Document xzme7oDmqng02D8RodDa3qwgb

LOUIS F. SCHOFIELD BURNHILL, MOREHOUSE, BURFORD, SCHOFIELD 6 BLUNDER, INC. 1220 Oakland Boulevard, Suite p. o. box 5168 Walnut Creek, CA 94596 415/937-4950 t^JPlAINTffPS ITS exhibit:^ * -ra j .r--'. -V--*,-?....... I * XH-44^ 200 RAyTON4 4S#QC FEB 0 7 1990 Attorneys for Defendant KELLY MOORE PAINT COMPANY 004843 SUPERIOR COURT OP THE STATE OF CALIFORNIA IN AND FOR THE CITY AND COUNTY OF SAN FRANCISCO IN RE: SHIPYARD AND APPLICATOR CASES (CLAPPER & BRAYTON) CONSOLIDATED FOR DISCOVERY / NO: 804416 DEFENDANT KELLY MOORE'S RESPONSES TO INTERROGATORIES PROPOUNDED BY PLAINTIFFS PROPOUNDING PARTY RESPONDING PARTY: SET NUMBER: PLAINTIFFS DEFENDANT KELLY MOORE PAINT COMPANY TWENTY-EIGHT 21 22 23 24 25 26 27 28 sDc NEAL BAKER, Plaintiff, v. ABEX CORPORATION, et al., Defendants. / LOUIS BLEILY, Plaintiff, v. hBEX CORPORATION, et al., Defendants. / ?RANK BOLDUC, Plaintiff, ^BEX CORPORATION, et al. , Defendants. / NO: 821066 NO: 804981 NO: 823025 22 23 24 25 26 27 28 SE .D <> I JAMES O. DAVIS, Plaintiff, v. ABEX CORPORATION, et al. , Defendants. __________________________ / ESTER DICKENS, Plaintiff, v. ABEX CORPORATION, et al. , Defendants. ____ / ROBERT EPPERSON, Plaintiff, v. ABEX CORPORATION, et al. , Defendants. / JAY WAYNE HARRIS, Plaintiff, v. ABEX CORPORATION, et al. , Defendants. / ElfiOND JOHNSON, Plaintiff, v. ABEX CORPORATION, et al., Defendants. J/ R. H. JOHNSON, Plaintiff, v. ABEX CORPORATION, et al. , Defendants. ________ / JOHNNIE MEACHAM, Plaintiff, \BEX CORPORATION, et al. , Defendants. / 1ERBERT THOMPSON, Plaintiff, r. IBEX CORPORATION, et al. , Defendants. / NO: 799977 NO: 800999 NO: 811399 NO: 804985 NO: 800948 NO: 803139 NO: 814472 NO: 804476 2 PENI TUFONO, Plaintiff, v. ABEX CORPORATION, et al., Defendants. CLARENCE TRULL, / Plaintiff, v. ABEX CORPORATION, et al. , Defendants. MOSES PARKER, / Plaintiff, v. ABEX CORPORATION, et al. , Defendants. / II CLINTON DICKSON, Plaintiff, i: v. ABEX CORPORATION, et al. , 1: Defendants. / 1: NO: 818696 NO: 800945 NO: 802061 NO: 805014 COMES NOW, Defendant KELLY-MOORE in response to if ies propounded by Plaintiffs to Defendants, Set u dumber 28 as follows: 17 18 19 20 21 22 23 24 25 26 27 28 SE .O 3 >o DEFINITIONS "Bay area"- this term shall refer to the counties of San Francisoc, Alameda, Contra Costa, Solano, Marin, San Mateo, Napa and Santa Clara. "You", "Your" - hese terms shall all refer to defendant, its employees, its agents, its predecessors and successors in interest. "Identify" - wherever you are requested to "identify" any writing or other item, please do so with terms sufficient to describe it within a request for production pursuant to Code of Civil Procedure, Section 2031 or subpoena duces tecum, including, but not limited to, the date of each such writing, the addressee and addressor of each such writing, and the identity of each copy of each writing. A request to "identify" a product shall mean a request to describe the product, the material or compound by the following means: (1) by nickname or slang name used in 17 your industry and/or occupation; (2) by the name under which it 18 is sold in the marketplace (tradename); and (3) by its generic 19 name. 20 "Writing", "document" - in these interrogatories means 21 printing, photostating, photographing, and every other means of 22 recording upon any tangible thing, any form of communication or 23 representation, including letters, words, pictures, sounds or 24 symbols, or combinations thereof. 25 "The GSA" - this term shall refer to the General Services 26 inistration of the United States Government. -3- "Navy" - this term shall refer to the Department of the Navy of the United States Government and where the interrogatory inquires of use of a product within the United States Navy, it refers to the use of that product for use at Naval Shipyards and for high temperature insulation uses generally by the United States Navy. "Raw asbestos" - means asbestos fiber mined or milled, either packaged or in bulk, not compounded with other substances and essentially pure with the exception of naturally occurring trace amounts of other substances. 11 "Product" - includes any product, materials, supplies or 12 equipment containing or including asbestos in whole or in mix 13 ture with other products or minerals. Specifically, "product" 14 shall include component parts, such as brake linings, clutch 15 facings, heat shields, or any other asbestos-containing subpart 16 of any product. 17 "Business Activities" - shall mean all activities in which 18 this defendant engaged during the period of time states. Such 19 activities, for example, may including, but are not limited to, 20 the mining, supply, sale, labelling, distribution, importing, 21 processing or manufacutre of products, for example. 22 A request to describe the "Nature" of such products means 23 to describe the: (a) color, (b) texture, (c) form (i.e., powder, 24 liquid, paste, solid, board, cloth, blanket, wire, insulation, 25 etc.), (d) physical dimensions if solid (length, width, and 26 -4- height), (e) the type of shipping package and shipping package dimensions if not solid, (f) type of asbestos fiber used in the composition of the product- (e.g., chrysotile, amosite, L crocido1ite), (g) the intended use or function of such product c as recommended by this defendant as the miner, producer, e supplier, manufacturer, distributor or reseller, and (h) the i work site in which it was intended to be used (e.g.: shipyard, 8 refinery, commercial building construction, manufacturing plant, 9 home, power generating plant). 10 A request to "Identify" an Oral Communication shall mean a 11 request to describe the communication with particularity, and 12 shall include, without limitation, the following information-. 13 (a) the identity of all parties to the communication; (b) the 14 identity of the person whom you contend initiated the com 15 munication; (and (d) the time, date, and place of the com 16 munication. 17 "Company" - means any profit making private enterprise, 18 including, but not necessarily limited to: corporation, part 19 nerships, joint ventures, and sole proprietorships and/or uti 70 lity company. 21 "Product" or "asbestos-containing product" shall mean a 22 product which this defendant knows or believes to contain any 23 amount or percentage of the mineral asbestos. 