Document zDG573EqGnbeGERnnVO9yj26

5E18bl (^ IN THE CIRCUIT COURT OF THE THIRD JUDICIAL CIRCuftDEPOSITOR ROY CARSON, BRUCE LUSK, AND WILLIAM ADAMS through LEWIS f^L OPT 'll H ` 0C` T ^7 *1987 -vs- Plaintiffs V ) JUL 1 7 H9? ^ no. 86 86-L-836, ANCHOR PACKING COMPANY; et al 86-L-834, ftfilK OF QRCUCTCpURT R, ' THIRD JUDratt.cSiT^ L 12R, RAMSON OTUNTYTiLlRcSIS through 86 Defendants ) ) ANSWERS TO PLAINTIFFS' INTERROGATORIES NOW COMES the Defendant UNITED STATES GYPSUM COMPANY, by HEYL, ROYSTER, !;VOELKER & ALLEN, its attorneys, and for their Answers to Plaintiffs' ;Interrogatories, states as follows; INTERROGATORY NO. 1: As to the person answering these interrogato ries, state: (a) Name; (b) Title or position with defendant; (c) Business Address; (d) Length of time employed by defendant; (e) State year by year all other positions, titles or jobs that person has held with the defendant. (f) The years during which Defendants have been licensed to do business within the State of Illinois, or State of Missouri and with regard to such years please state: HEYL. ROYSTER. VOELKER S ALLEN **OrcsS>OMAl COft^OAATtON ~TORNCYS AT LAW *t. lochs stscct D* jVILLE. ILLINOIS 62025 <<6I (1) The type of business conducted within the State of Illinois or State of Missouri; (2) The names and addresses of any franchise holders, dealers, or customers located in the State of Illinois - or State of Missouri during the last three years; (3) Whether or not Defendant directly or indirectly supplies the persons or entities identified in 1.(f)(2) with any products or services; if so, please describe the relationship between Defendant and those persons or entities and state the approximate dollar value of Defendant's 1930 to present sales to them 1 HRV -- 3PL. -- 116 8 5E1861 RHS:skb t ( a) United States Gypsutn Company b) 101 South Wacker Drive, Chicago, IL 60606 c) Delaware d) Date Incorporated Date Dissolved Name Sta 12/27/01 8/23/20 8/12/20 12/24/36 8/--/S2 2/04/66 7/01/66 8/23/20 10/14/27 12/24/36 8/-/S2 2/04/66 7/01/66 -/--/-- United States Gypsum Company Avery Gypsum Company United States Gypsum Company United States Gypsum Company United States Gypsum Company USG Corporation United States Gypsum Company NJ NJ IL DE IL DE DE e) This defendant has been authorized to transact business in the ;State of Illinois since 1933. Such authority was last renewed in 1985. :: f) 101 South Wacker Drive, Chicago, Illinois 60606 g) C T Corporation System, 208 South LaSalle Street, Chicago, IL 60604 ' INTERROGATORY NO. 4: Has this defendant been sued under its correct . name? If not, state the correct legal name of the defendant and provide the ^information requested in No. 3 above concerning the defendant as correctly names. ANSWER: Yes. INTERROGATORY NO. 5: Has this defendant ever acquired through purchase, reorganization or merger another corporation, company, or business which manufactured, sold, processed, distributed or contracted to apply asbestos products? HCYL. ROYSTER. VOELKCR B, ALLEN oorcss<0*At. COAPOAATIOM ~ORNCYS AT LAW JT lOUS STRCCT IDv*^ .^SVitLC. ILLINOIS 62025 <0101 010^040 ANSWER l ' hrv-pl-1 1 *7 1 4 5E1861 RHS:skb ( United States Gypsum Company acquired the assets of National Asbestos ^Manufacturing Company in 1936. National Asbestos Manufacturing Company was I;located in New Jersey and no longer exists as a corporate entity. !! ;icompany was a producer of asbestos-containing pipecovering. Said ; United States Gypsum acquired A. P. Green of Missouri in 1966. A. P. i; . iiGreen is located in Mexico, Missouri, and continues to exist as a separate .and independent corporate entity. Said company is primarily a manufacturer jjof refractory products. A small percentage of the products it manufactured i!or sold contained asbestos as part of their formulations. i! j; United States Gypsum Company acquired Chicago Mastic Company, a manu- |jfacturer of adhesives, in 1971. Said company was acquired by purchase of ii ij stock. :i .. . . . . .. . . ' 'j INTERROGATORY NO, 6: If the answer to Interrogatory No. 5 is "Yes", !i !;then state the following concerning such predecessor: i; ii ij (a) Full and correct name; ij (b) The principal place of business; :: (c) State of incorporation; (d) Date of acquisition by defendant; (e) Was this business authorized to transact business in the State of Illinois? (f) Attach copies of all papers pertaining to the acquisition. ANSWER: See this defendant's response to Interrogatory No. 5. INTERROGATORY NO. 7: As to any product containing asbestos in any form, has this defendant, or any predecessors): MEYL. ROYSTER. VOELKER a ALLEN 0rtSS0Ai CORPORATION 'ORNCYS AT LAW 5T. lOU'S STPCCT OwanQSVILLC. ILLINOIS 62023 io<ei e <4e (a) Ever designed such a product? (b) Manufactured such a product? 5 HRV-PL_1172 5E1861 RHSrskb ( ( See this defendant's resfc>onse to Interrogatory No. 12. INTERROGATORY NO. 14: In what year did the defendant first begin :! selling or distributing any products containing asbestos? j] ANSWER: ' . See attached Exhibit No. 1. !; INTERROGATORY NO. 15: In what year did the defendant last sell the iiany product which contained asbestos? j; ANSWER: i| This defendant last sold any products which contained asbestos as part i; \. | of their formulations in 1976. j ! | ll jjor i] INTERROGATORY NO. " l"l Ml . -- .. acquired business, 16: " state As to the named defendant or any predecessor(s) the various types of products, such as blocks, lipipe covering, cements, tape, spray-on insulation, mastics, and cloth, or any i! ;i other asbestos containing products and in connection with each type of such ijproduct, state how the same was packaged (i.e., bags, boxes, sacks, etc.) for ! sale. ;i ANSWER: See attached Exhibit No. 2. INTERROGATORY NO. 17: Is your company, as of the date of answering |:the$e interrogatories, still manufacturing, selling or distributing any products containing asbestos? If so, give the brand names of such products, the binding material and date first manufactured. ANSWER: See this defendant's response to Interrogatory No. 15. HEYl_. ROYSTER. VOELKER a ALLEN *ffOrcSS'ONAi CORPORATION TORNEYS AT LAW 4 ST. LOUIS STRCCT EOWARDSVILLC. ILLINOIS 6Z02S iioi e.S4ft INTERROGATORY NO. 18: Were each of your asbestos containing products generally expected to reach, or were packaged t reach, the consumer or user, without substantial change in the condition in which it was sold? 9 HR V" -- PL -- 1 1 V 6 5E1861 RHS:skb ( ( ANSWER: ' Yes. INTERROGATORY NO. 19: If your answer to Interrogatory No. 18 is "No", with respect to any product, explain in what way the defendant claims its products were altered or substantially changed after sale or distribution and before reaching the helper, mechanic or bystander. ANSWER: 'i Not applicable. :i INTERROGATORY NO. 20: Based upon the material contents of your ^products, the method of manufacturing, and the method of application, can i; liyour products be generally applied or installed without liberating asbestos 'fibers? '. s! (a) If there is a different answer concerning different products i manufactured, sold, distributed, or used by your company then specify the different products by exact manufacturers name and popular name. i; (b) If there is a difference in your answer depending on the year or ; years in which a particular product was used, then specify in detail i; what year or years you are referring to and the specific products you ! are referring to and the year involved. ANSWER: . j U. S. Gypsum is aware of tests which were performed to measure the release of asbestos fibers during the mixing and sanding of joint compounds. Non-privileged, relevant documents will be made available for plaintiff's inspection at a mutually convenient time through U. S. Gypsum offices at 101 South Wacker Drive, Chicago, Illinois 60606. INTERROGATORY NO. 21: Was it a foreseeable use of your asbestos con taining products that they may have to be removed, stripped or replaced at HCYL. ROYSTER. VOCLKCR aallen *OrcSSOMAL CORPORATION 'TORNCYS AT CAW ST. LOUIS STRCCT CC^ -OSVILLC. ILLINOIS 62023 6}(-46<0 any time after installation? If your company contends the plaintiff(s) . 10 11RV-PL- 1 1 7 *7 5E1861 RHSiskb ( INTERROGATORY NO. 32: `Has your company or its predecessor(s) ever conducted any studies concerning the effects of the inhalation of asbestos (dust or fibers on one.using or being exposed to any of the asbestos materials :i [manufactured, sold or distributed by you, or your predecessor(s)? If answer i;to this question is "Yes", give the date and nature of such studies, if any; ithe name or names of the persons conducting such studies and their addresses; iwhat the purpose of the studies were; and attach a copy of any reports based i ;!upon such studies, showing to whom such reports were given, and the date, jj ANSWER: ' . | U. S. Gypsum is aware of tests which were performed to measure the jirelease of asbestos fibers during the mixing and sanding of joint compounds. J; '. _ | U. S. Gypsum is aware that it may have contributed to a study conducted approximately 1936 by Dr. Leroy Gardner of the Saranac Laboratory. ; Relevant documents relating to the studies referenced above will be made available for plaintiff's inspection at a mutually convenient time at 101 -South Wacker Drive, Chicago, Illinois 60606. INTERROGATORY NO. 33: Has your company or its predecessor(s) ever ! conducted or caused to be conducted any studies designed to minimize or ; eliminate the inhalation of asbestos dust and fibers by those exposed to the use of your company's asbestos products? If so, give the following: (a) Name of the person or firm conducting such studies. (b) The date the studies began and the date completed. (c) Any publication or dissemination of the results of the studies. HCYL. ROYSTER. VOELKCR & ALLEN *OTCSSOMAL COPO**TiOM *TTORNEY5 AT LAW T LOU'S STRICT :Ov, .VILLC. ILLINOIS 62023 *0l OSO-44 (d) The nature of any action to eliminate or minimize inhalation of asbestos dust or fibers. (e) Attach copies. ANSWER: HR V -- PL. -- 118 1 14 5E1861 RHSrskb Not to this defendant's best current knowledge, information and belief. INTERROGATORY NO. 34: If your answer to Interrogatory No. 33 is "Yes", state the name and address of such industrial hygienist or hygienists. ANSWER: Not applicable. See this defendant's response to interrogatory No. 33. !; INTERROGATORY NO. 35: Does your company have, has it ever had, or has it ;:your predecessor(s) ever had, a Research Department? If so, give the year :isuch Research Department was established, and whether or not such Research !i . jjDepartment has operated continuously since being established. |j (a) How much expended each year on research, etc. . !: (b) What percentage of gross sales did your company or its u predecessor(s) spend on research concerning the health affects ii of asbestos. . !j ANSWER: ; This defendant has has a Research Department since 1921. The Research i, jj Department has never operated solely for the research and development of jj . asbestos-containing products. No medical research is performed by this i! hdepartment. a) Objection. This interrogatory is overbroad in that it is not limited to asbestos, the focus of this litigation. Therefore, this interrogatory is irrelevant and immaterial and will lead to the discovery of no admissible evidence. ; b) Objection. This interrogatory is overbroad. This defendant's Research Department, to this defendant's best current knowledge, information and belief, did not conduct research "concerning the mcyl. norSTCR. voelker & ALLEN PAO'CSSOmai CO**OAaTiOm 'TORNCrs AT LAW st cou'S stacct !