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PLAINTIFF'S EXHIBIT 1 THOMAS E. PFALZER - State Bar No. 85261 JOSEPH E. FINKEL - State Bar No. 167397 2 KRISTEN A. PICO - State Bar No. 186022 GEOFFREY J. MACMILLAN, JR. - State Bar No. 189658 3 MCNAMARA, HOUSTON, DODGE, McCLURE & NEY 1211 Newell Avenue, Second Floor 4 Post Office Box 5288 Walnut Creek, California 94596 5 Telephone: (510) 939-5330 Facsimile: (510) 939-0203 6 Attorneys for Defendant 7 RILEY STOKER CORPORATION 8 SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN FRANCISCO 9 10 IN RE: ) NO. 828684 COMPLEX ASBESTOS LITIGATION) 11 ) DEFENDANT RILEY STOKER ) CORPORATION'S AMENDED RESPONSES 12 ) TO PLAINTIFFS' STANDARD GENERAL ) ORDER 129 INTERROGATORIES 13 ) 14 ___) ) 15 16 17 Riley Stoker Corporation "Riley Stoker" or the "Company"), 18 pursuant to and under the protection of the California Rules of 19 Civil Procedures, hereby files these responses to Plaintiffs' 20 Standard Asbestos Case Interrogatories (hereinafter 21 "Interrogatories") pursuant to San Francisco Superior Court 22 General Order No. 129. 23 RESPONSE NO. 1 24 James S. Brantl, General Counsel, DB Riley, Inc., P.0. Box 25 15040, Worcester, MA. 01615-0040. 26 RESPONSE NO. 2 27 James S. Brantl, Esquire, joined Riley Stoker as an 28 Attorney in October of 1976. He became Senior Corporate Attorney ston, t Nty w Defendant Riley Stoker Corporation's Amended Responses to Plaintiffs' General Order 129 Interroaatories In Re Complex Asbestos Litigation SFSC #828684 1 in 1984. Since January of 1988, he has held the position of 2 General Counsel. 3 RESPONSE NO. 3 4 Riley Stoker states that it is a corporation. 5 A. Riley Stoker Corporation. 6 B. Commonwealth of Massachusetts. 7 C. 1921. 8 D. 5 Neponset Street, Worcester, Massachusetts 01613. 9 E. If this interrogatory is asking whether Riley Stoker 10 is licensed to do business in California, Riley Stoker 11 states that it is licensed to do business in 12 California. 13 F. Not applicable. 14 G. No business offices in California. 15 RESPONSE NO. 4 16 Yes. 17 RESPONSE NO. 5 18 See Exhibit 1. 19 RESPONSE NO. 6 20 Not applicable. 21 RESPONSE NO. 7 22 Not applicable. 23 RESPONSE NO. 8 24 Not applicable. 25 RESPONSE NO. 9 26 Norman Sarkisian, who is the /manager of Administrative 27 Services and Facilities. 28 stoo, StNey iW M596 ///// Defendant Riley Stoker Corporation's Amended Responses to Plaintiffs' General Order 129 Interrogatories 2 In Re Complex Asbestos Litigation SFSC #828664 1 RESPONSE NO. 10 2 Riley Stoker does not concede that its boilers are or were 3 "asbestos-containing products." Riley Stoker Corporation nor any 4 company it controlled, purchased, or acquired any interest in has 5 ever made, mined, manufactured, distributed or processed, as 6 Riley Stoker Corporation understands these terms, raw asbestos or 7 asbestos-containing products, which Riley Stoker Corporation 8 understands to mean thermal insulation products that contain 9 asbestos as an ingredient. Furthermore, this interrogatory 10 appears to be directed to manufacturers of asbestos-containing 11 products. As Riley Stoker did not manufacture asbestos12 containing products, this interrogatory is inapplicable. 13 Riley Stoker states that it has supplied asbestos14 containing products manufactured by others as a component of some 15 of the boilers it has fabricated. Riley Stoker followed the 16 directions and specifications of owners or their agents in 17 selecting material for boilers and relied upon sales information 18 supplied by manufacturers of asbestos-containing products. Riley 19 Stoker cannot answer further since no identification of specific 20 boilers has been made. 21 RESPONSE NO. 11 22 Riley Stoker has no knowledge of ever employing a medical 23 director, industrial hygienist or physician. 24 RESPONSE NO. 12 25 Riley Stoker has no knowledge of any employee who has 26 testified by deposition or at triaF on Riley Stoker's behalf. 27 RESPONSE NO. 13 28 Dorn, t Ney w Riley Stoker has no knowledge of membership or of ever Defendant Riley Stoker Corporation's Amended Responses to Plaintiffs' ftenerfll OrHpr lntorrr>oatorip<i 7 In Re Complex Asbestos Litigation SFSC #828684 1 paying dues for a representative to be a member of the listed 2 organizations. 