24 You are requested to furnish all non-privileged infor 25 mation in your possession and all information available to you, 26 -5- not merely such information as you know of your own personal knowledge, but also all knowledge that is available to you, your employees, officers and agents, by reason of inquiry including inquiry of their representatives. If you are unable to answer the following interrogatories completely, answer to the extent possible, specifically stating the reason for your inability to answer the remainder and stating whatever information or knowledge you have concerning the unanswered portion. /// /// '. /// // / 14 /// 15 /// 16 /// 17 / / / 18 / / / 19 /// 20 /// 21 /// 22 /// 23 /// 24 25 26 ' -6- 1 INTERROGATORIES 2 INTERROGATORY NO. 1: Please state the name, place of 3 employment, present address and job title of each person who ha: 4 supplied information used in answering these interrogatories. Jim Barry, 987 Commercial St., San Carlos, CA 94070, Assistant 5 Treasurer; Durward Berry, 987 Commercial St., San Carlos, CA 94070, Corporate Insurance Manager; Douglas Merrill, 1015 Com 6 mercial Street, San Carlos, CA 94070, Plant Manager 7 INTERROGATORY NO. 2: Please state whether or not this 8 defendant is a corporation. If so, please state: 9 (a) This defendants correct corporate name; Kelly-Moore Paint Conpany,' Inc. 10 11 (b) The state of incorporation; 12 I 13 I California, December 4, 1952 14 11811s 5 *i*5 5 15 16 17 18 19 (c) The address of this defendant's principal place of business; 9 87 Commercial Street, San Carlos, CA 94070 (d) (e) Whether or not defendant has ever held a Certificate of Authority to do business in the State of California and the dates thereof; No, Defendant has never held a Certificate of Authority in California. Whether the ownership is publicly or privately held. Ownership is held privately. 20 21 j 22 23 INTERROGATORY NO. 3: If this defendant has ever been identified, known or done business under any other name during any period of its existence please state such name or names and the time period during which this defendant was so known or 24 identified. 25 None 26 1 INTERROGATORY NO. 4: If any parent corporation# prede cessor corporation, predecessor business entity, successor in interest, or subsidiary of this defendant, or any corporation ir which this defendant holds, or held a controlling interest, has rained, manufactured, sold, distributed, imported or supplied any asbestos-containing product(s), please state the name(s) of such entlty(ies), corporation(s), predecessor(s) or successor(s). - if* fr"* 8 f|g5| 13 Kelly-Moore Paint Company, Incorporated of Colorado (Professional Paints, Inc., unit-August 11, 2975/ merged into parent July 5, 1983) * Paco Textures Corporation . INTERROGATORY NO, 5: If this defendant has purchased, acquired or merged at any time with any business entity, or any preexisting or established operating division of any other com sIIh5 Hi pany or business entity, which rained, manufactured, labelled, 15 l^sold, distributed, imported or supplied any asbestos-containing 16 product(s), please state the name of such business entity(ies) 17 or operating division(s). IS Same answer as No. 4 19 20 INTERROGATORY NO, 6.; Does, or at any time did, this 21 defendant own any shares of stock, or otherwise have any 22 interest in a company that either mines, produces, distributes, 23 imports, sells or supplies raw asbestos fiber? If the answer 24 is in the affirmative, state the following: 25 (a) The name of such corporation or entity; 26 -8i 1 (b) The date of incorporation or charter; 2 3 (c) The state or country of incorporation; 4 5 6 7 8 9 10 n c 12 13 14 15 (d) Each ownership interest owned in such corporation, setting forth any change in such interest; (e) The date each such interest was acquired; (f) The date of formation of such corportion or entity; (g) The names of all shareholders owning more than 5% of the shares of stock of such corporation; (h) The date each, such interest changed or terminated, if applicable; 16 (i) The name and location of each asbestos mine so 17 owned; and 18 19 (j) The grade and type of asbestos mined at each mine. 20 . None 21 INTERROGATORY NO. 7: Please state whether this defen 22 dant has organizational charts for the period 1945 to present. 23 If so, state whether you will produce copies of this defendant's 24 different organizational charts for this period without a 25 26 requests to produce. The defendant has never had, at present nor in the past, an organization chart. . -9- J INTERROGATORY NO. 8t Pleas state the following*. 4 (a) The address where the corporate records of this 5 defendant (including but not limited to minutes froo Board.of Directors meetings and corporation annual 6 reports), are currently, located. 7 8 (b) The name, job title and current address of the ' custodian for this defendant's corporate records. 9 10 (c) Whether this defendant would produce such records 11 for inspection and copying without a formal request for production of documents. 12 SEE ATTACHED 13 INTERROGATORY NO. 9: Please state whether this defen 14 dant. between 1945 and the present, has ever engaged in the 15 following activities with regard to raw asbestos fiber, and if 16 so, please state the inclusive dates of each such activity: 17 (a) Mining; 18 19 (b) Milling; 20 . (c) Supplying; 21 |22 (d) Importing; 23 (e) Processing; 24 25 (f) Distributing; 26 V -10- INTERROGATORY NO. 8: (a) 987 Commercial Street, San Carlos, CA 94070 (b) John Bacigalupo, Secretary-Treasurer 987 Commercial Street San Carlos, CA 94070 fc) "Defendant will not produce such records for inspection without a formal request. <g) Marketing; <h) Selling; (i) Mixing and/or compounding. No No I (c) No (d) Yes 12/60 - 12/77 (e) No (f) No (g) No (h) No (i) Yes 12/60 to 3/9/7B INTERROGATORY NO. 10: Please state whether this defen f dant , between 1945 and the present, has ever engaged in the < following activities with regard to asbestos-containing 1C products(s) and/or materials, and if so, please state the inclu u sive dates of each such activity: 12 13 (a) Manufacturing; 14 15 (b) Supplying; 16 17 (c) Importing; 18 19 (d) Processing; 20 21 (e) Distributing; 22 23 (f) Marketing; 24 25 {g) Selling; 26 -11- CKCEKWOOO RRCFESSJONAL CENTER 20 BEL M AUN KEYS BOULEVARD NOVATO. CALFORM A 04047 .(h) Mixing and/or compounding. 