>.. ^SVtLLC. ILLINOIS 620?S i<ei ese-Ae^e health effects of asbestos." INTERROGATORY NO. 36: Prior to 1965, did your company, or any pre decessors), ever at any time give persons "ho would h* aDDlvina or removing 15 HRV-PL-1182 5E1861 RHS:skb ANSWER: ' 1 Information may have been furnished upon request. This defendant has no l!further information in answer to this interrogatory. i| INTERROGATORY NO, 46: Prior to 1964 did your company or its pre- !!decessor(s) ever manufacture products containing asbestos without a warning? i` - "List the years. ;! ANSWER: Objection. This interrogatory is overbroad in that it is not limited to jiwarnings related to asbestos, the issue relevant to this litigation. ; However, without waiving said objection, see Exhibit No. 3. i INTERROGATORY NO. 47: After 1964 did you ever manufacture products [containing asbestos without a warning? If so, list the name of the product !:and the years. ANSWER: : Objection. This interrogatory is overbroad in that it is not limited to ;;warnings related to asbestos, the issue relevant to this litigation. iHowfever, without waiving said objection, see Exhibit No. 3. : INTERROGATORY NO. 48: If your company, as of the date of answering "these interrogatories, still manufacturing, selling or distributing any ;products containing asbestos? If so, give the brand names of such products and the binding material and dates of first manufacture of such product. ANSWER: This defendant, as of the date of answering these interrogatories, is not manufacturing, selling or distributing any products which contain HCYL. ROYSTER. VOCLKCR & ALLEN *OrcSSONAl C04MOAATIOM 'TORNCYS AT LAW ST. LOUIS ST#CT O* -SVILLC. ILLINOIS 62023 I asbestos as part of their formulations. INTERROGATORY NO. 49: Did your company or any predecessor(s) ever have a division or subsidiary company engaged in the contracting business of 19 HRV-PL-- a 18 6 5E1861 RHS:skb applying asbestos products? If so, give the name of such division or sub sidiary company, the full address of the home office of such division or subsidiary company, and the dates such division or subsidiary company was engaged in the contracting business. ANSWER: Prior to 1940, a group within U. S. Gypsum's corporate structure was engaged in contracting. It is unknown whether said group formally was a "division" or "unit", as no documents have been located from which to verify this information. U. S. Gypsum has no further information. INTERROGATORY NO. SO: Did any division of your company or subsidiary company engaged in the contract business of applying asbestos products or your workmen's compensation insurance carrier ever have any claims for lung diseases or death from lung diseases, whether directly or indirectly attri buted to asbestosis, mesothelioma, lung cancer, or any exposure to asbestos j;products prior to 1972? If the answer is "Yes", give the name of such . jl ji li employees and attach copies of such claims and copies of all documents relat- i! ' * liing to the disposition and handling of such claims. i! ANSWER: il See this defendant's response to interrogatory No.49. INTERROGATORY NO. 51: Give the location of the state industrial acci- jident board handling each such claim, the disposition of such claims, and the |jamounts paid in workmen's compensation benefits to each such employee, and i; the name of the compensation carrier. !i l| ANSWER: HCrt. ROYSTER. VOCLKCR i] ftALLCN :j ''AOfCSflOMAL COA*QKA1tO< *CYS AT LAW COUI5 STACCT I;|j I: WAROSVILLC. ILLINOIS 62023 l! <a<i i! Not applicable. See this defendant's response to interrogatory No. .49. 20 HRV -- 1PL. -- 118V SE1861 RHS:skb 0 (( INTERROGATORY NO. 52: Did your company or its predecessor(s) ever make any industrial hygiene surveys concerning its asbestos products? If so, jigive the date of such surveys, and attach copies of such surveys. :i ANSWER: : As relates to this defendant's asbestos-containing products, not to this ^defendant's best current knowledge, information and belief. j! INTERROGATORY NO. 53: State the year that this defendant or any pre- i' ;|decessor(s) was first advised of either threshold limit values or maximum !i i< # . jiallowable concentrations of both asbestos dust and total dust by the American jj jiConference of Governmental Industrial Hygienists, and state the name -of the !i j I employee-official of the company receiving such advise and attach copies of L! \\ ' iithe instrument communicating such advise. . il ANSWER: United States Gypsum Company understands the term "threshold limit :value" to mean a concentration to which nearly all workers can be exposed, jiday after day, without adverse effect. ; This defendant recognizes that The American Conference of Governmental ij Industrial Hygienists defines "Threshold Limit Values - Time Weighted ijAverage" as the time weighted average concentration for a normal 8-hour work iday or 40-hour work week, to which nearly all workers may be repeatedly :exposed, day after day, without adverse effect. This defendant has located no information indicating when it first became aware of the term. : INTERROGATORY NO. 54: Was such threshold limit values or maximum HCYL. ROYSTER. VOCLKCR ft ALLEN WKKCSSiONAt COAOAATio ^NCVS AT LAW . lOU'S STOCCT DWAftuaVJLLC. ILLINOIS 6eOZ5 allowable concentrations inquired,about in Interrogatory No. and not just asbestos dust? ANSWER: 53 TOTAL dust 21 HRV-PL_1188 SE1861 RHS:skb a (( See this defendant's response to interrogatory No. 53. : INTERROGATORY NO. 55: State in detail what test, if any, your company jiever made with regard to the quantity, quality or threshold limit values or |i jjasbestos dust or particles to which applicators or consumers of your product ijwere exposed while using your products containing asbestos. ii I: (a) If there were any such tests or studies, give the name or names of jj the person(s) conducting the tests, the date of the tests and attach !! true copies of any reports, findings or memorandums concerning such |i tests or studies. j ANSWER: . ' | As relates to this defendant's asbestos-containing products, U. S. ii Gypsum is aware of tests which were performed to measure the release of asbestos fibers during the mixing and sanding of joint compounds.. ! . j INTERROGATORY NO. 56: When did any official with your company first Jhave knowledge, information or understanding that asbestos would or could or I Jmight produce the diseases of: (a) Asbestosis; (b) Mesothelioma; ' ' (c) Lung cancer; (d) Any other diseases; j Jj (e) With reference to your company, give the name of such official jj who first had such knowledge, list them and attach copies.' ij . (f) If there are any documents, records or memorandums of any kind ! concerning such knowledge, list them and attach copies. ANSWER: j:. See attached Exhibit No. 4. INTERROGATORY NO. 57: Do you have any photographs of the products MEYl_ ROYSTER, VOELKCR a allcn :| inquired about above or their packages or containers? **OrCSS*OMAL COAPOAATtOM RNETS AT LAW *T. LOtl'S 3TCCT ;;exact copies. COWAnOSviLLC. ILLINOIS 02023 (<ei If so, please attach 22 118 9 Exhibit 4 (( United States Gypsum Company has been aware since the mid-1930's that inhalation of large quantities of asbestos fibers for long periods of time could produce a pneumoconiotic lung condition known as asbestosis. United States Gypsum Company is presently unaware of specifically now it acquired this knowledge. United States Gypsum Company is now aware that a relationship between the inhalation of asbestos, fibers and the development of bronchogenic carcinoma became generally recognized in the medical and scientific community in 1949, as evidenced by an editorial on the subject which appeared in that year in the Journal of the American Medical Association. United States Gypsum Company is not aware of precisely when it first knew of the relationship between the inhalation of asbestos fibers and the development of bronchogenic carcinoma, excep.t that it does know that one of its employees, E. C. Beuthin, United States Gypsum Company's first Safety Director, attended a conference in 1955, at which papers discussing this relationship were presented. United States Gypsum Company is now aware that the first published study which established a direct association between the inhalation of asbestos fibers and the development of mesothelioma was the 1960 epidemiological study entitled "Diffuse Pleural Mesothelioma and Asbestos Exposure in the North HRV -- PL-- 12 2 1 (( Western Cape Province" by J. C. Wagner, et al., which described mesothelioma occurrence among persons exposed to crocidolite. at or near crocidolite mines in South Africa. United States Gypsum Company is not aware of precisely when it first knew of the relationship between the inhalation of asbestos fibers and the development of mesothelioma, except that it believes that the first employee to become aware of this association was G. R. Krug, one of United States Gypsum Company's former Safety Directors. Mr. Krug has testified that he first became aware in the early to mid-1960's of the association between exposure to asbestos fibers and the development of mesothelioma in asbestos miners, as a result of reading articles in newspapers and magazines. hRv-pl_ 12 2 2 5E1861 RHS:skb (( (( determine who would have the knowledge of information that plaintiff is seek ing . INTERROGATORY NO. 60: As to each product identified in response to the foregoing interrogatory please indicate: (a) The type of asbestos contained in the product as it was first manufactured; (b) The percentage of asbestos contained in the product as it was first manufactured; (c) Any modifications to the product which altered the percentage or type of asbestos in the product and the dates of such modification; (d) The source of asbestos in each product; (e) The color, physical characteristics, and appearance of each product; (f) A full and complete description of the package in which the product was sold, including, but not limited to, type of package, size, color(s), and writings thereon; (g) All other names under which the product was sold; (h) The number and date of each patent or patent application as to the product; ' (i) If the product continued to be produced after the deletion of asbestos, all reasons why the asbestos was deleted, the identity of the person who made the decision to delete the asbestos, and the date the product was first produced without the asbestos; (j) If the product is no longer produced, all reasons it was dis continued, the identity of the person who made the decision to dis continue the product, the brand name of replacement product, and the date the replacement product first went into production; (k) The identity of the custodian, managing agent, or employee who has photographs, drawings, or labels for each product; (L) The reasons why asbestos was used as an ingredient in each such product; HEYL. ROYSTER. VOELKER ft ALLEN *+orCO**0aT*Ow NCVS AT LAW t. tou<s STecT ?WAOSVILLC. ILLINOIS 62023 <<! e9-4-40 (m) The content of any warning labels, inserts or other writings provided with such product with ever such printed warning, what period of time it has or had accompanied the product, the exact wording of the warning, any amendments made to the the wording, whether the warning was located on each product or packaging 1 -- products the warnings appear(ed); 24 HRV-PL--1191 I5E1861 :iRHS:skb e a (n) Any special instructions provided with such product regarding the use, protection or safety procedures to be employed by persons handling such product. ANSWER: i a) Chrysotile was the "type of asbestos" used in virtually all U. S. Gypsum Company products that contained asbestos. U. S. Gypsum now under stands that amosite asbestos may have been used as a component ingredient in jirigid block insulation for short periods of time. !