3/31/67 3/31/67 to 3/31/68 Policy No. KSL-9197398 NSL-381869 NSL-533025 NSL-1422695 NSL-1930716 NSL-3 097771 NSL-6645306 GL Retention N/A N/A N/A N/A N/A N/A N/A Individual Limits $ 200,000 $ 200,000 $ 500,000 $ 500,000 $ 500,000 $ 500,000 $ 500,000 Travelers Travelers Travelers Travelers Travelers Travelers Travelers Travelers Aetna Aetna Aetna Aetna Aetna Travelers , 3/31/68 to 3/31/69 3/31/69 to 3/31/70 3/31/70 to 3/31/71 3/31/71 to 3/31/72 3/31/72 to 3/31/73 3/31/73 to 3/31/74 3/31/74 to 3/31/75 3/31/75 to 3/31/76 5/01/76 to 5/01/77 5/01/77 to 5/01/78 5/01/78 to 5/01/79 5/01/79 to 5/01/80 5/01/80 to 5/01/81 5/01/80 to 2/02/81 NSL-2263542 N/A NSL-2347279 N/A NSL-4147573 N/A NSL-6518948 N/A NSL-7611460 N/A 650-335A237-A N/A 650-147B905-4 N/A 650-147B905-4 N/A 03AL-2532520-SRA $100,000 03AL-253527-SRA $500,000 03AL-253539-SRA $500,000 03GL-9-SRA $500,000 03GL-12-SRA $500,000 TRL-NSL-180T450-A-81 $500,000 $ 500,000 $ 500,000 $ 500,000 $ 500,000 $ 500,000 $1,000,000 $1,000,000 $ 300,000 $1,000,000 .. $4,000,000 $4,000,000 $4,000,000 $5,000,000 $5,000,000 INTERROGATORY NO. 127: With respect to each policy described in response to Interrogatory No. 126, state: (a) the dollar amount of coverage which remains unexpended; and (b) whether any dispute exists between insurer and insured with respect to coverage. ANSWER: With respect to Koppers Company, IncDefendant has ho knowledge regarding the current status of coverage unexpended. With respect to Thiem Corporation, see Interrogatory No. 126. Currently, there is no dispute between the insured and insurers with respect to this coverage. . INTERROGATORY NO. 128: Other than the policies of insurance described in response to Interrogatory No. 126, do there exist any agreements providing for the benefit of Defendant, any predecessor or any related t company, complete or partial indemnification for any or all expenses incurred with respect to any or all of these cases, including, but not limited to, judgments, settlements, costs, experts' fees and/or attorneys' fees? ,. ANSWER: No. INTERROGATORY NO. 129: . If your answer to Interrogatory No. 128 is "Yes," for each such agreement: - (a) Identify all parties to the agreement and state the capacity of each such party (i.e'.indemnitor, indemnitee, etc.); (b) State the terms of the agreement, including the nature of the expenses covered and, if applicable, any limitations on payment, reimbursement or indemnification; and (c) Identify any and all documents referring to, relating to or reflecting said agreement, ANSWER: Not applicable. INTERROGATORY NO. 130: Was this Defendant ever allowed to use the trademark or logo of any other company, including but not limited to, its predecessor or related company, on any products Defendant sold, distributed or installed, and if so please state: (a) The trademark or logo used by you;. (b) The company allowing such use of its trademark or logo; (c) The time period such use was allowed; (d) Whether such use was by written, verbal or implied agreement; (e) Each and every product such trademark or logo was placed upon; ,4 (f) Identify all documents which refer to, relate to or reflect the use of such trademark or logo. ANSWER: No. . ' INTERROGATORY NO. 131: From 1940 to present, state whether Defendant and/or any predecessor or related company ever provided workers' compensation, health, accident and disability and/or life insurance coverage for its employees, and if so: . .. * (a) Identify each insurance carrier which provided workers' compensation, health, accident and disability and/or life insurance coverage to your employees and the dates such coverage was provided by each such carrier; (b) State whether such insurance carrier(s) ever conducted any dust counts or studies, industrial hygiene surveys or other tests relating to any asbestos-containing products that Defendant's employees may have been working with or around; and, (c) If your response to subpart (b) hereof is in the affirmative, please indicate the date of each such count, study, survey or other test and identify all documents relating thereto. ANSWER: Pursuant to Court Order subpart a has been withdrawn. As to 131 (b) and (c). Defendant is unaware of any such information. INTERROGATORY NUMBER 132: Other than cases identified in Interrogatories 89, 90, 110 and 111, has defendant, any predecessor or any related company, ever appeared as a party in any lawsuit involving a claim or claims based upon issues of insurance for any claim of personal injury, property damage or cost of abatement arising out of the exposure to, use of, application of, installation of or presence of asbestos or asbestos-containing products? ' ANSWER: No. INTERROGATORY NUMBER 133: If your answer to Interrogatories 89,90,110 and 111 is "yes", identify each such lawsuit as follows: (a) Identify all plaintiff(s); (b) Identify all defendants); (c) State when and where the case was filed; ' (d) Identify each court in which the case was heard or is pending, including appeals, and state the style and cause number of the case in each court; and (e) State the current status of the case if it remains pending or, if the case has been disposed of, state the final disposition. answer! See responses to these interrogatories. INTERROGATORY NUMBER 134: Is the defendant, any predecessor or related company, claiming any document responsive to any interrogatory or any request for production filed by The Simmons Firm as being protected from disclosure because of a privilege claimed for any reason? If yes, please list each document being claimed as protected from disclosure in a privilege log