2 (a) Yes 12/60 to 3/78 (e) No (b) No 3 <c) No (d) . No 4 (f) No See (g) <S> Yes 12/60 to 1978 (h) Yes 12/60 to 3/78 INTERROGATORY NO. 11: If the answer to either of the 5 preceding two questions regarding the mining, supply, importing, 6 processing, distribution, labelling, manufacture, marketing 7 and/or sale of asbestos-containing products and/or materials by 8 this defendant is affirmative, please state the following as to 9 such raw asbestos fibers and/or as to-each such asbestos- 10 containing product and/or material; II 12 (a) The trade, brand and/or generic name of each and every such product and/or material mined, supplied, 13 distributed, processed, imported, labelled, manufac tured and/or marketed in any form or quantity bet 14 ween 1945 and the present time. 15 16 (b) The date(s) each such product and/or material was first placed on the market, including the date(s) 17 each such product or material was first marketed: 18 (i) on an experimental basis; 19 20 (ii) on a test basis; 21 (iii) for sale. 22 23 (c) The date(s) each such product and/or material was withdrawn from the market; 24 25 (d) A description of the physical (the chemical) com 26 position of each such product and/or material, including the type and/or grade of asbestos and/or -12- asbestos fiber contained in each such product and/or material and the quantitative percentage of asbestos or asbestos fiber in each such product and/or material; (e) A description of the physical appearance and nature of each such product and/or material, including any color coding, distinctive marking and/or logo; i (f) A detailed description of the intended uses of each i such product and/or material. Including any tem perature limits of each such use; c 1C (g) The method of manufacture and production, for each 11 such product and/or material; 12 13 (h) The name of the manufacturer of each such product and/or material; ' 14 15 (1) The volume and weight of each such product and/or 16 material; 17 18 (3) The name and location of each asbestos mine which this defendant presently operates, operated in the 19 past, and/or in which defendant has or had an ownership interest, the inclusive dates of such 20 ownership, and the grade and type of asbestos fiber mined; 21 22 (1c) The name and address of the suppliers of the 23 asbestos fiber used in each such product and/or 24 material; 25 (1) Whether any of this defendant's products and/or 26 materials containing asbestos fibers have, at any time, been sold to any companies in California. If so, please state: -13- (I) The names of each such company; uu The. inclusive dates of each such sale, and the amount {volume) and the trade or brand name of each product and/or kind of material sold; (ill) Whether you have any records indicating any such sale and. If so, the name, address and job classification of each Indivldaul who currently has possession of such records. (m) Whether any of this defendant's asbestos fibers have, at any time, been sold to any companies, ' 11 suppliers, and/or manufacturers in the San Francisco Bay Area. If so, please state: ' .12 13 (i) Whether you have any records indicating any 14 such sale and, if so, the name, address and job classification of each individual who 15 currently has possession of such records; 16 17 (ii) The names and addresses of each such company; 18 19 Uii) The dates of each such sale and the amount (volume) and the grade and type of asbestos 20 fiber sold. 21 22 (n) Whether any of your asbestos-containing products and/or materials have at any time, been distri 23 buted, marketed and/or sold in California by com panies other than your own. If so, please list the 24 name and address of each such company and the name of each product and/or material so distributed, 25 marketed and sold, and the inclusive dates of such marketing, distribution and selling. 26 , -14- .(o) Whether any'of the products and/or materials set forth above ever ceased'to.contain asbestos. If so, for each product set forth the date asbestos ceased to be used; (p) . Describe all records, sufficiently to identify them for discovery purposes, which set forth any of the foregoing information and the custodian (giving name and address) of each such records. 7 SEE.ATTACHED . . INTERROGATORY NO. 12:- For the period beginning 1945 to 8 present, identify each distributor of defendant's asbestos- 9 containing products and/or materials, :in the San Francisco Bay 10 Area and/or California including the beginning dates of such 11 distribution and ending dates where applicable and the products 12 and/or materials so distributed. If any was an exclusive 13 i distributorship for a time, please so state and identify the 14 relevant time period. 15 16 NONE 17 INTERROGATORY NO. 13: Describe in detail the records 18 this defendant has maintained over the period 1945 to present 19 regarding sales 'of its asbestos-containing products and/or 20 materials to distributors in: 21 22 (a) California; 23 24 (b) The San Francisco Bay Area; and 25 26 (c)Provide the name and address of the person having custody of any existing records and the location of such records. (a) None (b) None (c) _^one INTERROGATORY NO. 11 (a) through (f) See attached (g) Mixing (h) Kelly-Moore Paint Company, Inc./Paco Textures Corp. (i) See attached Cj) None (k) Johns-Manville, Carey Canadian, Union Carbide (l) Complete sales records on these products are not available. (m) No , (nl Only as answered in Interrogatory No. 14 (o) See attached (p) All records available are at San Carlos, CA. 2 /1 1 /1 $ 5 M8 I 23 lb , bag 30 lb , b( -n tw 30*F ta d to I a r u . t*> C t r* ioo*r r ll No l t 0 '5 .B 2 W ithdraw n C b ry a o tll* Fovdor Dry Fowdar O ff-w tilfa Not *o 2 rt> o HK Oad w9 *;we t B > tOo a * OO ** to m *e s 3 to _ ee * -* w to B O J=: i8 -i.1 3 to f 8 ft*too *53O* O to f. J of I .to age to* a a4 ttoo. <tCo r. ago o oe * tno o-<* go O to. t,ge tOo ttoo* to. a* u a to to *ge eg js O to* *3 s sQ5 e oe a a a o 9 5 ee o M d e s es e B e9 55 Oc e e 5s od oa sS e e ao a 9 O -- I. g e K xO M to* to* --o Va*, *x* to* g .5 o e xo M to e u Unknown Unknown 12/60 W all T cxtu c* ( t d t u A) c r e e k w o o o p r o fe s s io n a l c en ter 200 BEL M A ftN KEYS BOULEVARO NOVATO. C A lF O fW A 9464T <410)003 3336 1 INTERROGATORY WO. 1*: If this defendant entered into 2 any agreements for the rebranding of any asbestos-containing 3 products and/or materials mined, imported, manufactured, sold, 4 distributed and/or supplied by this defendant for resale or 5 H distribution by another