> b) See attached Exhibit No. 5. jj c) See attached Exhibit No. 5. :l d) The following are known to have been approved suppliers of asbestos: Canadian Johns-Manville, Lake Asbestos of Quebec, Nicolet 'Industries, Carey Canadian, Asbestos Corporation, Atlas Asbestos, Union Carbide, and Pacific Asbestos. Atlas Asbestos ad Pacific Asbestos shipped only to California. United States Gypsum Company also purchased small amounts of asbestos from North American Asbestos for a short period of time. ;;It is unknown which source of supply was used for any particular product, at . which mines the raw asbestos was mined, and from which locations the raw ;asbestos was shipped. U. S. Gypsum has located no documentation to ascertain Ifrom which particular supplier asbestos was purchased prior to 1975. For the years 1975 and 1976, U. S. Gypsum has located some records of purchase of asbestos. e) See attached Exhibit No. 6. f) See attached Exhibit No. 2. g) See attached Exhibit No. 1. MCYL. ROYSTER. VOELKER & ALLEN tlO"'VO*L CO>**OOATOM 'NETS AT LAW -r. lows STbcct DWAROSVILLC LLINOS 6ZOZS <e h) This defendant does not,maintain its patent files in such a manner as would facilitate retrieval of this information. To the extent such information is available to United States Gvosum Company and would not 25 HKV --X>L-- l. 1 9 2 SE1861 RHS:skb ({ (J require it to undertake an unreasonable investigation at an unreasonable cost, it is contained in documents which United States Gypsum Company will provide through its offices at 101 S. Wacker Drive, Chicago, Illinois 60606. i) See attached Exhibit No. 7. , j) See attached Exhibit No. 7. k) This defendant's Legal Department. l) Asbestos adds body when added to a material and also increases the ;iworkability of a material by increasing its water-holding properties. !'. In addition, asbestos was included in the formulations of some !;products to increase the fire rating of such products. !| m) See attached Exhibit No. 3. i n) See attached Exhibit No. 3. li ii i! ;:No. INTERROGATORY NO. 61: With respect to your Answer in Interrogatory 60, did you specifically inform the purchaser or user of your products i; ;!during the same time period that your products were manufactured and sold jjthat such products could cause cancer, asbestosis, and other serious diseases? ANSWER: Not to this defendant's best.current knowledge, information and belief. INTERROGATORY NO. 62: Identify the distribution chain of defendant's asbestos products since 1925 along with any documents evidencing or. confirm ing such chain, including but not limited to distribution from and to other defendants. ANSWER: Heru ROYSTER, VOCLKCR n a ALLEN coa*0*>at*on *trs at law *** -T. LOUIS STCCT >*AOSVILLE. (LLINO*S 62025 iei )A-440 U. S. Gypsum does not possess any records maintained in the normal . course of business which identify who the ultimate user of the product was or where it was installed. With that limitation, U. S. Gypsum responds as 26 HRV-PL- X 19 3 ExniDit o (( PERCENTAGE OF ASBESTOS (VOLUME) ACOUSTICAL PLASTERS PRODUCTS SABINITE "TF" SABINITE "B" SABINITE 38 (HYDRAULIC) SABINITE ACOUSTICAL PLASTER SABINITE "M" and SABINITE SPECIAL WHITE SABINITE "F" SABINITE "A" or SABINITE HYDROCAL HI-LITE ACOUSTICAL PLASTER AUDICOTE SPECIAL WHITE DATE No Change 04/18/33 11/03/33 11/10/30 04/18/32 01/13/37 07/12/39 05/23/30 01/01/31 06/29/32 05/03/40 10/18/40 01/23/48 02/27/44 07/28/50 07/28/50 09/18/52 04/04/31 04/18/33 11/03/33 06/09/53 03/31/55 09/15/55 08/24/56 10/31/56 12/14/56 03/27/57 12/02/57 12/02/57 03/10/58 03/27/58 04/04/58 05/16/58 05/29/58 05/29/58 05/29/59 PERCENT ASBE: 4.90% 2.00% 4.00% 2.40% 3.00% 2.00% 3.00% .98% 2.50% 2.00% 4.00% 4.00% 6.30% 4.00% 3.00% 4.00% 3.00% 4.00% 2.00% 4.00% 6.20% 6.30% 8.25% . 7.62% 7.60% 8.00% 7.70% 6.95% 22.50% 7.10% 6.95% 22.50% 16.89% 17.09% 16.89% 16.88% Page 1 of HRV-PL-1223 (( ACOUSTICAL PLASTERS PRODUCTS AUDICOTE SATIN WHITE ' RED TOP ACOUSTICAL PLASTER* *SPRAYDON STANDARD A *SPRAYDON STANDARD G *SPRAYDON POWERCOTE DATE 05/29/59 12/06/60 07/14/61 07/06/62 08/07/62 02/05/64 08/11/64 09/15/55 08/24/56 10/31/56 03/27/57 12/02/57 03/10/58 03/27/58 04/04/58 05/16/58 05/29/58 05/29/58 05/29/59 05/29/59 12/06/60 07/14/61 07/06/62 08/07/62 02/05/64 12/22/64 04/25/51 No Change . No Change No Change PERCENT ASBESTOS 16.9 3% 8.33% 8.46% 7.63% 7.65% 7.64% 7.63% 8.43% 7.78% 7.76% 7.47% 26.24% 8.06% 7.47% 26.24% 19.66% 19.49% 19.66% 19.22% 19.70% 8.60% 8.73% 7.85% 7.87% 7.86% 7.85% 9.70% 29.70% 7.60% 30.00% * SprayDon - U. S. Gypsum manufactured this product pursuant to the specifications of Sprayon Research Corporation. TEXTURE PRODUCTS DATE PERCENT ASBESTOS PAC-TEX 1943 1953 1954 4.5 4.5 3.5 -6.0 Page 2 of HRV -- IPL, -- 1224 A-B TEX ( USG TEXTONE TEXTURE PAINT SPECIAL TEXTURE PAINT SPRAY TEXTURE PAINT IMPROVED SPRAY TEXTURE MULTI-PURPOSE TEXTURE SANDED COLORED TEXTURE PAINT USG MULTI-PURPOSE TEXTURE PAINT USG TEXTURE PAINT SPRAY TEXTURE PAINT USG MULTI-PURPOSE SPECIAL WHITE ' USG MULTI-PURPOSE USG MULTI-PURPOSE SPECIAL TEXTURE PAINT USG MULTI-PURPOSE SPRAY TEXTURE ( 1935 1943 1944 1928 1930 1934 1938 1943 1947 1952 1955 1956 1958 1960 1970 1971 No Change No Change No Change No Change No Change 1954 1964 No Change 1966 1968 1969 No Change No Change No Change 1956 No Change 4.0 4.5 4 .0 3.3 - 4.5 2.8 - 4.5 3.3 - 4.5 2.67 - 5.0 2.67 - 6.0 2.67 - 8.0 2.5 - 3.5 1.2 - 3.5 2.3 - 3.5 1.2 - 6.0 1.2 - 10.0 .5 - 10.0 .5 - 3.5 3.0 - 4.0 1.5 - 2.5 1.5 - 2.5 6.0- 10.0 2.0 - 4.0 1.0 - 1.4 6.0 - 10.0 2.5 Unknown 5.0 2.0 5.0 6.0 - 10.0 4.0 Unknown 4.0 Page 3 of IIRV-PL -- 12 2 5 (( USG MULTI-PURPOSE SPRAY TEXTURE SPRAY TEXTURE AB TEX TEXTURE PAINT AB TEX TEXTURE PAINT USG TEXTURE MULTI-PURPOSE SPRAY TEXTURE PAINT WHITE SPRAY TEXTURE PAINT SPRAY TEXTURE PAINT SIMULATED ACOUSTICAL SPRAY SIMULATED ACOUSTICAL SPRAY SPRAY TEXTURE SPRAY TEXTURE SIMULATED ACOUSTICAL SPRAY. SIMULATED ACOUSTICAL SPRAY AGGREGATED SPRAY TEXTURE AGGREGATED SPRAY TEXTURE SIMULATED ACOUSTICAL SPRAY "QT" SIMULATED ACOUSTICAL SPRAY IMPERIAL QT SPRAY 1972 1973 No Change No Change No Change No Change 1971 1969 1973 1958 1971 No Change No Change . No Change No Change No Change No Change 1961 1962 ' No Change 1962 1963 No Change 19 64 1969 1971 No Change AGGREGATED SPRAY No Change Page 4 of ' Unknown 4.0 1.5 - 2.5 .5 1.2 - 1.6 1.6 - 3.5 Unknown 7.3 0.0 1.5 - 3.0 4.5 - 6.0 1.5 - 3.0 8.0 8.0 1.5 - 3.0 1.5 - 4.0 8.0 Unknown 8.0 1.0 1.0 .5 - 1.5 2.0 2.0 5.0 4.4 1.5 2.8 HRV-PL-1226 IMPERIAL QT REGULAR VERMICULITE SPRAY TEXTURE SMOOTH HARD FINISH IMPERIAL QT TEXTURE USG SUPER HARD SPRAY USG SPRAY TEXTURE SPRAY TEXTURE FINISH USG TEXTURE XII USG SPRAY TEXTURE USG TEXTURE XII SUPER VINYL USG SPRAY TEXTURE FINISH SHEETROCK SMOOTHCOAT USG EXTERIOR TEXTURE WALLBOARD FINISH EXTRA HARD FINE IMPERIAL QT SIMULATED ACOUSTICAL SPRAY TEXTURE SIMULATED ACOUSTICAL SPRAY TEXTURE IMPERIAL QT TEXTURE SIMULATED ACOUSTICAL SPRAY SIMULATED ACOUSTICAL SPRAY SIMULATED ACOUSTICAL SPRAY ( No Change No Change No Change No Change No Change No Change No Change No Change No Change 1971 1972 1971 1974 No Change No Change No Change No Change No Change No Change No Change No Change No Change 2.0 5.0 1.0 2.0 1.2 5.0 .1 3.0 5.0 3.0 Unknown 4.0 5.0 . 1.0 4.0 1.0 - 3 8.0 8.0 4.0 6.0 6.5 10.0 Page 5 of 0 HRV -- PL-- 12 2V (( SIMULATED ACOUSTICAL SPRAY No Change SIMULATED ACOUSTICAL SPRAY No Change SIMULATED ACOUSTICAL SPRAY No Change SIMULATED ACOUSTICAL SPRAY No Change IMPERIAL QT No Change IMPERIAL QT No Change IMPERIAL QT No Change IMPERIAL QT No Change MULTI-PURPOSE TEXTURE No Change READY-MIXED SIMULATED ACOUSTICAL SPRAY 1966 IMPERIAL QT 1966 IMPERIAL QT 1966 IMPERIAL QT 1966 IMPERIAL QT 1966 IMPERIAL QT Polystrene 1966 SHEETROCK RADIANT HEAT SIMULATED ACOUSTICAL SPRAY 1966 SHEETROCK SIMULATED ACOUSTICAL SPRAY 1966 SHEETROCK SIMULATED ACOUSTICAL SPRAY 1966 AGGREGATED SPRAY TEXTURE 1966 IMPERIAL QT REGULAR 1967 IMPERIAL QT REGULAR NC-4 1967 1968 Page 6 o* 8.0 2.S - 4.5 2.5 - 3.5 2.0 2.0 8.0 5.0 4.0 2.6 Unknown 4.0 .94 - 1.' 2.0 - 3.0 3.0 6.0 6.0 2.0 3.5 5.0 Unknown 8.0 6.0 HRV -- IPL -- 12 2 8 IMPERIAL QT USG SPRAY TEXTURE FINISH USG SPRAY TEXTURE FINISH XH WHITE AGGREGATED SPRAY TEXTURE IMPERIAL QT IMPERIAL QT IMPERIAL QT COARSE VERMICULITE No Change 1965 1965 1968 No Change No Change No Change No Change 2.0 .5 .5 .5 - 1.5 1.0 2.0 4.0 2.0 IMPERIAL QT COARSE VERMICULITE USG SPRAY TEXTURE R USG CONCRETE CEILING TEXTURE .. . 