providing the date .of the document, the identity of the author, what individual or entity the document was addressed to, the identity of any individuals or entities provided copies of the document, a brief description of the nature of the document, and the particular privilege claimed as shielding the document from disclosure. ANSWER: See the attached Privilege Log. Privilege Log 1. A February 19,1998 letter from Michael Bucci, Attorney for Beazer East to Amy Gee, a paralegal in the law department at Beazer East, Inc. discussing hot tops and enclosing the letter from Thomas Reid, in-house counsel at Koppers, dated September 3,1981 and the memos of Greg Curran in #3 below. A copy was sent to Mary Wright, in-house attorney at Beazer and James Zeszutek, an attorney representing Universal. Attorney/Client Privilege 2. A September 3,1981 letter from Thomas Reid, in-house counsel at Koppers Company, Inc. to Robert Little, attorney retained by Koppers Company, Inc. in the Sapp vs. Universal Refractories case regarding answers to interrogatories and analyzing case. A copy was sent to Walter Sylvester, President of Universal Refractories. Attorney/Client Privilege . 3. Memos from Greg Curran, Assistant Account Manager and in-house counsel at The Travelers, the insurer for Universal dated 7/05/94,7/11/94 and 8/10/94. These memos were prepared in anticipation of litigation and prepared for use in pending litigation. The 7/05/94 memo discusses Universal's product lines, the memo discusses pending litigation. The 7/11/94 memo discusses corporate history and operations of Universal Refractories that was prepared in anticipation of litigation and for use in pending , litigation. The 8/10/94 memo concerns a meeting with defense counsel Jim Zeszutek, independent counsel retained to defend Universal in pending lawsuits and concerns a meeting with President of Universal, Walt Sylvester, Executive Vice-President in charge of sales, Ed Davidson, and the Vice-President of Quality Control, Regis Frederick. Attorney/Client and Work Product Privilege 4. An index of the contents of approximately 27,000 boxes of corporate records was compiled in approximately 1989-1990 at the direction and request of Beazer's law department for the purpose of addressing document requests in pending and anticipated litigation. The index was compiled in a manner using categories specified by the law department that could reveal the law department's strategy and litigation plans and a review of the index could give mental impression and theories. In addition the vast majority of the index has nothing to do with issues involving asbestos or issues relevant to these lawsuits. Thus, any disclosure of the index in this litigation could prejudice Beazer in other litigation. Work Product Privilege 208 North High Street Belleville, IL 62220 618-235-7222; fax: 236-2800 e-mail: dbl103@mvp.net DUNHAM, BOMAN & LESKERA BY: Eric C. Youn^0509l783 Attorney fij^Befendant, Beazer'East, Inc., Individually, and as Successdr to Koppers Company, Inc., and Incorrectly Identified as Successor in Interest to Thiem Corporation and Universal Refractories Company Commonwealth of Pennsylvania County of Allegheny ) ) AFFIDAVIT OF MARY ) DOMBROWSKI WRIGHT ) ) PERSONALLY CAME AND APPEARED BEFORE ME, the undersigned authority in and for the aforesaid jurisdiction, the wilhin named MARY DOMBROWSKI WRIGHT, personally known to me to be the Litigation Manager and Assistant Secretary of BEAZER EAST, INC. F/K/A KOPPERS COMPANY, INC., who acknowledges that she is authorized to make this Affidavit on behalf of BEAZER EAST, INC. F/K/A KOPPERS COMPANY, INC. She further deposed and said that: the matters stated in the foregoing Objections and Responses to Plaintiffs Interrogatories and Requests for Production are not wholly within her personal knowledge, there is no current employee with personal knowledge of all such matters; and that the Objections and Responses have been made based upon corporate records and other information assembled or provided by authorized employees and she is informed and believes that the Objections and Responses are true and correct. MARY DOMBROWSKI WRIGHT Sworn to and subscribed before me this 21s1 day of June, 2002, Notary Public Notarial Seal Marlene Evans. Notarv Public Member, Pennsylvania Association of Notaries Commonwealth of Pennsylvania County of Allegheny ) ) ss; Affidavit of Jill M. Blundon ) ) BEFORE ME, the undersigned Notary Public, on this day personally appeared Jill M. Blundon who, being by me duly sworn on her oath, deposed and said that she was the General Counsel ofThiem Corporation. That Universal Refractories Corporation was merged into Thiem Corporation and ceased to exist as a separate corporate entity in 1977. That Thiem Corporation was dissolved in 1991 pursuant to the Delaware Corporate Code. That she was General Counsel at the time of the dissolution of Thiem and that she is authorized to make this Affidavit on behalf of Universal Refractories, formerly a Division of Thiem Corporation and Thiem Corporation. She further deposed and said that: the matters stated in the foregoing DEFENDANT BEAZER EAST, INC.'S OBJECTIONS AND ANSWERS TO PLAINTIFFS' INTERROGATOLRES AND REQUESTS FOR PRODUCTION OF DOCUMENTS are not wholly within her personal knowledge, there is no current employee with personal knowledge of all such matters; and that the Answers have been made based upon corporate records and other information assembled or provided by authorized employees and affiant is informed and believes that the Responses are true and correct. Member, Pawsytvaria Association of Notaries