3 RESPONSE NO. 14 4 Not applicable. 5 RESPONSE NO. 15 6 Riley Stoker has no knowledge of ever receiving documents 7 containing results or conclusions of any studies and/or tests 8 conducted by Bonsib for Standard Oil of New Jersey. 9 RESPONSE NO. 16 10 Riley Stoker has no knowledge of having received a copy or 11 any portion of any studies and/or tests conducted by any 12 insurance company prior to 1973 relating to asbestos exposure in 13 the place of work. 14 RESPONSE NO. 17 15 Riley Stoker has no knowledge of having received any 16 documents containing results or conclusions of any studies and/or 17 tests conducted by any laboratory relating to asbestos exposure 18 prior to 1973. 19 RESPONSE NO. 18 20 Riley Stoker has no knowledge of ever maintaining any 21 library which contained materials related to the subjects of 22 asbestos, industrial hygiene, medicine, safety and/or 23 occupational disease. 24 RESPONSE NO. 19 25 Riley Stoker has no knowledge that prior to 1980 it 26 exchanged documents or communicated with any person or other 27 company expressly regarding the results of tests and/or studies 28 relating to asbestos exposure in the place of work or the human sloe, fc Ney Defendant Riley Stoker Corporation's Amended Responses to Plaintiffs' General Order 129 Interrogatories 4 In Re Complex Asbestos Litigation SFSC #828684 1 health consequences of exposure to asbestos. 2 RESPONSE NO. 20 3 Riley Stoker has no knowledge of any employee or designer 4 of Riley Stoker that has testified as a representative of Riley 5 Stoker before the Occupational Safety and Health Administration, 6 the National Institute of Occupational Safety and Health, or any 7 committee or subcommittee of the United States Congress relating 8 to asbestos exposure. 9 RESPONSE NO. 21 10 Riley Stoker states that it does not concede that its 11 boilers are or were "asbestos-containing products." Riley Stoker 12 Corporation nor any company it controlled, purchased, or acquired 13 any interest in has ever made, mined, manufactured, distributed 14 or processed, as Riley Stoker Corporation understands these 15 terms, raw asbestos or asbestos-containing products, which Riley 16 Stoker Corporation understands to mean thermal insulation 17 products that contain asbestos as an ingredient. Furthermore, 18 this interrogatory appears to be directed to manufacturers of 19 asbestos-containing products. As Riley Stoker did not 20 manufacture asbestos-containing products, this interrogatory is 21 inapplicable. 22 RESPONSE NO. 22 23 Riley Stoker does not concede that its boilers are or were 24 "asbestos-containing products." Riley Stoker Corporation nor any 25 company it controlled, purchased, or acquired any interest in has / 26 ever made, mined, manufactured, distributed or processed, as 27 Riley Stoker Corporation understands these terms, raw asbestos or 28 itoa, t Ney asbestos-containing products, which Riley Stoker Corporation Defendant Riley Stoker Corporation's Amended Responses to Plaintiffs' In Re Complex Asbestos Litigation SFSC #828684 1 understands to mean thermal insulation products that contain 2 asbestos as an ingredient. Furthermore, this interrogatory 3 appears to be directed to manufacturers of asbestos-containing 4 products. As Riley Stoker did not manufacture asbestos- 5 containing products, this interrogatory is inapplicable. 6 RESPONSE NO. 23 7 Riley Stoker does not concede that its boilers are or were 8 "asbestos-containing products." Riley Stoker Corporation nor any 9 company it controlled, purchased, or acquired any interest in has 10 ever made, mined, manufactured, distributed or processed, as 11 Riley Stoker Corporation understands these terms, raw asbestos or 12 asbestos-containing products, which Riley Stoker Corporation 13 understands to mean thermal insulation products that contain 14 asbestos as an ingredient. Furthermore, this interrogatory 15 appears to be directed to manufacturers of asbestos-containing 16 products. As Riley Stoker did not manufacture asbestos- 17 containing products, this interrogatory is inapplicable. 