1970 1971 No Change . No Change 5.1 6.1 1.5 6.0 TEXTONE TEXTURE FINISH 1944 1967 1972 2.5 - 4.5 3.5 - 5.5 2.5 - 4.5 Miscellaneous Specialty Plasters - Generally less than 1% Fireproofing Plasters Firecode V Firecode V Type D Approximately 12% Approximately 12% Ceiling Tile Acoustone 120* Acoustone 180 Approximately 3% Approximately 3% Texture Products - Approximately 3 - 5 %. Investigation continues as to individual texture products. Paste Spacklinq Putty - Approximately 3% Pipecoverings - Approximately 30 - 91% *Not all formulations contained asbestos. Page 7 of 0 HRV -- PL --12 2 9 (( Joint Compounds - Approximately 3-5% Rigid Block Insulation - Approximately 10 - 21% Mortar - Less than 1% Siding Shingles - Approximately 12 - 15% Roofing Shingles - Approximately 0.6 - 1% Variation in asbestos content is usually reflective of formula changes relative to working properties. Page 8 of 0 HRV-PL-1230 STATE OF ILLINOIS ) ) COUNTY OF COOK ) SS VERIFICATION I. C. L. Murphy, declare: I am the Manager. Analytical & Administrative Services, of United States Gypsum Company, one of the above named defendants, and am authorized to make this verification for and on behalf of said corporation; I have read the foregoing Answers. Objections, and other responses to Plaintiff's Interrogatories and am informed and believe that the same is true and on that ground allege that the matters therein stated are true. I declare, under penalty of perjury, that the foregoing is true and correct, and that this declaration was executed on July 13, 1987 in Chicago. Illinois. Subscribed and sworn to before me Notary^ Public HRV -- I3 L, -- 12 11 5E1861 RHS:skb ( ANSWER: ' a-e) C. L. Murphy, Manager, Analytical and Administrative Services, United States Gypsum Company, has reviewed these responses for the purpose of -satisfying the verification requirements. These responses have been prepared ilbased on the continual review of documents located in this defendant's files jiand information obtained from discussions with this defendant's employees iover a period of many years. It is not possible to reconstruct each step ; taken to gather this information or to verify all documents which might iipossibly pertain to the matters at issue that have been located or examined :in connection with these responses. Nor is it possible to specifically identify by name each person who has participated in the preparation of these responses or to identify each document which may have provided information ;'used in preparing these responses. f) (1) This defendant has been licensed to do business in the state :;of Illinois since 1933 and the state of Missouri since 1936. ; (2) Objection. This defendant has not produced products which contain asbestos as part of their formulation during the last three years. -Therefore, this Interrogatory is irrelevant and immaterial and will lead to the discovery of no admissible evidence. (3) Objection. This interrogatory is irrelevant as no entities have been identified in 1(f)(2). INTERROGATORY NO. 2: Has the person answering these Interrogatories made reasonable inquiry of all available sources of information such that Plaintiff may rely on these answers as the truthful and complete answers made -IEYl. ROYSTER. VOELKER on behalf of this answering defendant? State the proper legal name and the a ALLEN BKKCSSiO*<*L CORPORATION "'OHNEYS AT LAW present address of the principal place of business of each of defendant's T COW'S STRCCT related companies. N* jVILLC. ILLINOIS 62023 IR'RI R3R-ASAR For each related comp^"" ' ',ar,+' -i f nlo^sp state: 2 HRV--PL-1169 5E1861 RHS:skb ( ' HCYL. ROYSTER, VOELKER a ALLEN MO^CSStOMAU COA^OAATIOK ORNCVS AT LAW S* lOU'S STCCT OWADSVLLC. ILLINOIS 62025 iei e)A4c (a) Whether or not the company is licensed to do business in the State of Illinois; (b) The business relationship between the company and defendant; (c) The nature of the products or services that defendant sells to or purchases from the company; (d) The type of business the company conducts within the State of Illinois (e) Whether or not the company advertises Defendant's products or services within the State of Illinois; (f) Whether or not the company sells Defendant's products or services within the State of Illinois; and, if so, the approximate value of those sales or services during 1930 to present; (g) Wnether or not the company pays any type of taxes to the State of Illinois or any political body located within the State of Illinois; . (h) Whether or not defendant has any control, directly or indirectly, over the company's advertising of defendant's products or services. ANSWER: See this defendant's response to Interrogatory No. l(a-e). INTERROGATORY NO. 3: State the following concerning this defendant: (a) Full and Correct name; , (b) Principal place of business; (c) State of incorporation; ' (d) Date of incorporation, and name of Corporation (e) Is this defendant authorized to transact business in the State of Illinois? If so, state the date such authority was first issued and last renewed; (f) Does this defendant have an agent, representative or place of business in Illinois? If so, state the name and address of such agent, representative, or other place of business; (g) Does this defendant have an agent for service in the State of Illinois? If so, state the name and address of the registered agent. ANSWER: 3 HRV -- 3PL. -- 1 1 T O 5E1861 RHS:skb (c) Processed such a product? (d) Sold such a product? (e) Distributed such a product? (f) Patented such a product? (g) Relabeled such a product which was manufactured, sold or distributed by another company? ANSWER: a) Yes b) Yes c) Objection. This defendant objects to the term "processed" vague and ambiguous. Therefore, this defendant is unable to form a meaning-, :ful response. d) Yes ` e) Yes :: f) This defendant does not maintain its patent files in such a manner ::as would facilitate retrieval of this information. This defendant will make I; information responsive to this inquiry available to the plaintiff at a jjmutually convenient time at 101 South Wacker Drive, Chicago, IL 60606. i! !' g) U. S. Gypsum manufactured colored exterior stucco for National jiGypsum Company from the 1940's to the 1970's. This was resold under National ::Gypsum's Gold Bond label. U. S. Gypsum possesses documents which indicate that it was authorized to manufacture exterior finish stucco for the follow ing companies who sold it under their company label: National Brickstone, early 1960's; Brickstone International, early 1960's to early 1970's; Temple Brick Corporation, mid-1960's. HEYL. ROYSTER. VOELKER ft ALLCN *OOrcsSK3N*L CO**OBaT*On OBNEYS AT Law . ST. LOCHS STCCT OWABOSVILLC. ILLINOIS 62023 6 HRV -- 1PL. -- 117 3 :5E1861 RHS:skb U. S. Gypsum manufactured a high temperature block insulation product for A. P. Green Refractories Company for an eighteen month period in 1970 and 1971. ' Further, U. S. Gypsum manufactured SprayDon Fireproofing from 1966 to 1971 for the Sprayon Research Corporation. Those products were sold ad ;distributed by Sprayon Research Corporation and Metropolitan Spray, and manu factured according to Sprayon specifications by this defendant. The above-referenced documents will be made available for plain- 'itiff's inspection through U. S. Gypsum's offices at 101 South Wacker Drive, jj Chicago, Illinois 60606. 11 INTERROGATORY NO. 8: If your answer to No. 7(b), 7(d), and 7(e) is '"Yes", then give the trade name of the product, the year the defendant or iipredecessor first sold or distributed such product, and the year the defendant last sold or distributed such product, i; ANSWER: j ' " ii;= jl See attachedExhibit No. 1. |! . INTERROGATORY NO. 9: . Have any of the products listed above in ]! Interrogatories No. 7 been altered in chemical composition since first being il !: : marketed? . ANSWER: : Objection. Thisdefendant objects to this interrogatory as being overbroad and burdensome. There may have been many minor changes over the years due to raw material availability and differing geographical market conditions; however, it would be extremely time consuming and burdensome to MEYL. ROYSTER. VOELKER ft ALLEN MOrCSSiOMAi. CORPOoaTiOm ^ORNEYS AT LAW ST. lOlMS STUCCT CO*. ^SVILLC. ILLINOIS 62025 ei document each and every one of those minor changes. INTERROGATORY NO. 10: If so, please state: (a) The trade name of each such product: 7 HRV-PL- 117 4 5E1861' RHS:skb ( ~ (b) The date each such product was altered; (c) The nature of the alteration; i (d) The reason for the alteration. ANSWER: : Not applicable. See this defendant's response to interrogatory No. 9. INTERROGATORY NO. 11: What is the name, address, and the job title of 'each individual who participated in the design and preparation of manufactur ing specification for each such product? ANSWER: Objection. This interrogatory is overbroad, burdensome and harassment ;!to this defendant. This defendant has employed thousands of employees since i - , . its inception, and thus it would be impossible to determine who would have ihe knowledge or information that plaintiff was seeking. INTERROGATORY NO. 12: Do any written memoranda, specifications, blue prints or other written materials of any kind of character.relating to the design and preparation of said products now exist? ANSWER: Operating bulletins which plaintiff can establish are relevant to the ' subject matter of this litigation will be made available for plaintiff's inspection at a mutually convenient time at 101 South Wacker Drive, Chicago, IL 60606. INTERROGATORY NO. 13: If so, please state: (a) List each written material or document; HEYL. ROYSTER. VOELKER aallen "O^ISSKXMI CORPOAaTOm -OBNtrS AT LAW T. lOUIS STftCCT CM. jVILLC. ILLINOIS 62023 lil (b) Who presently has possession of each such document? (c) Where is it located? ANSWER: *--"" HRV-PL-- 1 1 V 5 8 5E1861 RHSrskb ( ( _ misused any of your products then state how and under what circumstances your product was misused. ANSWER: :: Objection. There is no indication in these cases that this defendant's I'asbestos-containing products have been removed, stripped, or replaced at any j;time after installation. Therefore, this interrogatory is overbroad, irrelevant, immaterial and not calculated to lead to the discovery of ^admissible evidence. I; INTERROGATORY NO. 22: Prior to releasing the asbestos products manu- ijfactured, sold, etc. to the public for sale, were any tests conducted on same ito determine potential health hazards involved in the use of materials con- 'tained therein? . ANSWER: !; Objection. This defendant objects to this Interrogatory as not being limited to asbestos, the focus of this litigation. Furthermore, no product "can be tested for all "potential health hazards involved in the use of materials contained therein", therefore this interrogatory is overbroad and : burdensome. INTERROGATORY NO. 23: If so, please state: (a) The name, address, and job classification of each individual who conducted such tests. (b) The results of such said tests. (c) Date of such studies. ANSWER: HCYL. ROYSTER. VOCLKER 6 ALLEN voortSSiOMAi. CO*pOAaTiOm TORNCYS AT LAW - ST LOU'S STCO EOWAPOSvil.Lt. ILLINOIS 620S Not applicable. See this defendant's response to interrogatory No. 22. - hrv -- pl-- lavs 11 5E1861 RHS:skb ( ( INTERROGATORY NO. 24: ` Do any written memoranda, specifications, blue prints or other written materials of any kind or character exist relating to 'the testing of said product? 