company, describe each agreements*s 6 terms and the parties to said agreement, the duration of the 7 agreement, and name of each product and/or material covered by 8 each such agreement. Agreement between Kelly-Moore Paint Company, Inc. and Georgia 9 Pacific for Kelly-Moore to supply some of its products with the Georgia Pacific label. The agreement was from December 27, 1968 10 to October 12, 1971. Products were: Bedding Cement, Topping Cement, All Purpose Joint Cement, Triple Duty, Bestex D, * 11 Bestex A, Ready Mix INTERROGATORY NO. 15: If this defendant entered into 12 any agreements for the rebranding of asbestos-containing pro 13 ducts and/or materials mined, imported, manufactured, sold, 14 distributed and/or supplied by another company for resale or 15 distribution by your company, describe each of the agreements 16 and the parties to said agreement, the terms, duration and names 17 of each product and/or material covered by each such agreement. 18 19 NONE 20 21 INTERROGATORY NO. 16: Please state the date this defen- 22 dant first purchased or otherwise obtained asbestos, asbestos 23 fibers and/or asbestos-containing materials. 24 On or about December 1960 25 26 -16- INTERROGATORY NO._ 17: Between the years 1945 to the present, did this defendant purchase any products and/or materials containing asbestos from any other miner, manufacturer i and/or producer of such products and/or materials with the pur pose of selling such under defendant's own name? If so, state i the name of such miner, manufacturer and/or producer, date or I approximate dates of such purchase or purchases and the brand or trade names of each such product and/or material, and iden c* tify any names under which such product was sold. 1C NONE 11 12 INTERROGATORY NO.' IS: State whether any asbestos used, 13 processed, mined, manufactured, imported, supplied, distributed, 14 labeled and/or sold by this defendant was purchased from or 15 acquired from the General Service Administration or any branch 16 or agency of the United States government during the period 1930 17 to the present date. If the answer is in the affirmative, 18 state: 19 NO 20 (a) The name and address of the agency which supplied the asbestos; 21 22 (b) The grade and types of asbestos purchased or 23 acquired. 24 25 (c) The quantities of each type of asbestos purchased or acquired annually during the period 1930 to the 26 present date; -17- CREEKWOOO PROFESSIONAL CENTER 390 BEL M ANN KEYS BOULEVARD NOVATO. CALFOflNIA 04047 (416)0033230 1 (d) The means of packaging; 2 3 (e) The health warnings, if any, which accompanied each shipment of asbestos and indicate when said warnings 4 were first made part of the shipments. 5 NO. 6 INTERROGATORY NO. 19: Please describe in detail the 7 type of containers or packaging in which defendant has sold or 8 distributed asbestos-containing products and/or materials, q listing the dates each type of package was used, a physical 10 description thereof, and a description of any printed materials, ii! 12 13 14 15 logo or trademarks that appeared thereon. One gallon pail Box with plastic liner (4 gallons, 48 lbs., 50 lbs.) Five gallon pail (62 lb.) 25 lb. bag 31 lb. bag 32 lb. bag 35 lb. bag 40 lb. bag 50 lb. bag INTERROGATORY NO. 20: As to each of the asbestos- 16 containing products and/or materials listed in your preceding 17 answers to interrogatories, does this defendant have in its 18 possession a picture, model, sample or brochure illustrating the 19 color and general description of the various packaging or con 20 tainers you have used to contain these products and/or materials 21 from 1945 to present date? If so, identify what item, where 22 each such item is located, and state when and where defendant 23 can make such illustrative material available for inspection. 24 YES. A picture or sample of most products has been 25 retained at San Carlos, California. 26 -18 INTERROGATORY NO. 21; As to each product and/or material listed in defendant *'s preceding answers to interroga tories, did defendant put on such products and/or materials or I their containers any warning of their hazards to health by vir < tue of the asbestos content of such products and/or materials? 6 If so, state for each such warning: 7 SEE ATTACHED 8 (a) Each such warning with particularity, with regard to 9 size, color and location of the warning; whether the warning was contained on the material or on the 10 container; whether warning was printed, stamped, and/or placed on a tag; and the nature and wording 11 or other content. 12 13 (b) Whether you have any photographs thereof; 14 15 (c) The inclusive dates on which you began using each 16 such warning on each of your asbestos products and/or materials; 17 18 (d) All of the facts, circumstances and considerations 19 which motivated you to use such warning; 20 21 (e) All changes you made in such warnings, the dates of such changes and the reasons for such changes; 22 23 (f) The names, present addresses and titles of all per 24 sons on whose opinions you relied in determining to put such warnings on your products and/or materials 25 or their containers; 26 -19- INTERROGATORS No. 21: (a) Warnings were printed on container to read: Caution - Read Before Using Contains asbestos fibers Avoid Creating Dust Breathing Asbestos Dust May Cause Bodily Harm Warning Size; 1-1/2" X 3-1/2" or Larger (b) November 19 72 (c) Result of O.S.H.A. Publications (d) No changes (e) Robert Miller, 1007 - 41st St., Oakland, CA 94608, former V.P. 1 .(g) The namesy-;present addresses and titles of all per sons on'whose*opinions you relied in determining to 2 put such warnings on your products and/or materials or their containers; 3 4 (h) The name, address and job classification of-each per 5 son who presently has possession of the abovedescribed documents. 6 7 INTERROGATORY WO. 22: As to any of the bags of raw 8 asbestos referred to in defendant's preceding answers to ' 9 interrogatories, did defendant put on such bags any warning of 10 the hazards to health by virtue of the asbestos contained 11 therein? If so, state for each such warning: 12 13 (a) Such warning with particularity, with regard to 14 size, color, location; whether the warning was con tained on the material or on the container; whether 15 the warning was printed, stamped, and/or placed on a tag; and the nature and wording or other content. 