18 RESPONSE NO. 24 19 Riley Stoker has no knowledge of a medical examination 20 program that was made available to its employees to determine the 21 absence or presence of asbestos-related disease. 22 RESPONSE NO. 25 23 Riley Stoker does not concede that its boilers are or were 24 "asbestos-containing products." Riley Stoker Corporation nor any 25 company it controlled, purchased, or acquired any interest in has 26 ever made, mined, manufactured, distributed or processed, as 27 Riley Stoker Corporation understands these terms, raw asbestos or 28 StOD, t Ney asbestos-containing products, which Riley Stoker Corporation Defendant Riley Stoker Corporation's Amended Responses to Plaintiffs' In Re Complex Asbestos Litigation SFSC #828684  1 understands to mean thermal insulation products that contain 2 asbestos as an ingredient. Riley Stoker was named in two 3 workers1 compensation proceedings in which the claimants sought 4 compensation for alleged asbestos-related injuries. Ernest R. 5 Moreno v. Marine Engineering & Supply Co., et. al.. claim number 6 L.A. 76-144, was brought in the Industrial Accident Commission of 7 the State of California in 1947. The suit was dismissed as to 8 Riley Stoker. In or around August 1956, Riley Stoker appears to 9 have received a Notice of Hearing from the Workers' Compensation 10 Department of the State of Michigan in connection with Lewis 11 Munger v. Armstrong Cork Co., Travelers Insurance Co.. So far as 12 Riley Stoker is able to determine, neither claim included any 13 "report or communication" regarding the alleged hazards of 14 asbestos apart from the making of the claim itself. Discovery is 15 continuing. Riley Stoker therefore reserves the right to amend 16 or supplement this response. 17 RESPONSE NO. 26 18 Riley Stoker anticipates it has sufficient insurance 19 coverage with which to satisfy reasonable judgments in these 20 cases. 21 RESPONSE NO. 27 22 Riley Stoker does not concede that its boilers are or were 23 "asbestos-containing products." Riley Stoker Corporation nor any 24 company it controlled, purchased, or acquired any interest in has 25 ever made, mined, manufactured, distributed or processed, as 26 Riley Stoker understands these tenths, raw asbestos or asbestos- 27 containing products, which Riley Stoker Corporation understands 28 slot, fc Ney to mean thermal insulation products that contain asbestos as an Defendant Riley Stoker Corporation's Amended Responses to Plaintiffs' In Re Complex Asbestos Litigation SFSC #828684 1 ingredient. 2 RESPONSE NO. 28 3 Riley Stoker has never mined, milled, supplied, imported, 4 processed, distributed, marketed, sold or brokered raw asbestos. 5 RESPONSE NO. 29 6 Not applicable. 7 RESPONSE NO. 30 8 Riley Stoker does not concede that its boilers are or were 9 "asbestos-containing products." Riley Stoker Corporation nor any 10 company it controlled, purchased, or acquired any interest in has 11 ever made, mined, manufactured, distributed, processed, imported, 12 marketed, labeled or brokered as Riley Stoker Corporation 13 understands these terms, asbestos-containing products, which 14 Riley Stoker Corporation understands to mean thermal insulation 15 products that contain asbestos as an ingredient. At times 16 between 1930 and 1985, Riley Stoker supplied asbestos-containing 17 products manufactured by others as a component of some of the 18 boilers it has fabricated. Riley Stoker followed the directions 19 and specifications of owners or their agents in selecting 20 material for boilers and relied upon sales information supplied 21 by manufacturers of asbestos-containing products. Riley Stoker 22 cannot answer further since no identification of specific boilers 23 has been made. 24 RESPONSE NO. 31 25 Riley Stoker does not concede that its boilers are or were 26 "asbestos-containing products." Ri/ley Stoker Corporation nor any 27 company it controlled, purchased, or acquired any interest in has 28 ever made, mined, manufactured, distributed, processed, imported, fcNey Defendant Riley Stoker Corporation's Amended Responses to Plaintiffs' rionoral HrWar i OO In+afrAHof^riflc