Document ymK3j4k6ZG3e1eGx93NOMnk53

FILE NAME: Chevron (CHV) DATE: 0000 DOC#: CHV001 DOCUMENT DESCRIPTION: Legal - Chevron Responses to Interrogatories Selected Pages 10 fM F R P A U L AND HANLE V L L P 5 5 9 9 9 7 0 TO 1 4 1 0 4 4 9 2 3 9 8 P .02 1 SEDGWICK, DETERT, MORAN & ARNOLD STEPHEN JONES (Bar No. 040884) 2 BERRIDOS R. MARSH (Bar No. 077304) HOLLY A. HARRIS (Bar No. 132336) 3 One Embarcadero Center, 16th Floor San Francisco, California 94111-3765 4 Telephone: (415) 781-7900 5 Attorneys for Defendant CHEVRON PRODUCTS COMPANY 6 7 8 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 IN AND FpR THE CITY AND COUNTY OF SAN FRANCISCO 10 11 ) NO. 828684 IN RE:COMPLEX ASBESTOS ) 12 LITIGATION ) RESPONSES OF DEFENDANT CHEVRON ) PRODUCTS COMPANY TO PLAINTIFFS' 13 ) STANDARD INTERROGATORIES TO ALL ________________________________ ) DEPENDANTS_______________________ 14 15 PROPOUNDING PARTY: PLAINTIFFS 16 RESPONDING PARTY: DEPENDANT CHEVRON PRODUCTS COMPANY 17 SET NUMBER: GENERAL ORDER 129 18 19 Defendant CHEVRON PRODUCTS COMPANY, a division of 20 c h e v r o n u.S.A. i n c . (hereinafter "Chevron"), provides the ; 21 following objections and responses to-San Francisco Superior 22 Court General Order No. 129 Plaintiffs' Standard Interrogatories 23 to All Defendants as follows: 24 P.RELIMINARY STATEMENT 2S Defendant's responses are based upon as diligent and 26 complete an inquiry as possible as of this date and are subject 2 7 to corrections for errors, mistakes or omissions. Defendant 328 anticipates that additional discovery, investigation, and - *MA606 02/15/00 14:31 TX/RX NO.0124 P.002 10 AM F r PAUL AND HANLEY LLP 559 9970 TO 14104492369 P .03 1 INTERROGATORS NO,-.a* 2 State the date of first employment with YOU, and the dates 3 and titles of each job position the person verifying these 4 interrogatories has held while employed by YOU. 5 RB8PQM9S ISLINIBRRQflftSPRY-ire,-^-. 6 First date of employment: 1977. 7 1977-1987: Mr. Walker worked for Chevron U.s.A. Inc. 8 and/or other Chevron entities as division manager and held other 9 related titles. 10 1987-present: Assistant Secretary of chevron U.S.A. 11 In c . 12 INTERROGATORY NO.. 3.; 13 State whether or not YOU are a corporation, and if so, 14 state: 15 A. YOUR correct corporate name; 16 B. YOUR state of incorporation; 17 C. The date of YOUR incorporation; 18 D. The address of YOUR principal place of business 19 fi. Whether or not YOU have ever held a certificate of 20 authority to do business in the state of California, and if so, 21 the inclusive dates of any certificate; 22 F. If You are wholly owned or the majority interest of YOUR 23 company is owned by another business entity, state the entity's 24 name and principal place of business; 25 G. Whether YOU have any business offices in California, and, 26 8 0 YOUR principal place of business in California. /// tMra/MSOf 02/15/00 14:31 TX/RX NO.0124 P.003 44 AM F R P A U L AND H A N LEY L L P 5 5 9 9 9 7 0 TO 1 4 1 0 4 4 8 2 3 6 8 P.04 1 RESPONSE TO INTERROGATORY NQn-3= 2 Yes - . 3 A. Chevron U.S.A. Inc. (dba) Chevron Products Company. 4 B. Pennsylvania. S C. August 19, 1922. 6 D. 575 Market Street, San Francisco, CA 94105. 7 E. Yes. January 18, 1965. 8 F. Not applicable. 9 G. 575 Market Street, San Francisco, California 94105. 10 11 Have YOU ever been identified, known, or done business under 12 any other name in the State of California? 