1 ANSWER: r Not applicable. See this defendant's response to interrogatory No. 22. INTERROGATORY NO. 25: If so, please state: (a) List each such written material or document. ; (b) Who presently has possession of each such document and where it is located. : ANSWER: ; Not applicable. See this defendant's response to interrogatory No. 22. INTERROGATORY NO. 26: Did defendant or any of its subsidiary ;i companies make any design changes as a result of such tests? ANSWER: i;1 . ---- Not applicable. See this defendant's response to interrogatory No. 22. J ' INTERROGATORY NO. 27: If so, please state: ;; . (a) The nature ofthe change made. : (b) The name,address, andjob classification of each person in " charge of making a change. ANSWER: Not applicable. See this defendant's response to interrogatory No. 22. INTERROGATORY NO. 28: After releasing said products to the public, were any tests conducted thereon to determine potential health hazards involved in the use of materials contained therein? ANSWER: HEYL. ROYSTER. VOELKER ft ALLEN *0tSS*0*ML COOAAT*OM JRNEYS AT LAW ST. COW'S STtCT OWAPOSVILLC. ILLINOIS 62025 io>ai e)-44fl Objection. This defendant objects to this interrogatory as not being limited to asbestos, the focus of this litigation. Furthermore, no product can be tested for all "potential health '"wniwoH in t-ho ,,co nf 12 HRV--PL-1179 5E1861 RHS:skb ( materials contained therein",' therefore this interrogatory is overbroad and 'burdensome. |i INTERROGATORY NO. 29: If so, please state: i. | (a) The name, address, and job classification of each person conducting said tests. (b) The results of said tests. ; ANSWER: : Not applicable. See this defendant's response to interrogatory No. 28. ; INTERROGATORY NO. 30: Prior to 1970, did you or your predecessor(s) !i .ever have any labor inspectors or anyone from your company whose job it was ii j; to go to areas where your products were being used or installed to make a 11 . i! . ildust level count? If so, state when this procedure started, the purpose of i| . lisuch procedure, and what action, !i ,! ijings, and attach results. il ' if any, was taken in response to the find- jj ANSWER: ii jj :j Not to this defendant's best current knowledge, information and belief. l| _ INTERROGATORY NO. 31: If your company performed or had performed any :|dust level counts, what action based on the results did your company take? ANSWER: ii Objection. This interrogatory is vague and ambiguous in that it is not .limited to dust levels related to asbestos. Without waiving this objection, ! several surveys were taken at various U. S. Gypsum plants. These involved 11 studies of nuisance dusts, one of which was asbestos. Relevant documents relating to the studies referenced above will be made available for plaintiff's inspection at a mutually convenient time at 101 HCVL. ROYSTER. VOELKER . allen South Wacker Drive, Chicago, Illinois PROrtSS'QNAi CORPORATION TORnCYS AT LAW ST LOU'S STRCCT COWaROSviilC. ILLINOIS 6*025 33'44 60606. 13 HRV-PL-1180 SE1861 RHS:skb ( ( your asbestos products instrubtions concerning safety precautions to 'use in applying such products? If so, describe such instructions, to whom they were ;given, the dates they were given, and the manner of giving such instructions. ! ANSWER: ;i Objection. This interrogatory is overbroad in that it is not limited to asbestos, the focus of this litigation. Therefore, this interrogatory is irrelevant and immaterial and will lead to the discovery of no admissible evidence. Nevertheless, without waiving the above stated objection, all jpackaging contained directions and instructions for use. INTERROGATORY NO. 37: Did your company, or your predecessor(s), ever :place any warning signs on the containers in which asbestos products were : ' ^packaged? . . .. '. : ANSWER: .. See attachedExhibit No. 3. i; INTERROGATORY NO. 38: If you have answered Interrogatory No. 37 in ;! . i:the affirmative, please state: (a) On what date did your company, or your predecessor(s), issue an order directing a warning be placed on your asbestos products, or containers? (b) On what date was such warning actually first placed on your asbestos products or containers? (c) On what date did your asbestos products, accompanied by such warning, first reach the contractor? (d) State the exact wording of the first warning. (e) State the exact size of the warning printed on your asbestos products or container. MCYU ROYSTER. VOELKER a ALLEN VtSSK>**Al COAPOAATtON TTORNCYS at LAW ST LOUIS STBCCT L jviCLC. ILLINOIS 62025 <i ese-ee (f) Did your company, or its predecessor(s) dictate the exact size of the printed warning? (g) Why did your company or its predecessor(s) place such warning on your asbestos products or containers? 16 HRV--PL-1183 5E1861 RHS: skb ( ( (h) Did your company or* its predecessor(s) place such warning dn your asbestos products or containers because you received a directive, command, suggestion, legal opinion, or any type of communication (written or otherwise) from any person, firm, corporation, governmental agency, committee, association, attorney or institute? If so, from whom and on what date did you receive such directive, command, suggestion, legal opinion, or other type of communication. (i) If the wording of the warning has ever been changed or altered, state when it was changed and the exact change in the wording. ANSWER: !' See this defendant's response to interrogatory No. 37. i INTERROGATORY NO. 39: Did your company or its predecessor(s) ever i! ' iiplace any warning directly on any of its asbestos pipe covering, block, !i 11 ijcloth, millboard or other asbestos products? ii ij ANSWER: j. ______ . . . i; See this defendant's response to interrogatory No." 37. jj ;j INTERROGATORY NO. 40: Did your company ever stamp the name of the jj '!company, its initials, or any identifying logo on any of its asbestos pipe ij ;!covering, blocks, cloth, millboard or other asbestos product? ANSWER: Not to this defendant's best current knowledge, information and belief. ; INTERROGATORY NO. 41: Did the warning inquired about in Interroga tories 39 and 40, or similar warning, ever appear in any of your sales liter- mature? If so, attach copies of such sales literature, showing the date such literature was printed. ANSWER: U. S. Gypsum maintains no central repository for the accumulation of the requested information in the ordinary course of business. Documents that HEYL. ROYSTER. VOECKCR ft ALLEN *(*OtCSS*Omai COA<*OAaT*0* have already been identified and gathered to respond to discovery requests in ytornCYS at law a ST lOVHS STftcrr other litigation and that relate to products which plaintiff can establish CL*taOSVJLLE. ILLINOIS 62023 IOiOI S-44 17 HRV-PL-1184 5E1861 RHS:skb ( are relevant to this litigatibn, will be made available for inspection at a mutually convenient time through U. S. Gypsum's offices at 101 South Wacker Drive, Chicago, Illinois, pursuant to a properly filed motion to produce. INTERROGATORY NO. 42: On what date was the sales literature inquired about in Interrogatory No. 41 first provided to distributors or sellers of your company's asbestos products, or your predecessor(s)'s products? ANSWER: See this defendant's response to interrogatory No. 41. ' INTERROGATORY NO. 43: Were any material safety data sheets ever pre- : pared by your company or its predecessor(s)? If so, attach copies. 1 ANSWER: This interrogatory is overbroad in that it is not limited to asbestos- Icontaining products, the focus of this litigation. Therefore, this ; interrogatory is irrelevant and immaterial and will lead to the discovery of no admissible evidence. INTERROGATORY NO. 44: Did your company or its predecessor(s) ever recall any products containing asbestos from the common market? (a) State all details of such recall, giving the name of the product, the time of recall and any further action taken in connection with the recall. ' ANSWER: Not to this defendant's best current knowledge, information and belief. INTERROGATORY NO. 45: Has your company or its predecessors) ever directly advised any contractor to whom you sell your products containing asbestos of threshold limit values for exposure to asbestos dust recommended HCYL. POYSTE*. VOCLKER & ALLEN orcss*OMAi coo*o*tom *>RNEYS AT LAW ST LOUIS STUCCT OWAROSVILLE. ILLINOIS 62023 O'Oi ese-eo by the American Conference of Governmental Industrial Hygienists? If so, state the date or dates that you so advised such contractors, the manner in which you advised such contractor, and the oa<-h rnntractor. 18 HRV-PL-1185 5E1861 iRHS:skb e a ANSWER: Packaging bulletins for products which plaintiff can establish are ! relevant to the subject matter of this litigation will be made available for ijplaintiff' s inspection at a mutually convenient time at 101 South Wacker M<j jiDrive, Chicago, Illinois 60606. li |L INTERROGATORY NO. 58: Has the answering defendant or any of its pre- j|decessor( s) ever mined asbestos? If so, state the dates in which such mining t; Htook place and the locations of the mines. ;j ANSWER: t! !' This defendant never mined asbestos. ii INTERROGATORY NO. 59: List by brand name every product containing j ... , i -- - i; ` I, .. .. jiasbestos which defendant or defendant's predecessor(s) has manufactured since i; 1910. As to each such product, please state the following: i; 'i i; (a) The type of product (e.g., acoustical plaster, fireproofing, || concrete, etc.); jj (b) The date the product first went into production; ij i| <c) The date the product was discontinued from production; * ;i :! . (d) The last date the product was sold; I; i; (e) All manufacturing locations of the product; Ii : (f) The identity of the plant manager(s) or managing agent(s) of defendant who has knowledge of the products manufactured by defendant : and its predecessor(s), and who may be called upon by plaintiffs to testify by deposition. ANSWER: a-e) See attached Exhibit 1. f) Objection. This interrogatory is overbroad, irrelevant and will :yl. roystcr. voelkcr a ALLEN OOTCSSIOMAI CO"*OAaT*Om a' :ys at law *. Ovrs STBCCT AOSVILLC. ILLINOIS 62023 ' lead to the discovery of no admissible evidence. This defendant has employed thousands of employees since its inception and thus it would be impossible to 23 HRV-PL- X 1 9 O 5E1861 RHS:skb C( follows: Prior to 1966, U. S. Gypsum sold its construction products, some of which may have contained small amounts of asbestos, exclusively through inde pendent dealers. Beginning in about 1966, U. S. Gypsum sold its construction products either directly to independent contractors, independent distributors or, as had previously been the custom, through independent dealers. INTERROGATORY NO. 63: Identify your distributors and/or suppliers of raw asbestos, asbestos cement and other asbestos products with which you had ^business contact. ; ANSWER: , This defendant never sold, distributed or manufactured raw asbestos. In 'further response to this interrogatory, see this defendant's response to interrogatory No. 60(d). INTERROGATORY NO. 64: Is this defendant aware or has it possessed knowledge concerning the reported causal connection between exposure to ;asbestos or asbestos products and: (a) Asbestosis? (b) Lung cancer? (c) Mesothelioma? (d) Other cancer? ANSWER: a-c) See attached Exhibit No. 4. ` HRV-PL-1194 . INTERROGATORY NO. 65: If answer to preceding Interrogatory as to any or all of its subparts, is in the affirmative, identify: (a) When and how defendant first learned of such connection; MEYL. ROYSTER. VOCLKER a ALLEN coo^ORATtoN NCYS AT LAW LOUS STCCT JWAOSVLLC. ILLINOIS 62025 <ii e? 44 (b) If knowledge was obtained by attendance at any conference, . lecture, convention, symposium or meeting, identify such meeting and provide the identity of persons attending and documents obtained; (c) If knowledge was obtained from medical or scientific studies. 