Document ybYDN0yoKabkDRk68gebwD3gE

t I 4 D 2523 MKV/ks f. IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT McLEAN COUNTY ESTOL L. REED and VIRGINIA REED, Plaintiffs, vs. EMPIRE ACE INSULATION MFG. CORP., et al., Defendants. ) ) ) ) ) ) ) ) ) ) LAW NO: 83 L 68 ANSWERS TO SUPPLEMENTAL INTERROGATORIES EL NOW COMES the defendant, OWENS-ILLINOIS, INC., by HEYL, ROYSTER, VOELKER & ALLEN, its attorneys, and for answer to the supplemental interrog atories previously propounded to it by the plaintiffs, ESTOL L. REED and VIRGINIA REED, states as follows: INTERROGATORY NO. 6. Were any photos taken of Estol Reed? If so, state the total nuaber of photos, the date of each photo, and who has each. ANSWER. This defendant has no photographs of Estol Reed. INTERROGATORY NO. 7. Were you naaed or covered under any policy of liability insurance, effective on the date of the occurrence, which may be construed to provide coverage for any claia stated in the complaint? If so, as to each policy state: (a) The name of the company. (b) The policy number. (c) The effective period. (d) The maximum liability limits for: 1. injury to any one person; 2. aggregate personal injury limits. I HCYU AO^STCR. VOCLKCR | A AtLCN Miorr '*a*. coaoa*tio AY rrs AT LAW ' urrc too j(rrtHO uloimO ! ! CORIA, ILLINOIS i0* '| IlOK T-00 I (e) What amounts, if any, have previously been paid under the policy which in the opinion of the carrier reduces the cover age available? 1980 4 ) 2523 MKW/ks r (g) Whether the policy contains any first party medical pay or disability coverage, and, if so, describe the coverage. i ANSWER, (a) through (e) and (g): Defendant is not aware of any policy i j of liability insurance which may be construed to provide coverage for any | claim stated in the complaint and which was in effect during the time it was involved in the manufacture or sale of asbestos-containing products. INTERROGATORY NO. 32. List the following information for each claim, not identified in your answer to the preceding interrogatory, brought against defendant by a present or former employee of defendant or the spouse or child of a deceased employee alleging a disease or condition of ill-being caused by asbestos: (a) The name and address of the person alleged to be diseased or in a condition of ill-being. (b) When the alleged disease or condition of ill-being began. (c) The circumstances under which the employee is alleged to have come into contact with asbestos. (d) Whether the person is represented by an attorney, and if so, the name and address of his attorney. (e) The agency where the claim was filed, the docket number of the claim and the date the claim was filed. ANSWER. This defendant has received no worker's compensation claims at any time from any present or former employees of its Kaylo Division. HCYL. ROYSTC*. votutc* * ALLCN mmo CO*OA*TIO A. AlCTS AT LAW pcofttA. icunois eieot such sasriwys it . r e *, :: c.!;/ :ne pleadings cf rcccrcJ f.crc.n, w.ih o it. / pro;, id, ar.d by depocitlng said envelope in a U S. Kcct 0Oh.cc uox in Peoria, -2- AFFIDAVIT STATE OF OHIO COUNTY OF LUCAS ) )SS: ) PHILIP M. RICE, being duly worn according to lav, deposes and says that he Is an Assistant Secretary of Owens-Illinois, Inc., a defendant herein; that as such he is authorized to make an Affidavit on its behalf; and that the facts set forth in the foregoing DEFENDANT, OWENS-ILLINOIS, INC.'S ANSWERS TO SUPPLEMENTAL INTERROGATORIES, are true and correct to the best of his knowledge, information and belief. SWORN TO and subscribed before me this ' ' day of _ Li____. 1986. Notary Public My Commission Expires: DOWS MT STHNSt Notary Public. State of Ohio My Coamittion Expire* Aug. , lv#v PHILIP M. RICE cf 4 D 2523 RHS/pmk Reed, Estol Attorney Service List Janies Walker, Esq. Janies Walker, Ltd. .207 W. Jefferson Street Post Office Box 3455 Bloomington, 2L 1702-3455 Attorneys for Plaintiff Jackson B. Button, Esq. 16 West Kadison Street P. O. Box 1128 Danville, IL 61832 Attorneys for Wicolet Katten, Muchin, Zavis, Pearl & Galler 525 West Monroe Street Chicago, IL 60606 Attorneys for GAF Lloyd E. Williams, Jr. Jacobs, Williams & Montgomery Suite 3500 20 North Wacker Drive Chicago, IL 60606 Attorneys for Standard Asbestos