16 State whether you have any photographs thereof; 17 (b) The inclusive date on which you began using each such warning on each of your asbestos products 18 and/or materials; 19 (c) All of the facts, circumstances and considerations 20 whch motivated you to use such warning; 21 22 (d) All changes you made in such warnings, the dates of such changes and the reasons for such changes; 23 24 i 25 i 26 (e) The names, present addresses and titles of all per sons on whose opinions you relied in determining to put such warnings on your products and/or materials or their containers. -20- (f) The names, present addresses and titles of all per sons on whose opinions you relied in determining to put such warnings on your products and/or materials or their containers. (a) Defendant- did not sell raw asbestos (b) Not applicable (c) Not applicable (d) Not (e) Not {f) Not applicable applicable applicable INTERROGATORY NO. 23: With respect to each of your asbestos-containing products, state whether this defendant's name, a trade mark, logos, color coding or other identifying markings ever appeared on the actual product itself. If so, identify each such product, state when the practice of placing such identifying markings upon the product was begun, when it ended, if applicable, and describe in detail the pertinent markings and the purpose, if any, of such markings. NO INTERROGATORY NO. 24: Were any efforts made by this defendant to alert users, consumers and/or other persons likely 17 to be exposed to said products or materials of the raw asbestos 18 or asbestos-containing products or materials set forth in your 19 answers above to the risks and health hazards of exposure to 20 such materials by virtue of their asbestos content? If so, set 21 forth in detail each and every such effort made by defendant. 22 23 Yes. By placing a warning on the container of each product. 24 25 INTERROGATORY NO. 25; Have any written materials of any 26 kind or character been prepared by this defendant or its agen -21- cies~indicating how defendant's asbestos-containing products and/or materials should be used, handled, fabricated and/or maintained? If so, for each such document please state: (a) The name, address and job classification of each person who prepared each such material: 7 8 (b) The name, address and job classification of each person who presently has possession of same: 9 10 (c) The dates and manner in which said material was 11 distributed to purchasers of defendant's products and/or materials: 12 13 (d) Identify any documents which reflect such; 14 15 (e) Describe the instructions for use, handling, fabri 16 cation and/or maintenance given in each such, docu ment . 17 SEE ATTACHED .. 18 INTERROGATORY NO. 26: After the initial placement of 19 warning labels regarding the hazards of exposure to asbestos on 20 any of your asbestos-containing products and/or. materials, did 21 this defendant recall or make any attempt to recall those pro 22 : ducts and/or materials which had been sold in containers without 23 j such labels? If so, state when and under what specific cir 24 cumstances such was done. 25 NO. 26 . -22- INTERROGATORY 25 : Yes* (a) Unknown (b) Douglas Merrill, 1015 Commercial St., San Carlos, CA Plant Manager (c) Directions for use were included on each and every container. (d) Samples and/or pictures (e) Instructions included mixing procedures, cautions and applications INTERROGATORY NO. 27: To the extent'this defendant ever placed warnings on Its asbestos-containing products and/or materials regarding the hazards of exposure to asbestos dust. Identify each person who participated In the process of drafting each warning and otherwise determining its shape, description, color and location on packaging. If the warning first placed on this defendant's products and/or materials was changed in any of these particulars, also identify each participant in each such change. II Douglas Merrill Robert Miller i: 1; INTERROGATORY NO. 28: Did defendant ever recommend to x; purchasers or users of the asbestos-containing products that respirators, protective masks and/or protective clothing be worn if when using, applying or working around the product? If so, 16 state: 17 (a) The date or dates when such recommendation was made; 18 19 (b) The date or dates when each such recommendation was made to each user; 20 21 (c) Who made the recommendation; 22 (d) Who received the recommendation; 23 24 (e) If oral, the manner and substance of the recommen 25 dation; 26 (f) . If written, identify the document by title, date, file designation and author of each such recommen- -23- 1 dation and the location and present custodian of each such recommendation. 2 Recommendations were oral and respirators were made available 3 at the Defendants* outlets. INTERROGATORY WO. 29: Please state whether sales 4 materials were prepared by this defendant or its agents for pur 5 poses of marketing or advertising this defendants asbestos- 6 containing products and/or materials from 1945 to present. If 7 so, please state for each such sales materials; . 8 o (a) The name and address,job title and relationship to defendant of each person of entity who prepared 10 them; 11 c 12 (b) The name, address, job title of each person or entity who presently has possession of them; 13 (c) The date each such sales material was prepared; 14 15 (d) The first date such material was used, distributed, 16 or otherwise disseminated; * 17 (e) Briefly describe such material; 18 19 (f) The manner and media used to disseminate the sales materials, including but not limited to all trade 20 journals and/or publications. 21 (g) The present location of sales materials 22 (a) Unknown 23 (b) Douglas'Merrill, 1015 Commercial St., San Carlos, CA 9 4Q7Q (c) Unknown (f) Mailed on request 2U (d) Unknown (e) Brochures . (g> San Carlos, California 25 INTERROGATORY NO. 30 : Have you undertaken or financed 26 -24- any studies to determine-what types of respirator and/or protec tive mask would either eliminate the hazards of asbestos inhala tion or afford maximum protection against the inhalation of asbestos fibers? If so, state: (a) Who made the study; (b) When the study was made; (c) What was the result of the study; 9 10 11 e 12 n 14 (d) If the result was written, identify the document by title, date, file designation and author of each such study, and the location and present custodian thereof; (e) The name, address and job title of the individual in your organization or consulted by your organization who is most knowledgable about said studies. 