13 RESPONSE TO INTERROGATORY NO. 4 : 14 Yes. IS mTBKRQfiftTQRY NP- 5 16 If your answer to Interrogatory No. 4 is in the affirmative, 17 please state such name or names and the time period during which 18 THIS DEFENDANT was so known or identified. 19 RESPONSE TO INTERROGATORY NO. S r 20 Standard Oil Company of California was incorporated in 21 Delaware on January 27, 1926. standard Oil Company of 22 California, Western Operations, Inc., was organized as a Nevada 23 corporation on December 1 0 , 1956. Effective 1/31/62, it was 24 merged into the Standard Oil Company of California and then 25 operated as a division until 12/31/76, with no name change. 26 Although "I n c ." was included in the name, it was not a separate 27 corporation but functioned as a division. Chevron U.S.A. Inc. was created effective 1/1/77 and Standard Oil Company of SDSFJ/ISCOC 4 02/15/00 14:31 TX/RX NO.0124 P.004 : 4 4 AM F R PAUL AND H A N LEY L L P 5 5 9 9 9 7 0 TO 1 4 1 0 4 4 8 2 3 6 8 P . 05 1 California made a capital contribution of the division's assets 2 to Chevron U.S.A. Inc. effective that date. Western Operations, 3 Inc. and/or Standard Oil Company of California ran the Richmond 4 Refinery until Chevron U.S.A. Inc. was areated. Pursuant to a 5 1985 merger, chevron U .S.A. Inc. was also formerly known as Gulf 6 Oil Corporati o n . From 1992 to 1996, Chevron U.S.A. Inc. operated 7 as Chevron U.S.A. Products Company, and as Chevron Products 8 Company from 1996 to the present as to the Richmond Refinery. 9 XNTERRPQATPRY. NQ .; 10 If YOU are not a corporation, what is YOUR business 11 structure (partnership, joint venture, sole proprietorship, 12 e t c .). 13 RESPONSE TO INTERROGATORY NO. 6 ; 14 Not applicable. Please see response to Interrogatory No. 3. 15 INTERROGATORY NO. 7 : 16 If YOU are not a corporation, please IDENTIFY all persons or 17 other entities with an ownership interest in YOU. 18 RESPONSE TO INTERROGATORY NO. 7 : 19 Not applicable. Please see response to Interrogatory No. 3. 20 INTERROGATORY NO. 8 : ; 21 If you are not a corporation, please state the following: 22 A. The address where the HISTORICAL, RECORDS of THIS 23 d e f e n d a n t are currently located; and 24 B. The name, job title and current address of the Custodian 25 for THIS DEFENDANT'S HISTORICAL RECORDS. 26 AS used herein, "HISTORICAL RECORDS" shall include all 27 DOCUMENTS relating to the formation of THIS DEFENDANT, all minutes of partners', general partners', or other owners' SD3F3/1S80 ^ 02/15/00 14:31 TX/RX NO.0124 P.005 45 AM PR PAU L AND H A N LEY L L P 5 5 9 9 9 7 0 TO 3 4 2 0 4 4 8 2 3 6 8 P .06 1 meetings, and all DOCUMENTS relating to THIS DEPENDANT'S merger 2 with, acquisition of or purchase, or sale of or by any other 3 COMPANY. 4 RESPONSE. TO INTERROGATORY NO. 8 : 5 Not applicable. Please see response to Interrogatory N o . 3. 6 INTERROGATORY N O ...9 : 7 IDENTIFY YOUR custodian of Business Records. 8 RESPONSE TO INTERROGATORY NO. 9 : 9 Chevron has offices located in many states. Business 10 records are located in many of these offiSes. without greater 1 1 specificity as to the nature of the business records sought, 12 Chevron is unable to provide a Custodian of Business Records or a 13 location of these records. Subject to the foregoing statement, 14 documents which Chevron believes to be responsive to these 15 interrogatories are maintained by Steve A. Cavazos, who may be 16 contacted through the undersigned counsel of record. 