Q In Re Complex Asbestos Litigation SFSC #828684 1 marketed, labeled or brokered as Riley Stoker Corporation 2 understands these terms, asbestos-containing products, which 3 Riley Stoker Corporation understands to mean thermal insulation 4 products that contain asbestos as an ingredient. At times 5 between 1930 and 1985, Riley Stoker supplied asbestos-containing 6 products manufactured by others as a component of some of the 7 boilers it has fabricated. Riley Stoker followed the directions 8 and specifications of owners or their agents in selecting 9 material for boilers and relied upon sales information supplied 10 by manufacturers of asbestos-containing products. Riley Stoker 11 cannot answer further since no identification of specific boilers 12 has been made. 13 RESPONSE NO. 32 14 Not applicable. 15 RESPONSE NO. 33 16 Not applicable. 17 RESPONSE NO. 34 18 Not applicable. 19 RESPONSE NO. 35 20 Riley Stoker does not concede that its boilers are or were 21 "asbestos-containing products." Riley Stoker Corporation nor any 22 company it controlled, purchased, or acquired any interest in has 23 ever made, mined, manufactured, distributed or processed, as 24 Riley Stoker understands these terms, raw asbestos or asbestos- 25 containing products, which Riley Stoker Corporation understands 26 to mean thermal insulation products7 that contain asbestos as an 27 ingredient. Riley Stoker Corporation has no knowledge of 28 stou, t Ney entering into any agreements for the rebranding of products. Defendant Riley Stoker Corporation's Amended Responses to Plaintiffs' General Order 129 Interrogatories 9 In Re Complex Asbestos Litigation SFSC #828684 1 RESPONSE NO. 36 2 Riley Stoker does not concede that its boilers are or were 3 "asbestos-containing products." Riley Stoker Corporation nor any 4 company it controlled, purchased, or acquired any interest in has 5 ever made, mined, manufactured, distributed or processed, as 6 Riley Stoker understands these terms, raw asbestos or asbestos- 7 containing products, which Riley Stoker Corporation understands 8 to mean thermal insulation products that contain asbestos as an 9 ingredient. Riley Stoker Corporation has no knowledge of 10 entering into any agreements for the rebranding of products. 11 RESPONSE NO. 37 12 Riley Stoker does not concede that its boilers are or were 13 "asbestos-containing products." Riley Stoker Corporation nor any 14 company it controlled, purchased, or acquired any interest in has 15 ever made, mined, manufactured, distributed, processed, imported, 16 marketed, labeled or brokered as Riley Stoker Corporation 17 understands these terms, asbestos-containing products, which 18 Riley Stoker Corporation understands to mean thermal insulation 19 products that contain asbestos as an ingredient. At times 20 between 1930 and 1985, Riley Stoker supplied asbestos-containing 21 products manufactured by others as a component of some of the 22 boilers it has fabricated. Riley Stoker followed the directions 23 and specifications of owners or their agents in selecting 24 material for boilers and relied upon sales information supplied 25 by manufacturers of asbestos-containing products. Riley Stoker 26 cannot answer further since no identification of specific boilers 27 has been made. 28 sto*, t Ney vv nee* ///// Defendant Riley Stoker Corporation's Amended Responses to Plaintiffs' General Order 129 Interrogatories 10 In Re Complex Asbestos Litigation SFSC #828684 1 RESPONSE NO. 38 2 Riley Stoker does not concede that its boilers are or were 3 "asbestos-containing products." Riley Stoker Corporation nor any 4 company it controlled, purchased, or acquired any interest in has 5 ever made, mined, manufactured, distributed, processed, imported, 6 marketed, labeled or brokered as Riley Stoker Corporation 7 understands these terms, asbestos-containing products, which 8 Riley Stoker Corporation understands to mean thermal insulation 9 products that contain asbestos as an ingredient. At times 10 between 1930 and 1985, Riley Stoker supplied asbestos-containing 11 products manufactured by others as a component of some of the 12 boilers it has fabricated. Riley Stoker followed the directions 13 and specifications of owners or their agents in selecting 14 material for boilers and relied upon sales information supplied 15 by manufacturers of asbestos-containing products. Riley Stoker 16 cannot answer further since no identification of specific boilers 17 has been made. Riley Stoker further states that an identifying 18 name plate was attached to each Riley Stoker boiler. 