15 NO. 16 17 INTERROGATORY NO. 31: Have you undertaken or financed 18 any tests or studies to determine what type of ventilator or 19 ventilating system would eliminate or decrease the number of 20 airborne asbestos fibers in confined spaces? If so state: 21 22 (a) Who made the test or study; 23 , (b) When was the test or study made; 24 25 i 26 -25- (c) What was: the result of the study or test; 2 3 If the result was written, identify the document by 4 title, date, file designation and author of each such test or study, and the location and present 5 custodian thereof. No. However, an engineer or engineers from dust collector equip 6 ment suppliers conducted studies which led to the ourchase of dust collectors for our manufacturing facilities. * 7 INTERROGATORY NO. 32: Identify all present or former 8 executives, officers or other supervisory officials of defendant 9 whose depositions have been taken by plaintiffs, other than i 10 those herein, in cases involving workers or their heirs who are 11 suing this defendant or who have sued this defendant for 12 illnesses or injuries allegedly caused, in whole or in part, by 13 exposure to asbestos dust allegedly created by defendant's 14 asbestos-containing products and/or materials. Also identify 13 the style of each case involved, court of filing, the name and 16 address of plaintiff's counsel who took each deposition, the 17 date of the deposition, number of pages of the deposition, and 18 , whether defendant will make available said deposition(s) without 19 a motion to produce. The defendant is aware that Tom Smith and Don Marquardt, both 20 former employees, have given depositions in the, Denver Carey suit t file no. C62330 in the Superior Court of the State of Californa 21 for the County of Merced, you have'been provided with copies. 22 INTERROGATORY NO. 33: Has this defendant ever operated 23 contract insulation installation units and/or has any company in 24 any way affiliated with defendant ever been involved in the 25 installation of insulation? If so, for each corporation, cor26 -26- porate division and/or company affiliated with defendant, state: (a) The applicable period of time during which said entity was involved in insulation installation; (b) In detail, the relationship between the entity and i your corporation (including but not limited to, the details of any relationship of ownership or control); i (c) Each job site and/or company, refinery, shipyard, c power plant and/or manufacturer with which each cor poration, corporate division and/or affiliate entity 1C had a contract, the inclusive dates of such . contract, and the present location and custodian of 1] such contract(s). 12 NO. 12 14 INTERROGATORY NO. 34: Has this defendant, at any time, 15 been a member of any "trade organization" or "association" com 16 posed of other manufacturers, miners, distributors, importers, 17 labellers, suppliers and/or sellers of asbestos-containing pro 18 ducts and/or materials? If so, please state for each such orga 19 nization or association. 20 21 (a) The name and address of each such association or organization; 22 23 (b) The inclusive dates during which this defendant was 24 a member; 25 26 (c) The names of any committee or sub-committee of which this defendant was a member or on which this defen- -27- dant had a representative and the Inclusive dates of such representation and the name of this defendant's representative(s); {d) The name of any committees or sub-committees of which this defendant was a member or on which this defendant had a representation and the name of this defendant's representative(s); (e) The names of each committee and sub-committee of which this defendant received minutes and the inclu sive date of such reception and the dates of those minutes received. NO. INTERROGATORY NO. 35: Has this defendant ever been a member of the Asbestos Textile Institute ("A.T.I.")? If so., please state: (a) The inclusive dates during which this defendant was 16 member; 17 (b) The names of any publication published by or written 18 by such association or organization; 19 (c) The name of any committee or sub-committee of which 20 this defendant was a member or on which this defe- nant had a representative, the inclusive dates of 21 such representation and the name of this defendant's representative(s); 22 23 (d) The names of each such committee and sub-committee of which this defendant received minutes and the 24 inclusive dates of such reception and the dates of 25 NO. those minutes received. 26 INTERROGATORY NO. 36: Has this defendant ever been a -28- member; of the National Insulation Manufacturers Association ("N.I.M.A.")? If so, please state: (a) The inclusive dates during which this defendant was a member; (b) The names of any publication published by or written by such association or organization; (c) The name of any committees or sub-committees of which this defendant was a member or on which this defendant had a representative, the inclusive dates of such representation and the name of this defen dant's representative; ' (d) NO. The names of each such committee and sub-committee of which this defendant received minutes and the inclusive date of such reception and the dates of those minute received. INTERROGATORY NO. 37: Has this defendant ever been a 16 member of the Quebec Asbestos Mining Association ("Q.A.M.A.")? 17 If so, please state: 18 19 (a) The inclusive dates during which this defendant was a member; 20 21 (b) The names of any publication published by or written by such association or organization; 22 23 (c) The name of any committees or sub-committee of which this defendant received minutes and the inclusive 24 date of such reception and the dates of those 25 minutes. 26 NO. -29- INTERROGATORY NO. 38: Has this defendant ever been a member of the Industrial Health Foundation? If so, please state: (a) The inclusive dates during which this defendant was a member; (b) The names of any publication published by or written by such association or organization; (c) The name of any committees or sub-committees of which this defendant was a member or on which this defendant had a representative and the inclusive dates of such representation; (d) NO. The names of each such committee and sub-committee of which this defendant received minutes and the inclusive date of such reception and the dates of those minutes received. INTERROGATORY NO. 39 : Please state: (1) Whether any of the following methods has been used to transport either raw asbestos or asbestos- 17 containing products and/or materials of this defen- dant to the San Francisco Bay Area: 18 19 (a) Ship 20 (b> Train 21 22 (c) Truck 23 24 (d) Other, and if so, please specify what method; 25 (2) The inclusive dates each such method was used by 26 this defendant; -30- 1 (3) The-type**of asbestos or asbestos-containing pro 2 ducts and/or materials transported by each such method. 