17 I N T E R R O G A T O R Y NO. 1 0 : 18 IDENTIFY the person or persons most knowledgeable about: 19 A. YOUR acquisition of RAW ASBESTOS and/or ASBESTOS 20 CONTAINING PRODUCTS; ; 21 B. YOUR use Of RAW ASBESTOS and/or ASBESTOS CONTAINING 22 PRODUCTS; 23 C. YOUR contracting with others to do work involving use or 24 handling of RAW ASBESTOS or ASBESTOS CONTAINING PRODUCTS. 25 RESPONSE TO INTERROGATORY NO. 1 0 , 26 A-B. Chevron has no one person who is most knowledgeable 27 regarding its acquisition and/or use of RAW ASBESTOS and/or 28 ASBESTOS CONTAINING PRODUCTS. Any RAW ASBESTOS acquired by SDSF3/1S506 6 02/15/00 14:31 TX/RX NO.0124 P.006 1 0 : fM FR PAUL AND HANLEY LLP 5 5 9 9 9 7 0 TO 3 4 1 0 4 4 9 2 3 6 9 P.07 1 aware that certain of its personnel attended conferences and 2 meetings of various organizations in an attempt to learn of 3 potential hazards in the workplace. 4 INTERROGATORY HO.. 1 A : 5 For each organization, association or other entity- 6 identified in YOUR Response to Interrogatory No. 13, please 7 state: 8 A. The dates during which THIS DEFENDANT was a member,* 9 B. The name(s) of any publication^) received by THIS 10 DEFENDANT from such association or organization; 11 C. The name of any committee or subcommittee of which THIS 12 DEFENDANT was a member, and the dates of such committee or 13 subcommittee membership. 14 BlSPOBfiB.IP INTERROGATORY JgP .1.4: 15 A. American Fetroleum Institute*. Approximately 1965 to the 16 present. 17 American Industrial Hygiene Association: Dates 18 Unknown. 19 Industrial Hygiene Foundation: 1955-1960. 20 National Safety Council: Dates Unknown. 21 B. Chevron and/or its employees subscribed to and 22 undoubtedly received numerous business, technical and 23 professional publications during the relevant time period. As to 24 this interrogatory, these include, but are not limited to: 25 American Petroleum-Institute: Abstracts of Petroleum 26 /// '28I /// Be.finA.nc..and Petrochemicals; Abstracts of Refining Patents SDSF3/1550C 15 02/15/00 14:31 TX/RX NO.0124 P.007 ) 1 : 4 6 AM FR P A U L AND HA N LEV L L P 5 5 9 9 9 7 0 TO 1 4 1 0 4 4 8 2 3 9 8 P.08 1 C. Membership in committees and/or subcommittees known at 2 this time include the Medical Advisory Committee, the Health & 3 Biological Science Committee and the Industrial Hygiene Committee 4 of the American Petroleum Institute. 5 INTERROGATORY NO. 1 5 ; 6 Had THIS DEFENDANT prior to 1973 received any DOCUMENTS 7 containing results or conclusions of any studies and/or tests 8 conducted by Bonsib for Standard Oil of New Jersey relating to 9 asbestos exposure in the work place or the human health 10 consequences of exposure to asbestos? If so: 11 A. Either (1) attach all DOCUMENTS evidencing the 12 information sought in this Interrogatory and its subparts to your 13 answers to these Interrogatories, or (2) attach disks containing 14 such data, or (3) describe such DOCUMENTS with sufficient 15 particularity that they may be made the subject of a request for 16 production of documents. . 17 B. State the date upon which THIS DEFENDANT first received 18 such DOCUMENTS; 19 C. State the IDENTITY of the custodian of such DOCUMENTS. 20 D. This interrogatory does not apply to DOCUMENTS contained 21 in a library maintained by a DEFENDANT hospital or a DEFENDANT'S 22 library providing access to the general public. 23 RESPONSE TO INTERROGATORY NO. 1 5 : 24 Chevron is not aware of having received any such 25 document(e) before 1973. 26 /// /// /// scspj/issoa 16 02/15/00 14:31 TX/RX NO.0124 P.008