19 RESPONSE NO. 39 20 Riley Stoker does not concede that its boilers are or were 21 "asbestos-containing products." Riley Stoker Corporation nor any 22 company it controlled, purchased, or acquired any interest in has 23 ever made, mined, manufactured, distributed, processed, imported, 24 marketed, labeled or brokered as Riley Stoker Corporation 25 understands these terms, asbestos-containing products, which 26 Riley Stoker Corporation understands to mean thermal insulation 27 products that contain asbestos as an ingredient. 28 item, t Ney w ///// Defendant Riley Stoker Corporation's Amended Responses to Plaintiffs' General Order 129 Interrogatories 11 In Re Complex Asbestos Litigation SFSC #828684 1 RESPONSE NO. 40 2 Riley Stoker does not concede that its boilers are or were 3 "asbestos-containing products." Riley Stoker Corporation nor any 4 company it controlled, purchased, or acquired any interest in has 5 ever made, mined, manufactured, distributed, processed, imported, 6 marketed, labeled or brokered as Riley Stoker Corporation 7 understands these terms, asbestos-containing products, which 8 Riley Stoker Corporation understands to mean thermal insulation 9 products that contain asbestos as an ingredient. At times 10 between 1930 and 1985, Riley Stoker supplied asbestos-containing 11 products manufactured by others as a component of some of the 12 boilers it has fabricated. Riley Stoker followed the directions 13 and specifications of owners or their agents in selecting 14 material for boilers and relied upon sales information supplied 15 by manufacturers of asbestos-containing products. Riley Stoker 16 cannot answer further since no identification of specific boilers 17 has been made. 18 RESPONSE NO. 41 19 Riley Stoker does not concede that its boilers are or were 20 "asbestos-containing products." Riley Stoker Corporation nor any 21 company it controlled, purchased, or acquired any interest in has 22 ever made, mined, manufactured, distributed or processed, as 23 Riley Stoker Corporation understands these terms, raw asbestos or 24 asbestos-containing products, which Riley Stoker Corporation 25 understands to mean thermal insulation products that contain 26 asbestos as an ingredient. Riley stoker states that it has 27 supplied asbestos-containing products manufactured by others as a 28 StOB, t Ney component of some of the boilers it has fabricated. Riley Stoker Defendant Riley Stoker Corporation's Amended Responses to Plaintiffs' General Order 129 Interrogatories 12 In Re Complex Asbestos Litigation SFSC #828684 1 followed the directions and specifications of owners or their 2 agents in selecting material for boilers and relied upon sales 3 information supplied by manufacturers of asbestos-containing 4 products. Riley Stoker cannot answer the remainder of the 5 interrogatory since no identification of specific boilers has 6 been made. 7 RESPONSE NO. 42 8 Riley Stoker has no knowledge of contract units within its 9 corporate structure. 10 RESPONSE NO. 43 11 Not applicable. 12 RESPONSE NO. 44 13 Sometime after 1972 Riley Stoker became aware that some 14 diseases were alleged to be associated with exposure to asbestos. 15 RESPONSE NO. 45 16 Riley Stoker has no knowledge of how it became aware of 17 that there was an association between asbestos exposure and 18 disease in human beings. 19 RESPONSE NO. 46 20 See response to interrogatory numbers 44 and 45. 