3 (1) (a) No ' (b) Yes (c) Yes 4 (2) December 1960 to December 1978 (3) Crysotile, Joint Compound, Textures and Paint 5 INTERROGATORY NO. 40: Identify all brochures, pamph- 6 lets, catalogs or other descriptions or listings of asbestos- 7 containing products and/or materials which this defendant 3 manufactured, sold, distributed or supplied from the year 1930 to the present. For each such document please state: 10 (a) The title of such document; 11 12 (b) The year it was printed; 13 (c) The years in which it was used; 14 15 (d) The purpose of such document; 16 (e) Whether the document(s), or copy(ies) of said 17 . document(s), presently exist; 18 I 19 I 20 21 (f) If said document(s) or copy(ies) still exist, where they are located; (g) The name, job title, and current address of the pre sent custodian of such document(s); 22 (h) Whether defendant would produce such document(s) for 23 inspection and copying without a formal request for production of documents. 24 See answer to Interrogatory No. 30 25 INTERROGATORY NO. 41: State whether any raw asbestos or 26 -31- asbsestos-containing products and/or material mined, manufac tured, sold, processed, imported, supplied, distributed and/or labelled by this defendant was sold or provided to the General Service Administration and/or any other govenmental agency during the period 1930 to the present date. If the answer is in the affirmative, please state for each such agency: (a) The name and address of the agency to which the raw asbestos or asbestos-containing products and/or materials was sold and/or provided, and the inclu sive dates of such sale or provision; {b) The grade and type of raw asbestos sold; and the quantity sold or supplied per each calendar year; (c) The trade, brand name, and/or generic name of each asbestos-containing product(s) and/or materials(s) sold or supplied and the quantity sold or supplied during each calendar year; (d) The means of packaging of each product set forth above; 17 (e) The health warning, if any, which accompanied each shipment of raw asbestos or asbestos-containing pro 18 ducts and/or materials. Please indicate the date when said warnings were first made part of the ship 19 ments. . . There is no information available that indicates that products of 20 this defendant containing asbestos were ever sold or provided to G.S.A. or any other governmental agency. 21 INTERROGATORY NO. 42: Between the years 1930 to pre 22 sent, did this defendant purchase or otherwise acquire any 23 asbestos-containing product, asbestos material or product line 24 from another company? If so, please state for each such purcha 25 se : 26 NO. -32- (1) Date of contract of sale;* (2) Terms of purchase and sale agreement, or if you will do so without a motion to-produce, attach a copy of said agreement(s) to your answers; (3) Trade, brand and/or generic name of each asbestos( containing product, asbestos material or product line so acquired; 4 (4) Name of company from whom you purchased each such asbestos-containing product, asbestos material or c product line; K 11 (5) Location of any manufacturing facilities so acquired, and the type of asbestos products or 12 materials manufactured therein. 12 INTERROGATORY NO. 43: Do you have in effect one or more 14 policies of insurance or co-insurance by or through which you 15 are or were insured in any manner or to any extent, whether pri 16 mary or excess coverage, with respect to any of the claims, 17 causes of action, injuries or damages alleged or claimed against 18 you in the complaint herein? 19 YES. 20 21 INTERROGATORY NO. 44: If your answer to the preceding 22 interrogatory is in the affirmative, state: 23 24 (a) The total 'number of such policies; 25 (b) The name, address and telephone number of the com 26 pany issuing each policy; -33- (c) The name, address and telephone number of the insurance agent issuing each policy; (d) The policy number; (e) The complete wording of all named insureds on each policy; CflECKWOOO P flO tS S O N A t CENTER J40 BEL M A R N K t'rS OOUIEVAFO NOVATO C A l (FORMA Q4Q4 7 (4141>83 333# (f) The limits of bodily injury or public liability coverage of each policy; S (g) The effective dates of each policy. 9 See attached. 10 INTERROGATORY NO. 45: Do you or did you have in effect 11 one or more policies of insurance or co-insurance, where a 12 question or controversy exists as to whether such policy or 13 policies afford you any bodily injury or public liability 14 coverage, whether primary or excess, in connection with the 15 asbestos litigation? 16 Most insurance companies have reserved their rights under their policies and Home Insurance Company is presently in dispute. 17 INTERROGATORY NO. 46: If your answer to the preceding 18 interrogatory is in the affirmative state: 19 (a) The total number of such policies; 20 21 (b) The name, address and telephone number of the com pany issuing each policy; 22 23 (c) The name, address and telephone number of the insurance agency issuing each policy; 24 25 (d) The policy number; 26 (e) The complete wording of all named insureds on each -34- INTERROGATORY NO. 44 (a.) (d.) (f.) (g.) See attached (b.) Not available (c.) Not available (e.) Kelly-Moore Paint Company, Inc. et al. and Subsidiaries x JuC ! ee KII.I.V-liOOMI- PA I NT COMPANY. INC. > c * 9 < m >H >s >. >. >N c 1. Q a a & O o. cw a Cl 1 & R a & e jw 5 5 s u <j 8 u 8 u U 8 j u8 X VV V $cm Cw e o c c Nu r> o a u * a a a a -- c cs i -- ti n xw x w *** ** fN u *** r*' X u ** a 9 * a a c ft & o o V w c ae e # u ** >C V < w* u> + . Wm Xm 4) O C Jl *3 mX m c eVOlWv *> *W Xc wft-O a e *x** 2S*'.' --> evV 9*sX:--* V 4 *X w o> oO w a. v t , L. fm % uo ( 8 < > c X *o wa -- o X I a CK *C - -* f* M ^ tloA. O ^2 C e SL* v mi to ~ 21:2 2 to to u oaw ge vOa u < b w e m U a * 0 5 ~+ a Xto e c s cc So c `fi e? ccooooc CO Vc\ <A Ms XX >o 4< a 5 a