27 5E1861 RHSiskb <? or any other published work, identify same; (d) If otherwise obtained, identify manner of receipt of document or communication. ANSWER: See attached Exhibit No. 4. INTERROGATORY NO. 66: With regard to any knowledge obtained subse quent to that identified in your answer to Interrogatory 65 (a) above, identify: <1 (a) All documents or communications, oral or written, concerning the ;i casual connection between exposure to asbestos or asbestos products and disease, and identity of persons so communicating; (b) Did answering defendant obtain from or transmit any such information to other defendants in this case? If so, identify: (1) Manner of receipt or communication for each contact; (2) All documents and persons involved. ANSWER: U. S. Gypsum maintains two libraries, neither of which deals specifi- : cally with industrial hygiene, medicine, safety or engineering. Individual employees of this defendant may maintain personal files on specific subjects. Furthermore, this defendant has, in preparation for the defense of these iasbestos-related cases, gather documents and literature regarding asbestos, : including its health effects, which are subject to attorney/client privilege and work product doctrine. If the plaintiff will identify the articles, journals or periodicals in which it is interested, U. S. Gypsum will attempt to ascertain whether or not the publication is in its library. HEYL. ROYSTER. VOELKER S ALLEN ^IIOrr^stOMAL CORPORATION OWAROSVILLC ILLINOIS 62023 Librarians at 101 South Wackgr Drive, Chicago, Illinois 60606: M. Morrissey M. Dorigan N. Nwerdyke Unknown Unknown - 6/30/74 8/20/74 - 5/29/80 28 HRV-PL-1195 ::5E1861 RHS: skb O' (( C. Crabtree P. A. Julien S. Gerrity 1/80 - 11/80 9/80 - 9/84 9/84 - present Research librarian: M. Ehrmann 1961 - present Investigation is continuing. INTERROGATORY NO. 67: As to any knowledge possessed by answering |i jldefendant at any time referred to in your answer to Interrogatory 64, did you ||educate your employees, distributors or purchasers of the hazards known to it ' . (you and the safety precautions necessary to guard against cancer and other ii!: Ijdiseases arising from the use and handling of your products? If so, j; identify: *i ' t ' . ! (a) When arid in what manner customers, insulators, factory workers and ;j the general public were so informed; (b) Documents communicating or otherwise disseminating such ; information; ;! (c) Programs initiated orsponsored to establish or promotesafety procedures, methods or usage of equipment;, ! - (d) Published articles or reports by employees (present or prior), including those ofmedical directors,scientists, engineers or other : professionals; Ij (e) Symposia or lectures sponsored for the benefit of asbestos workers and/or the general public. ANSWER: ' a-e) See attached Exhibit No. 3. INTERROGATORY NO. 68: When and by what manner were your first aware of the hazards relating to exposure to asbestos or asbestos products: (a) For inside insulators and contractors. HCVL. POYSTER. VOCLKCR & ALLEN WKCS5*ONAt CO*OaTi0n ^NCYS AT LAW .T tOUS STCCT OWAOOSVILLE. ILLINOIS 62023 (b) For outside insulators and contractors. ANSWER: HRV-PL-1196 29 5E1861 RHS:skb (< Objection. This interrogatory assumes that there is automatically and always a hazard condition to the occupations specific, which is not necessarily the case. Nevertheless, without waiving said objection, see '.attached Exhibit No. 4. : INTERROGATORY NO. 69: If you have knowledge or information concerning ;the following, answer in the affirmative or negative, whether: " : (a) Early detection of mesothelioma results in any appreciable : rate of cure or arrest; (b) A single exposure to asbestos may cause mesothelioma, other : cancers or asbestosis; ; (c) Cumulative or multiple exposures to asbestos result in a greater ' risk of harm to the exposed person; (d) An outside insulator has a risk of harm from exposure to asbestos I; or asbestos products; j! (e) Stripping or removing old asbestos creates a greater risk of harm |i than insulation of asbestos or asbestos products; (f) Cancer resulting from exposure to asbestos develops generally j after: . (1) 1-5 years : (2) 6-10 years (3) 11-20 years (g) There is any known relationship between smoking and : mesothelioma; (h) There is any reported cause of mesothelioma other than exposure to asbestos. ANSWER: a-b) Objection. This interrogatory calls for a technical and medical conclusion which no employee of this defendant is sufficiently trained to HEYL. ROYSTER. VOCLKER a ALLEN MO'TSS'ONAI COA^OAATIOm RNCYS AT LAW T LOlMS STBCCT OWAROSVJLLC. LL'NCM5 62025 <> 3ft-44 provide. , INTERROGATORY NO. 70: As to each answer to Interrogatory 69, at least one person or document upon which answer-inn rinforHant identify 30 HRV-PL- 1 19 V 5E1861 RHS:skb (( ANSWER: See this defendant's answer to interrogatory No. 69. INTERROGATORY NO. 71: Did you perform, direct to be performed, finance, sponsor or receive the results of any studies or tests concerning ithe relationship between asbestos exposure and asbestosis and/or cancer? If so, identify: (a) When, where and at what intervals such studies were performed; | (b) Were such studies in writing or reported at a later date in v writing; ! (c) Were the results of such studies published or otherwise i: disseminated? If so, state to whom and when; i: . i| (d) Whoperformed such studies; r -` II - 1. ` j| (e) Will you produce the results of such studies at this time or || state where theresults are maintained. |l ANSWER: I: a-e) U. S. Gypsum is aware that it may have contributed to a study :jconducted beginning approximately in 1936 by Dr. Leroy Gardner of the Saranac Laboratory. ` :i ;i ' Relevant documents relating to the studies referenced above will be j' ijmade available for plaintiff's inspection at a mutually convenient time through U. S. Gypsum's offices at 101 South Wacker Drive, Chicago, Illinois. liHowever, documents relating to the above-referenced research projects, con taining as they do confidential and proprietary information, will be made available only pursuant to a court approved confidentiality stipulation and protective order. INTERROGATORY NO. 72: Identify the scientific or medical periodicals <EYl_ ROYSTER. VOELKER o,allen coo^oiuTtON * EYS AT LAW * tous s*cct waAOSVILLC. ILLINOIS 62023 iil to which defendant, its medical department or industrial hygiene division subscribed from 1925 to the present, and the dates of such subscriptions. 31 HR V -- JP-- 119 8 5E1861 RHS:skb (f <f ANSWER: See attached Exhibit No. 8. INTERROGATORY NO. 73: Did defendant, its medical department or industrial hygiene division maintain a medical and/or scientific library at ;any time from 1925 to the present? If so, state: (a) The dates such library existed; (b) The number of volumes maintained therein; (c) The number of employees, part-time or full-time, assigned to ; maintenance of said library, and to whom in the corporate structure \ those employees report(ed). , ANSWER: ' i See this defendant's response to interrogatory No. 66. INTERROGATORY NO. 74: Identify all trade organizations, associations, :or other entities, including but not limited to A.T.I., I.H.F., N.I.M.A., :A.I.A., N.I.C.A., T.I.M.A., Q.A.M.A., P.I.C.A., or Q.A.P.A., to which you have belonged or in which you have participated since 1925, stating the applicable dates of such membership or participation. ANSWER: See attached Exhibit No. 8. INTERROGATORY NO. 75: Identify all persons attending on .your behalf any meetings held by trade organizations, associations, or other entities identified in answer to Interrogatory No. 74. . ANSWER: See attached Exhibit No. 8. INTERROGATORY NO. 76: Identify the names or nature of all notes, HCYL. ROVSTCR. VOCLKCR & ALLEN 'OWAt. COO POAATION tNCYS AT LAW ST. LOUIS STACCT OWAROSVILLC ILLINOIS 2023 <<ai reports, studies, or other writings submitted by you or received by you at meetings held by organizations described in answer to Interrogatory No. 74. ANSWER: 32 HRV-PL-1199 5E1861 RHSrskb t ( See attached Exhibit No. 8. INTERROGATORY NO. 77: Identify any documents received by you from or ;jsubmitted by you to those trade organizations, associations or other entities !i jjidentified in answer to Interrogatory No. 74 relating to the relationship i;between asbestos exposure and disease. ANSWER: i! : See attached Exhibit No. 8. ;i INTERROGATORY NO. 78: Identify all agreements, oral or written, I;between you, any of the other defendants in this lawsuit, and/or any other ! i ^organizations, associations or other entities identified in your answer to lithe Interrogatory No. 74 or any medical or scientific ji j;to the standardization of: ii , |j (a) Specifications for asbestos cloth products; foundations, relating I; (b) Specifications for paper or burlap bags, or other packaging to be j: ' used for the transport and/or storage of asbestos cement; Ii!' . !i (c) Warning or caution labels to be applied to asbestos products I: and/or their packaging, cartons, containers, or boxes; ij . ' * (d) Methods of dissemination of public relations information to " defendant's purchasers, advertisers, distributors, factory workers, contractors, insulators, users, consumers of asbestos products and/or ij the general public; (e) Safety equipment and/or protective clothing to be utilized while handling defendant's asbestos products; (f) Medical programs to be offered or sponsored by defendant. ANSWER: Objection. This interrogatory is overbroad in that it requires this ' defendant to respond for entities other than itself and of which this HEYL. ROYSTER. VOELKER a ALLEN WX' *04A. COaPORATiOM iNCYS AT LAW - ST (.OU'S ST*CCT OWABOSVILLC. ILLINOIS 02025 defendant cannot be fully knowledgeable. As relates to this defendant, to this defendant's best current knowledge, information and belief. none 33 X 2 o O HRV-PL- 5E1G61 RHS:skb (t INTERROGATORY NO. 79: Did you direct to be performed, sponsor, finance, receive the results of or were yu aware of any studies or tests performed by the Saranac Lake Laboratory of the Trudeau Foundation relating ;to asbestos exposure and its effects upon human life? If so, identify: (a) All documents summarizing findings or results of those studies or tests which you have in your possession or control; : (b) All communications, oral or written, between answering defendant and Saranac personnel, including but not limited to Gerrit W.H. j; Schepers, M.D.; ii (c) All documents relating to Saranac studies received or submitted !j by you either directly, through associated or predecessor companies, ij through other companies, or through any trade associations, organiza- jl!i tions or other entities; il ' ;; (d) All recommendations or findings of such studies relating to: Ij (1) Adequacy or inadequacy of threshold limit- values; i! ' Si il (2) Substitution of materials other than asbestos to be used I- in the insulation