21 RESPONSE NO. 47 22 Riley Stoker does not concede that its boilers are or were 23 "asbestos-containing products." Riley Stoker Corporation nor any 24 company it controlled, purchased, or acquired any interest in has 25 ever made, mined, manufactured, distributed or processed, as 26 Riley Stoker Corporation understands these terms, raw asbestos or 27 asbestos-containing products, which Riley Stoker Corporation 28 itM, feNey understands to mean thermal insulation products that contain Defendant Riley Stoker Corporation's Amended Responses to Plaintiffs' 1T In Re Complex Asbestos Litigation SFSC #828684 1 asbestos as an ingredient. Furthermore, this interrogatory 2 appears to be directed to manufacturers of asbestos-containing 3 products. As Riley Stoker did not manufacture asbestos- 4 containing products, this interrogatory is inapplicable. 5 RESPONSE NO. 48 6 Riley Stoker states that it does not concede that its 7 boilers are or were "asbestos-containing products." Riley Stoker 8 Corporation nor any company it controlled, purchased, or acquired 9 any interest in has ever made, mined, manufactured, distributed 10 or processed, as Riley Stoker Corporation understands these 11 terms, raw asbestos or asbestos-containing products, which Riley 12 Stoker Corporation understands to mean thermal insulation 13 products that contain asbestos as an ingredient. Furthermore, 14 this interrogatory appears to be directed to manufacturers of 15 asbestos-containing products. As Riley Stoker did not 16 manufacture asbestos-containing products, this interrogatory is 17 inapplicable. 18 RESPONSE NO. 49 19 Riley Stoker states that it does not concede that its 20 boilers are or were "asbestos-containing products." Riley Stoker 21 Corporation nor any company it controlled, purchased, or acquired 22 any interest in has ever made, mined, manufactured, distributed 23 or processed, as Riley Stoker Corporation understands these 24 terms, raw asbestos or asbestos-containing products, which Riley 25 Stoker Corporation understands to mean thermal insulation 26 products that contain asbestos as an ingredient. Furthermore, 27 this interrogatory appears to be directed to manufacturers of 28 asbestos-containing products. As Riley Stoker did not HOB, fc Ney Defendant Riley Stoker Corporation's Amended Responses to Plaintiffs' In Re Complex Asbestos Litigation SFSC #828684 1 manufacture asbestos-containing products, this interrogatory is 2 inapplicable as to Riley Stoker. Riley Stoker states that it has 3 supplied asbestos-containing products manufactured by others as a 4 component of some of the boilers it has fabricated. Riley Stoker 5 followed the directions and specifications of owners or their 6 agents in selecting material for boilers and relied upon sales 7 information and warnings supplied by manufacturers of asbestos- 8 containing products. Riley Stoker cannot answer the remainder of 9 the interrogatory since no identification of specific boilers has 10 been made. 11 RESPONSE NO. 50 12 Riley Stoker states that it does not concede that its 13 boilers are or were "asbestos-containing products." Riley Stoker 14 Corporation nor any company it controlled, purchased, or acquired 15 any interest in has ever made, mined, manufactured, distributed 16 or processed, as Riley Stoker Corporation understands these 17 terms, raw asbestos or asbestos-containing products, which Riley 18 Stoker Corporation understands to mean thermal insulation 19 products that contain asbestos as an ingredient. Furthermore, 20 this interrogatory appears to be directed to manufacturers of 21 asbestos-containing products. As Riley Stoker did not 22 manufacture asbestos-containing products, this interrogatory is 23 inapplicable. 24 RESPONSE NO. 51 25 Riley Stoker Corporation has no knowledge of ever owning or 26 operating a railroad. / 27 RESPONSE NO. 52 28 Riley Stoker Corporation has no knowledge of ever owning or slot, fc Ney ,w Defendant Riley Stoker Corporation's Amended Responses to Plaintiffs' General Order 129 Interrogatories 15 In Re Complex Asbestos Litigation SFSC #828684 1 operating a shipyard. 2 RESPONSE NO. 53 3 Riley Stoker does not concede that its boilers are or were 4 "asbestos-containing products." Riley Stoker Corporation nor any 5 company it controlled, purchased, or acquired any interest in has 6 ever made, mined, manufactured, distributed or processed, as 7 Riley Stoker Corporation understands these terms, raw asbestos or 8 asbestos-containing products, which Riley Stoker Corporation 9 understands to mean thermal insulation products that contain 10 asbestos as an ingredient. Furthermore, this interrogatory 11 appears to be directed to manufacturers of asbestos-containing 12 products. As Riley Stoker did not manufacture asbestos13 containing products, this interrogatory is inapplicable. 