Document y9Nx1Ddax37vv2J1VYEYNLbX

FILE NAME: Asbestos Corp Ltd (ACL) DATE: 1980 DOC#: ACL016 DOCUMENT DESCRIPTION: Legal - Response of ACL to Requests for Admissions -4 'i \ / /7 (.A 0M1NSKY, JOSEPH & WELSH, P. C. BY: EDWARD B. JOSEPH/FREDRIC id e n t i f ic a t io n no.02938/2 77 99 16TH FLO O R, TWO PENN C EN TER P LA Z A P H ILA D E LP H IA , PA. 19102 (215) L. GOLDFEIN * attorney for Defendant ASBESTOS CORPORATION LIMITED CLARENCE JOHNSON, et al. v. ` TURNER & NEWALL, et al. IN THE UNITED STATE'S,-DISTRICT COURT FOR THE EASTERN DIS TRICT OF PENNSYLVANIA No. 7 8 " 464 RESPONSE OF ASBESTOS CORPORATION LIMITED TO __________REQUESTS FOR ADMISSIONS____________ 1. This request does not list the dates of alleged em- ployment of the persons listed with Asbestos Corporation Limited nor are the middle initials, or other identifying criteria given. Asbestos Corporation Limited has searched what files exist respecting present and former employees and admits that it had former employees named: Theodore Courture Leo Goupil Joseph Marceau Thomas Provencal Ernest Rouleau William Bizier auG 5 Albert Champagne Wilfred Fortier William Cooling Joseph Tremblay Louis Lessard Joseph Adams Ludger Ainsley Eddy Lemieux Alexandre Nadeau Asbestos Corporation Limited has no record of employment of. Albert Simard Joseph Turcotte Arthur Ainsley - 2. Asbestos Corporation Limited can neither admit nor deny Request No. 2. Asbestos Corporation Limited s records respecting events of 30 years ago are not complete. Asbestos Corporation Limited has no record of it having sent any medical files, x-rays, or x-ray reports, pathology reports or autopsy report to the Saranac Laboratory, the Trudeau Foundation, Saranac Lake, New York. Plaintiffs' request states "was sent" and it is assumed that plaintiffs mean that the material described * was sent by Asbestos Corporation Limited. 3. Asbestos Corporation Limited can neither admit nor deny Request No. 3. The alleged letter of September 22, 1950, addressed to Mr. Alfred Penhale is 30 years old. Asbestos Corporation Limited does not retain all correspondence and pro posals for such a period. Those files that do exist do not contain the letter identified in (a) nor the proposals identified in (b). OMINSKY, JOSEPH & WELSH EDWARD B. JOSEPH {J FREDRIC L. GOLDFEIN a-H-nrnPUfi fnr Asbestos CorDoration Limited COMMONWEALTH OF PENNSYLVANIA ss COUNTY OF PHILADELPHIA : FREDRIC L. GOLDFEIN, being duly sworn according to law, depo and says that he is attorney for Defendant Asbestos Corporation Limited; that he is authorized to and does take this affidavit on its behalf; and that he is acquainted with the facts set forth herein; and that the.same are true and correct to the best of his knowledge, information and belief. FREDRIC L. GOLDFEIN SWORN TO AND SUBSCRIBED V before me this\ day of 1980. iNOTARY JPUBLI C"'v DEBORAH L. S'ii_,;tpN - 'toTARY'PUBUC, PHILA., PHILA. CO.