process. j; !! (e) Where documents and/or communications identified in answers to ;j (a)-(d) of this interrogatory are maintained. ji ANSWER: i! a-e) See this defendant's response to interrogatory No. 71. i| INTERROGATORY NO. 80: How many employees of answering defendant are ;!known by defendant to be suffering from, have suffered from or whose deaths Ii*; ::have been caused by asbestosis? State the date such disease of any employee was first known by defendant. ANSWER: Objection. There has been no allegation that plaintiff was ever an employee of this defendant. Therefore this interrogatory is overbroad, meyl.RorsTtR vocLKEd 6 ALLEN ~or-,w.lCojTo. NCVS AT LAW irrelevant, immaterial and will lead to the discovery of no admissible _ .' evidence. Nevertheless, any documents that this defendant may have that may be responsive to this request will be made "'aii=Wo fnr olaintiff's 34 HRV-pl_1203 5E1861 RHS:skb (( inspection at a mutually convenient time at 101 South Wacker Drive, Chicago, Illinois 60606. INTERROGATORY NO. 81: How many employees of answering defendant are known by defendant to be suffering from, have suffered from or whose deaths have been caused by lung cancer? State the date such disease of any employees was first known by defendant. ANSWER: Objection. Three has been no allegation that plaintiff was ever an employee of this defendant. Therefore this interrogatory is overbroad, irrelevant, immaterial and will lead to the discovery of no admissible i:evidence. Nevertheless, any documents that this defendant may have that may ;!be responsive to this request will be made available for plaintiff's ilinspection at a mutually convenient time at 101 South Wacker Drive, Chicago, Illinois 60606. INTERROGATORY NO. 82: How many employees of answering defendant are ;known by defendant to be suffering from, have suffered from or whose deaths :have been caused by mesothelioma? State the date such disease of any ..employee was first known by defendant. ; ANSWER: ; Objection. There has been no allegation that plaintiff was ever an employee of this defendant. Therefore this interrogatory is overbroad, irrelevant, immaterial and will lead to the discovery of no admissible evidence. Nevertheless, any documents that this defendant may have that may be responsive to this request will be made available for plaintiff's heyl.boyster votLKEB inspection at a mutually convenient time at 101 South Wacker Drive, Chicago, a allcn onorcssoMAL coH>onArioM ^Crs AT LAW COv<S sracrr WA*OSV1LLC. ILLINOIS 62025 Illinois . 60606. 35 HR V -- 1PL. -- 12 0 2 15E1861 :RHS:skb C INTERROGATORY NO. 83: ' Do you send or have you at any time sent counsel or other representatives to courses at defending asbestos cases? If ijso, identify. !; ANSWER: Objection. This interrogatory seeks information protected by iattorney/client privilege and work product doctrine. Furthermore, this ^interrogatory is vague and ambiguous; therefore this defendant is unable to jjform a meaningful response. !j INTERROGATORY NO. 84: Identify all expert witnesses who have testi- !l jified in other cases, pending or otherwise, on behalf of answering defendant. I! ji ANSWER: i; . i! Objection. This interrogatory is overbroad in that it is not limited to |I iiasbestos, the focus of this litigation. ;; INTERROGATORY NO. 85: Identify all present or former employees or ^answering defendant, other than plaintiffs, who. have testified against this ^defendant in a litigation matter or before a governmental agency or unit. E : ANSWER: W < : Objection. This interrogatory is overbroad in that it is not limited to l E asbestos, the focus of this litigation. F INTERROGATORY NO. 86: With respect to your answers to Interrogatories 120 3 No. 84 and 85, identify all documents, including but not limited to tran scripts or notes of testimony employed by or resulting from the testimony of such expert witnesses or employees. ANSWER: MEYL. ROYSTER. VOELKER a ALLEN CO*OH*TiOM (NGYS AT LAW .T LOWS STOCCT OWABOSVILLC. ILLINOIS 202S liai 4SS.L44 See this defendant's response to interrogatory No.'s 84 and 85. . INTERROGATORY NO. 87: Identify: (a) Any expert whom you intend to call as a witness or otherwise 36 5E1861 RHS:skb utilize in connection with this litigation; (b) The subject matter on which the expert is expected to testify; (c) The substance of the facts and opinions to which the expert is expected to testify; (d) A summary of the grounds for each opinion; (e) The address of such person and his field or expertise; (f) Identify and produce each treatise, article or text upon whether the expert will rely in his testimony. ANSWER: ji a-f) Such determination has not yet been made. !j INTERROGATORY NO. 88: Identify and produce all board meeting minutes jiat v/hich asbestos products, the hazards of-asbestos exposure, the possible j| application of warning labels on asbestos containing products were discussed ;| liby the Board of Directors of your company. ij :i ^ ANSWER: il !| Relevant documents, to the extent they exist, will be made available for H R V --P L -- 1 2 0 4 j:this plaintiff's inspection at a mutually convenient time at 101 South Wacker '\ . Drive, Chicago, Illinois 60606. INTERROGATORY NO. 89: Please identify by name, address and phone number each person who has provided this answering party with statements in connection with this litigation. ANSWER: Objection. It is not possible to specifically identify by name each person who has participated in the preparation of these responses or to identify each document which may have provided information used in preparing HEYL. ROYSTER. VOELKER ft ALLEN ** <OMAt COAPOAAT<On NCYS AT LAW ST. LOU'S STSCCT OWAHOSVILLC. ILLINOIS 6202S '! these responses. - INTERROGATORY NO, 90: Please identify each person who has been viewed in the course of preparing for the trial of this matter. inter 37 5E1861 RHS:skb a a ANSWER: Objection. These responses have been prepared based on the continual review of documents located in this defendant's files and information obtained from discussions with this defendant's employees over a period of many years. It is not possible to reconstruct each step taken to gather this information or verify all documents which might possibly pertain to the matters at issue that have been located or examined in connection with these responses. INTERROGATORY NO. 91: Has this Defendant ever sold any asbestos con taining products to Insulation and Material Company of St. Louis, Missouri or `i I'any other individual, corporation, partnership or other business entities ;within a 100 mile radius of Madison County, Illinois since 1920 including but ilnot limited to St. Louis County, St. Louis City, St. Charles County, Missouri jior Madison County or St. Clair County, Illinois, if so state: iN! . : (a) List all individuals, corporations, partnerships or other ' business entities you have sold asbestos containing products to; . -(b) State all dates when asbestos containing products were sold S3 to these entities; S3 < (c) State what asbestos containing products were sold to these entities I and identify by brand name; S3 (d) State what quantity of asbestos products were sold to these r entities; i k (e) Provide copies of all purchase orders, specifications, contracts N or correspondence with the entities identified in (a) above or otherwise 0 identify all documents relating to the sale. 01 ANSWER: This defendant has no sales records for the years prior to 1966. Sales EYL. ROYSTER. VOCLKCR a ALLEN `ocr- '*ALCOi>OflATioi A ITS AT law If- LOWS STBCCT 'AOSVILLC. ILLINOIS 62023 <e>6> 3-446 records thereafter are contained in computer printouts. Records of products which the plaintiff can establish were relevant to the subject matter of this lawsuit will be made available for inspection at a mutually convenient time 5E1861 RHS:skb ( (( at 101 South Wacker Drive, Chicago, IL 60606, pursuant to a properly filed motion to produce. INTERROGATORY NO. 92: Have you ever sold any asbestos containing ^products to: : Monsanto, East St. Louis, Illinois Marathon Oil Refinery, Robinson, Illinois . Shell Oil Company Refinery, Roxana, Illinois ; Amoco Refinery, Wood River, Illinois Clark Oil Company Refinery, Hartford, Illinois : Granite City Steel, Granite City, Illinois Illinois Power Company (Alton Powerhouse) Central Illinois Power Service (Coffeen Powerhouse) : Commonwealth Edison (Kinkaid Powerhouse) Illinois Power Company (Portage Des Sioux Powerhouse) r Central Illinois Power Service (Meredosia Powerhouse) Illinois Power Company (Grant Ford Powerhouse) Owens-Illinois Glass Co., Alton, Illinois Central Illinois Power. Service (Baldwin Powerhouse) :: Central Illinois Power Service (Pearle Powerhouse) J Central Illinois Power Service (Marion Powerhouse) Central Illinois Power Service (Newton Powerhouse) Texaco Oil Company Refinery, Lawrenceville, Illinois | American Steel, Granite City, Illinois j; Cerro Copper, Granite City, Illinois Consolidated Aluminum Company, Granite City, Illinois Olin Corporation, East Alton, Illinois . Laclede Steel Company, Alton, Illinois : ' Sinclair Oil Refinery, Hartford, Illinois Apex Oil Refinery, Hartford, Illinois ' - ::and if so: (a) List all individuals, corporations, partnerships, or other business entities you have sold asbestos containing products to. (b) State all dates when asbestos containing products were sold to these entities. (c) State what asbestos containing products were sold to these entities and identify by brand name. (d) State what quantity of asbestos containing products were sold to these entities. HCYL. ROYSTER. VOELKER ft ALLEN C0<**0***TOn 1NEVS AT LAW j'. LOUIS STBCCT CJWAROSVILLC. ILLINOIS 62023 (e) Provide copies of all purchase orders, specifications, contracts or correspondence with the entities identified in (a) above or otherwise identify all documents relating to the sale. ANSWER: 39 HRV-PL-1206 5E1861 RHS:skb C- (( This defendant has n sales records for the years prior to 1966. Saies records thereafter are contained in computer printouts. Records of products which the plaintiff can establish were relevant to the subject matter of this lawsuit will be made available for inspection at a mutually convenient time at 101 South Wacker Drive, Chicago, IL 60606, pursuant to a properly filed motion to produce. INTERROGATORY NO. 93: Has this Defendant ever been a General Contractor or Subcontractor where it used asbestos containing products at any of the following locations: i Monsanto, East St. Louis, Illinois Marathon Oil Refinery, Robinson, Illinois : Shell Oil Company Refinery, Roxana, Illinois !. Amoco Refinery, Wood River, Illinois . Clark Oil Company Refinery, Hartford, Illinois Granite City Steel, Granite City, Illinois Illinois Power Company (Alton Powerhouse) | Central Illinois Power Service (Coffeen Powerhouse) Commonwealth Edison (Kinkaid Powerhouse) Illinois Power Company (Portage Des Sioux Powerhouse) Central Illinois Power Service (Meredosia Powerhouse) Illinois Power Company (Grant Ford