14 DATED:' December 8, 1997 bv Tkfwfc- I'TOdv'_____________________ _____ 15 Thomas E. Pfalzer 16 Attorneys for Defendant RILEY STOKER CORPORATION 17 18 19 20 21 22 23 24 25 26 / 27 28 fc Ney ,w Defendant Riley Stoker Corporation's Amended Responses to Plaintiffs' f^onoral OrWor 1 OQ IntorrrtnfltnriAC T^ In Re Complex Asbestos Litigation SFSC #828684 RILEY STOKER CORPHRATE HISTORY 1211 I SANFORD RILEY STOKER COMPANY (itKcrporxord) 0512 ( MURPHY IRON WORKS (purchased) 1222 [ UNDERFEED STOKER COMPANY (puichascd) GROUND COAL ENGINEERING COMPANY (purchased) RERNITZ FURNACE APPLIANCE COMPANY (purchased) 19N 1 UNITED MACHINE AND MANUFACTURING COMPANY (purchased) UNDERFEED STOKER, MURPHY IRON WORKS & UNITED MACHINE AND MANUFACTURING (inerted with Sanfotd Riley Stoker Company) A.W. CASH COMPANY (becomes direct subskli*jy; tome hier changed to Ctsbco. Inc.) RILEY ENGINEERING SUPPLY COMPANY. LTD ' (acquired) 12Z 1 BERNTTZ FURNACE APPLIANCE COMPANY (told die*. 1927; 1931 ! BADENHAUSEN CORPORATION (becomes subsidiary) 1937 I RILEY ENGINEERING SUPPLY COMPANY LTD (sold) i CASH STANDARD STACON COMPANY, INC. (ortaniaed as subsidiary of A.W. Cash ) 025 I CASH STANDARD STACON COMTANY (dissolved) . 12) l UNION IRON WORKS (becomes subsidiary) 0252 i. BADENHAUSEN CORP. (merged) UNION IRON WORKS (mertcd) BROS MICK7CAN DIV. OF AMERICAN HOIST AND DERRICK COMPANY (purchased) - 1971 \ CASHCO. INC. (disposed) r 1972 l ABBOTT HEAT EXCHANGER CORP. (jxirdhascd and renamed Riley Southwest Corp.) 12SQ I RILEY SOUTHWEST CORP. ( VERIFICATION COMMONWEALTH OF MASSACHUSETTS) ) COUNTY OF WORCESTER ) ss JAMES S. BRANTL, being duly sworn, deposes and says that he is an authorized agent of DB Riley, Inc., and that he verifies the foregoing Defendant, DB Riley, Inc.'s Amended Responses to Plaintiffs' Standard Asbestos Case Interrogatories for and on behalf of DB Riley, Inc.; that ofthe matters stated therein are not within the personal knowledge of deponent; that the facts stated therein have been assembled by authorized employees and counsel of DB Riley, Inc., and deponent is informed that the facts stated therein are true. SWORN TO BEFORE ME and subscribed in my presence this / 7 day of L) f CfmktfZ 1997. 1 PROOF OF SERVICE BY MAIL (C.C.P. 1013a, 2015.5) 2 I hereby declare that I am a citizen of the United States, am 3 over the age of eighteen years, and not a party to the within 4 action; my business address is 1211 Newell Avenue, Second Floor, 5 Walnut Creek, California 94596. 6 On this date I served the foregoing RILEY STOKER 7 CORPORATION'S AMENDED RESPONSES TO PLAINTIFFS' STANDARD GENERAL 8 ORDER 129 INTERROGATORIES on the parties in said action, by placing 9 a true copy thereof enclosed in a sealed envelope with postage 10 thereon fully prepaid, in the United States Post Office mail box at 11 Walnut Creek, California, addressed as follows: 12 Bruce L. Ahnfeldt, Esq. LAW OFFICES OF BRUCE L. AHNFELDT 13 P.O. Box 6078 Napa, CA 94581 14 Alan R. Brayton, Esq. 15 BRAYTON, HARLEY & CURTIS 222 Rush Landing Road 16 P.O. Box 2109 Novato, CA 94948 17 Jack K. Clapper, Esq. 18 LAW OFFICES OF JACK K. CLAPPER Marine Office Plaza 19 2330 Marinship Way, Suite 140 Sausalito, CA 94965 20 Christopher E. Grell, Esq. 21 LAW OFFICES OF CHRISTOPHER E. GRELL 685 Market Street, Suite 540 22 San Francisco, CA 94105 23 Steven Kazan, Esq. KAZAN, MCCLAIN, EDISES, SIMON & ABRAMS 24 171 Twelfth Street, Suite 300 Oakland, CA 94607 25 Harry F. Wartnick, Esq. 26 WARTNICK, CHABER, HAROWITZ, SMITH & TIGERMAN, INC. 101 California Street, Suite 2200 27 San Francisco, CA 94111 28 l Nc? 1 I declare under penalty of perjury that the foregoing is true 2 and correct. 3 Executed on January 12, 1998, at Walnut Creek, California. 4 PittmtLitidlm/ 5 ROWENA WALKER 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 i Ny