KRJ.LY-MOOnK PAIHT COMPANY. INC eo 3 O' z O' >v I CO o X as 3 Xx n--I v<e o --C < ax J> o a ma i e w JO <a ax > aa #t A**l ^u <a mX O' O' aa cc uu WA e r. to X a o^ N <o 55 55 55 55 55 -C X x to to o X 0tto oo XX w0 wo oo XX 0w ^ 0 oo XX 0 0* *rt XX ^o wo aa n uu rr7 X K > ^rt / u 5 16 xx ea aa x a a o* u u uSISw. o^ na e N (J U a *c -J to, U W to x o Pto* to. 4a to 99 ! to. e rt ON* - xc i uto to to ae "to * t L> to ^at X e c , e c O uu a a to 99 to e e a to l bu O' o a to 4a 99 ee 1 0 to 4a o0e to to X s* no i c O' a to 5* ao u CJ to u e V N c to s Na w V" 9 c N% e -- V i> w a X V. to art o X Xc a ao<as ao u uc V c u c to 9c 9 N* C " c > to IN r. to. X M to to. Oz sW tso 4 to tao a a X Oa ' --e S to mc x 3 X to X a too ? c. I V 9 * Jt A w u e e> e c c i T> e M fa fa fa 3 C. 3 AS C ^ fa * eo c <** o s^a ^c -- <oo s e* s ce ee gg S g? ce ce ec 0 44 g 3 CeB < e o e *g 1 e e coo eg e *e eMl o- =A <b rx o i 1e a es co oc w e cWA c c^ a* -- NM * ' co So A A U S^M Nn n O , . o o o e c o as o *c1 oA c-oA NNN o 1 1 1g oc c ococ o ecAecAecAc- =8 - <0 -- O' ba 11 t0 * * _> z z >. C.m f- ~ k. fa gwa C A - g se <s gg g3b C w -C cg <s ss fa O h cfa ~3 -Go < bV 0 <b1 fa. e ** C -e fa 3 fi <9O g oh b e ^ - gs e <o= u V a e 3 Z 01 cI tWfNA WN"l -- (N -- Ci *wr> i c /i ^ o:c ^ 9C C CO -- *> >r\ <r* CCO ^O' i0nC lCA ^-- c c---- /Il nIIn)iA Vbh ftbft c)A*>* <f<* ^O' 0>C ----3 --^C A /I ^ lA WinIA AI >> b -- o-* -->e sO sC till t -e . . II uJC<m u2 b<: m: _wl 2b >-Jb S" o _1 J J 9 KF.Ll.Y-HOOHK MNT COMPANY. INC. --* -- --C b 3 -- M3 bfa ' m >>x N fa b .3 lA fa fa ff--aa. -) Xohi ce c & I&S a BEE ooo wuu ffaa ffaa Vfa eee >.>>. efa c cfa & fib & see Uo J o & & <a & ee$b uo uo u5 uo fa o fa fa fa w e fa e <cs fea a aa a e0 e0 a3 e0 uu fa o u ve eeee n b3 b3 b3 w3 a eec c CO ffaa ffaa c ea bb 33 --3 3 3 VA 3 3 3 ZXX 1 fa, fa. >1 -- AAA -- --3 3 3 A 3 3 3 b -- Xt ^ Ji *A --33 fa*> 3 3 xx xX >\ >h A fa> -- bbb -- JO .B JS ^ --3 *A 3 3 3 3 XXXX -- XX >* . > aX ^ : m * KELLV-MOORE p a in t C O U PAN t, tH C . Sum m ary o f L i a b i l i t y P o lic ie s' January 1. 1956 Octobar 1, 1964 jt u uI * -a es ** $ "v ^ u I oo <t Omaaa;<H. X a**. <HUUUi>*MW i to bu%a* ** u i * <3/ 1 ns e U > <s oOO w Ut o**. *>t 3i U4 _ e s o B 4 7 ooo Cc5-*-ooo0 oo0o<5 o o - ^* 0 0 0 0 o9 o o* o o* o* - o o* o o o o oo o* oo- _?* o* oo ooe ooo o * *o o oo oo o% *o o in r4 V 0 u 0 > *- o oo X a-* 6x- ---* .0 4 -3 *4 *) A *> t- V. V U .,o0j .oOa MUx kO*l k> o U* 4 J3 -* <r\ E 3 Prt 0O4 2 X o o a e0 9 . m. v wM0 a a i 0 v 0 a O W0 0 b 0 0 a* U W U g 43 30 *W XW 38 U* 0X1 c <S . 2 JS e o0 *+ ^ 0 r0V<* 00 00 M^ U V 22 e 9 i a Ob b ,A U <a 5a wx * a N* 4) * bO 4W gV <3 aE uX O' &a n <v r* 0. -O4 . 0> >0 -a O* <"4 IN <*4 rs oO I <3- On Ov>' *Oh OC x _ >r> O 1 l IN *o4 3 r*n. *IN* A Mw b fN INN in o* <14 X a X4 .-4 s<0 in 7* O <T IN CD - w* X O K--QxNo IN -< in o IINNOXX gj Meq tty vt K M *> <4 < f-> ^* 0> >~A finir- <3 x x IN b N SX A 14 IA IN 10 0 414 l14 X mx It <N # O> XQ <A 2 !K >* q a. 0 a. aU u *a to J5'S S * ss s:c9 I Uc uc 32 . * to m r< v c / <N-* o -- m 0 *- <-333. --. 3w *3/ C * t X2 -* N v. >>- w #n b a r*.b W b** ~ JO JS 'o w N. M -M k n J J h-1* uQ x x 0oe uw CC 2 .Ue m Jb 3w e 41 u c u (i /N -- 3 Wb 3 -- *** 4 e P" me X V0. W* 12x aO. X0 w* IN J* NN H --nN.. WN Vb3 K> -*a* j V) 3 0 "kO X 0 -* X 0 G bl 0 -- X 0e iI NL. g aOs v0 ac Nn-*. be wa 4 3 B >-i 4 *C- c KO' ovl n. g a v. C5 * r> X X JS U X 3 u cb a x b e m w a i-* b a a3 3 a xto <eJ c*b o v n o g X W -- X > a a a w au w icMeveg c CCU X<"rt Hb3 ne ne b 0 9oo a Cw 0 0o MU 5. O u >* u eg x a -- >4 y C 0 f e**y 300 au r c c0 cW ab* > be Ne -->. bva 9O <wQeJ * 0o O' o c0 3UX 0 Cx * WX ab N 3 33 ^ s-u M^ 3 0 I a N bc* c0 c0 3 CC X M i >! in u x Xo-4 tu3~ <oC_i uco m Mk X m s o et 3* 33 3e KRLLY-MOORn PAINT COMPANY, INC Page 5 o f 5 Ss >! ~2 o * Vn. b> 62 5* CO o o5Q 0o o0 4 -o On nO 4 V u k > *-- uo o >. c.- >s -- ^><>U>M .3 .O4 .4O 0 m J -J -4 4 1 VST \ V a * Vf * J V X e a 2 >. u O-4 fin o* CD * OlO <to0 ao. JO < <O sA 0 * n - A vs H J Vf V [S O *) fn s v x N* X X sO Tfr > I u 52* v u V* A s Oe 8*12^^ \O- u3e is. Sw ^ *v> ^K Ke * ?vt in > wS.Vi is w tft IN 1 .V 2 ee S3 ^ K i, H $ * ,5 * 4 1 policy; 2 (f) The lloits of; bodily Injury or public liability 3 coverage of: each'policy; 4 (g) The effective*dates of each.policy. 5 NOT APPLICABLE 6 INTERROGATORY NO. 47: State whether, between 1945 and 7 the present, any of your asbestos-containing products were 3 placed In containers bearing the name of an entity other than 9 your own; that is, state whether your products were relabeled or 10 rebranded to reflect that they were manufactured or distributed 11 by another company, and identify each such other company, the 12 product and the inclusive dates thereof of each product. 13 SEE ANSWER TO INTERROGATORY No. 14 14 13 INTEROGGATORY NO. 48: State whether, between 1945 and 16 the present, you placed your label or brand, or that of your 17 subsidiaries or companies in which you held an ownership 18 interest, on any asbestos-containing product, or raw asbestos, 19 manufactured or mined by an entity other than yourself; that is, 20 state whether you relabeled or rebranded products manufactured 21 or mined by companies other than your own to reflect that they 22 /// 23 /// 24 25 26 -35- were yours*,-, and.identify each - such.product,. the original manufac turers oirminers and. the inclusive dates thereof for each product. NO Dated:. August 31, 1984 BURNHILL, MOREHOUSE, BURFORD, SCHOFIELD & BLUNDEN, INC. By 8 LOUIS F. Attorney for Defendant, 9 Kelly Moore Paint Company 10 11 12 13 14 15 16 17 18 19 20 !21 22 23 24 25 26 27 28 tt. PROOF OF SERVICE BY HAIL - CCP 1013a, 2015.5 I declare that: I am employed in the County of Contra Costa, I am over the age of ighteen years and not a party to the within cause; my business ddress is 1220 Oakland Boulevard, Suite 200, Walnut Creek, alifornia 94596. On September 20, 1984, I served the within Answers to Interrogatories - Set #28 Solano County & San Francisco County Consolidated Actions n said action by placing a true copy thereof enclosed in a sealed nvelope with postage thereon fully prepaid, in the United States ail at* Walnut Creek, California, addressed as follows: (See Attached) 24 25 26 27 28 29 30 31 32 I declare under penalty of: perjury that the foregoing is true and 33 rrect. . 34 Executed on Sppi-gtnher 20. 1984 * at Walnut Creek, CA 94596, 35 Q. - Hoqr^T LISA A. HOGARTX) (J