Powerhouse) Owens-Illinois Glass Co., Alton, Illinois - Central Illinois Power Service (Baldwin Powerhouse) Central Illinois Power Service (Pearle Powerhouse) ' Central Illinois Power Service (Marion Powerhouse) Central Illinois Power Service (Newton Powerhouse) : Texaco Oil Company Refinery, Lawrenceville, Illinois American Steel, Granite City, Illinois : Cerro Copper, Granite City, Illinois : Consolidated Aluminum Company, Granite City, Illinois Olin Corporation, East Alton, Illinois Laclede Steel Company, Alton, Illinois : Sinclair Oil Refinery, Hartford, Illinois . Apex Oil Refinery, Hartford, Illinois and if so: HCYU. ROYSTER. VOELKER 6 ALLEN PP" SIONAL COft^OftATtOM RNEYS AT LAW .. - sr LOU'S STftCCT DWAROSVILLE. ILLINOIS 62025 <6'OI 036-4640 (a) List all individuals, corporations, partnerships, or other business entities you have sold asbestos containing products to. (b) State all dates when asbestos containing products were sold tc these entities. (c) State what asbestos containing products were sold to these 40 H R V -P L --12 O 7 I.5E1861 JJrhS : skb (( (( entities and identify by brand name. . (d) State what quantity of asbestos containing products were sold to these entities. . (e) Provide copies of all purchase orders, specifications, contracts or correspondence with the entities identified in (a) above or otherwise ; identify all documents relating to the sale. ;; ANSWER: :: Not to this defendant's best current knowledge, information and belief. j: INTERROGATORY NO. 94: Did this defendant ever provide any warning !i jlconcerning the hazards of asbestos to any of the following companies: . iIi: || Monsanto, East St. Louis, Illinois || Marathon Oil Refinery, Robinson, Illinois ji Shell Oil Company Refinery, Roxana, Illinois ;i Amoco Refinery, Wood River, Illinois ;i Clark Oil Company Refinery, Hartford, Illinois Granite City Steel, Granite City, Illinois !' Illinois Power Company (Alton Powerhouse) I; Central Illinois Power Service (Coffeen Powerhouse) Commonwealth Edison (Kinkaid Powerhouse) ; Illinois Power Company (Portage Des Sioux Powerhouse) Central Illinois Power Service (Meredosia Powerhouse) Illinois Power Company (Grant Ford Powerhouse) : Owens-Illinois Glass Co., Alton, Illinois Central Illinois Power Service (Baldwin Powerhouse) ; Central Illinois Power Service (Pearle Powerhouse) Central Illinois Power Service (Marion Powerhouse) - Central Illinois Power Service (Newton Powerhouse) ; Texaco Oil Company Refinery, Lawrenceville, Illinois , American Steel, Granite City, Illinois Cerro Copper, Granite City, Illinois Consolidated Aluminum Company, Granite City, Illinois Olin Corporation, East Alton, Illinois Laclede Steel Company, Alton, Illinois Sinclair Oil Refinery, Hartford, Illinois ! Apex Oil Refinery, Hartford, Illinois - ' If so, identify what the warning was, how the warning was delivered and when the warning was delivered. Provide copy of warning and correspondence con cerning the warning. MCYU ROYSTER. VOELKCR a Allen POOrtSS'OHAL COflPOAATtOM 1NEYS AT LAW LOUIS STHCCT OWAROSVILLC. ILLINOIS 62023 ANSWER" - . HRV -- PL- 1 2 O 8 41 5E1861 RHS:skb (( Some or all of the listed companies may have seen this defendant's packages containing warnings as specified in Exhibit No. 3. Otherwise, not to this defendant's best current knowledge, information and belief. INTERROGATORY NO. 95: Has this Defendant ever had any correspondence with any of the following companies or facilities concerning products con taining asbestos: Monsanto, East St. Louis, Illinois Marathon Oil Refinery, Robinson, Illinois Shell Oil Company Refinery, Roxana, Illinois Amoco Refinery, Wood River, Illinois Clark Oil Company Refinery, Hartford, Illinois Granite City Steel, Granite City, Illinois Illinois Power Company (Alton Powerhouse) Central Illinois Power Service (Coffeen Powerhouse) Commonwealth Edison (Kinkaid Powerhouse) Illinois Power Company (Portage Des Sioux Powerhouse) Central Illinois Power Service (Meredosia Powerhouse) Illinois Power Company (Grant Ford Powerhouse) Owens-Illinois Glass Co., Alton, Illinois Central Illinois Power Service (Baldwin Powerhouse) Central Illinois Power Service (Pearle Powerhouse) Central Illinois Power Service (Marion Powerhouse) Central Illinois Power Service (Newton Powerhouse) Texaco Oil Company Refinery, Lawrenceville, Illinois American Steel, Granite City, Illinois .Cerro Copper, Granite City, Illinois Consolidated Aluminum Company, Granite City, Illinois . Olin Corporation, East Alton, Illinois Laclede Steel Company, Alton, Illinois Sinclair Oil Refinery, Hartford, Illinois Apex Oil Refinery, Hartford, Illinois ' * If so, provide copy of any correspondence with any of the above-companies concerning asbestos containing products. ANSWER: None, to this defendant's best current knowledge, information and belief. EYL. ROYSTCR. VOCLKCR a ALLEN COo^OMltON * evs AT LA<H COW'S STBCCT VAROSVILLC. ILLINOIS l'0l UNITED STATES GYPSUM COMPANY, Defendant By:__________:_____________________________________ "L, ROYSTER, VOELKER & ALLEN HRV-PL--1209 42 5E1861 RHS:skb ( (? Barry S. Noeltner ARD #06190817 Attorneys for Defendant ! I HCYL. ROYSTER. VOELKER a ALLEN W'*'iONAt CO**0*TiOw INCYS AT LAW .T LOU'S STCCT OWAPOSVILLC ILLINOIS 6202S i6>ai 12 10 43 Product Name Sabinite ( Product Tvoe/Use Acoustical Plaster Audi cote Hi-Lite Red Top Trowel Finish Acoustical Plaster Acoustical Plaster Finish Plaster Oriental Interior Finish Plaster Finish Plaster Red Top Cover Coat Finish Plaster Red Top Patching Plaster Finish Plaster ( (Dates Approximately) First Last Produced Produced 1930 1930 1930 1930 1930 *1964 1945 1945 *1964 1945 1955 1972 1955 1972 1930 1930 1950 1942 1942 1942 1942 1942 1949 1949 1942 1935 1935 1951 1972 1972 1972 1972 1944 ` 1950 1972 1954 Manufacturing Locations Fort Dodge, IA Midland, CA East Chicago, IN New Brighton, NY Gypsum, OH New Brighton, NY ' Fort Dodge, IA New Brighton, NY Fort Dodge, IA Gypsum, OH East Chicago, IN Fort Dodge, IA New Brighton, NY Fort Dodge, IA Oakfield, NY Fort Dodge, IA New Brighton, NY Sweetwater, TX Boston, MA Gypsum, OH Philadelphia, PA Jacksonville, FL Norfolk, VA Philadelphia, PA Southard, OX 1929 1942 1942 1944 1947 1946 1951 1947 Gypsum, OH New Brighton, NY Nephi, UT Milwaukee, WI South Cate, CA Page 1 of 7 HRV-PL-1212 ( Product Name Product Tvpe/Use Red Top Wood Fiber Plaster - Regular Basecoat Red Top Wood Fiber Plaster - Machine Application Basecoat Cement Plaster Basecoat Regular. Name changed to Gypsum Plaster 7/67; to Red Top Gypsum Plaster 11/68 Red Top Cement Basecoat Plaster for Machine Application.- Name changed to Red Top Gypsum Plaster for Machine Application 7/67 Red Top Structo-Lite Gypsum Plaster for Hachine Application Basecoat ( (Dates Approximately) First Last Produced Produced 1945 1945 1945 1945 1945 1945 1945 1945 1945 1948 1948 1952 1972 1952 1959 1963 1963 1965 1966 1967 1960 1952 1972 1960 1959 1972 1961 1972 Manufacturing Locations East Chicago, IN Heath, MT Nephi, UT Midland, CA Fort Dodge, IA Detroit, HI Sweetwater, TX Loveland, CO Southard, OK Plaster City, CA Gerlach, NV Sigurd, UT Empire, NV Plaster City, CA East Chicago, IN 1943 1947 Loveland, CO 1962 1962 1964 1966 1966 1966 Gypsum, OH Detroit, MI Oakficld, N 1955 1962 Boston, MA Detroit, MI East Chicago, IN Fort Dodge, IA Gypsum, OH Jacksonville, FL Loveland, CO New Beighton, NY Norfolk, VA Oakficld, NY Philadelphia, PA Plastcrco, 7A Page 2 of 7 HRV -- X>L- X 2 X 3 Product Name Product Type/Use Red Top Structo-Lite Gypsum Plaster for Machine Application (cont.) Oriental Exterior Finish Stucco Exterior Finish Stucco Pyrobar Mortar Mix Aggregated plaster Sheetrock Radiant Heat Filler Machine Application Specialty plaster Bondcrete Basecoat ( (Dates Approximately) First Last Produced Produced 1955 1957 1958 1963 1971 1930 1930 1930 1930 1932 1932 1949 194.9 1969 1969 1971 1959 1962 1962 1972 1972 1973 1944 1972 1972 1944 1946 1972 1972 1970 1972 1972 Manufacturing Locations Southard, OK Sweetwater, TX Milwaukee, WI Shoals, IN Plaster City, CA Fort Dodge, IA Detroit, MI Fort Dodge, IA Gypsum, OH New Brighton, MY Oakfield, NY Sweetwater, TX Boston, MA Philadelphia, PA Milwaukee, WI Jacksonville, FL Philadelphia, PA Norfolk. VA East Chicago, IN New Brighton, )(Y Empire, MV 1940 1943 Midland, CA Page 3 of 7 HKv -- pl Product Name Product Type/Use SPRAYDON STANDARD A SPRAYDON STANDARD G Fireproofing Fireproofing ( (Dates Approximately) First Last Produced Produced 1966 1971 1968 1970 Manuf acturing Locations S. Plainfield, NJ Torrance, CA S. Plainfield, NJ Torrance, CA SPRAYDON P0WERC0XEO Thermal Insulation 1969 1971 Corsicana, TX SprayDon - U. S. Gypsum manufactured this product pursuant to the specification of Sprayon Research Corporation. FIRECODE V Fireproofing Plaster 1964 1968 East Chicago, IN ' New Brighton, NY Empire, NV FIRECODE D Fireproofing Plaster ****ACOUSTONE 120 Ceiling Tile 1959 1967 1964 1975 New Brighton, NY East Chicago, IN Empire, NV Cypsum, OH Walworth, WI ACOUSTONE 130 Ceiling Tile 1966 1976 Walworth, WI Gypsum, CH USG Texture 19'64 1976 Gypsum, OH Sweetwater, 71 Dallas, TX Chamblcc, CA Midwa y, IL South Gate, CA Texolite . Texture 1961 1967 Cypsum, OH Dallas , TX New Brighton, NY South Gate, CA Page 4 of 7 HBV-PL- 1 2 1 5 Product Name Pac-Xex Imperial QT ( Product Tvpe/Use Texture Texture "SHEETROCK" Texture Texture Textone Texture USG Textone Texture Paint USG A-B TEX Texture Paint Texture Paint ( (Dates Approximately) First Last Produced Produced 1943 1963 1964 1976 1964 1976 Manufacturing Locations South Gate, CA Dallas, TX Sweetwater, TX South Gate, CA Dallas, TX Gypsum, OH Midway, IL New Brighton, NY Chamblee, GA Gypsum, OH Dallas, TX Hidway, IL South Gate, CA 1944 1975 1928 1974 1954 1967 1964 1976 1935 1959 only 1973 only 1949 Gypsum, OH Sweetwater, TX South Gate, CA Dallas, TX New Brighton, NY South Gate, CA Gypsum, CH Chamblee, GA New Brighton. NY Sweetwater, TX Chamblee, GA Sweetwater, TX Gypsum, CH Gypsum, OH Hew Brighten, NY Sweetwater, TX Midway, IL Chamblee, CA South Cato, CA Page 5 of 7 HRV- X2a6 Product Name Product Tvpc/Use Other Products (By generic group) Paste Spackling Putty Pipecoverings Joint Compounds Rigid Block Insulation Siding Shingles Roofing ( (Dates Approximately) First Last Produced Produced Manufacturing Locations 1952 1975 1936 1920's? 1938 1976 1943 1970 193 7 - 1950 1971 1975 - 1937 1946 1967 1975 Possible other dates. New Brighton, NY Gypsum, OH Chamblee, GA Sweetwater, TX Jersey City, NJ Gypsum, OH Midway, IL Chamblee, CA Dallas, TX East Chicago, Jacksonville, IN FL East Chicago, IN Greenville, MS East Chicago, IN Jersey City, MJ St. Paul, YJ! South Gate, CA Thermalux Electric Heating 1961 1965 Shoals, IN (Assembled) Asbestos Cement Insulation purposes where sheet and block insulation would be impractical. 1936 1939 Jersey City, NJ NOTE: Mot all products were made at all plants at all times listed. * May have been produced until this date, but sales diminished substantially by the mid-1950's. Page 6 of 7 HRV -- 3?L -- 12 1V *** Some of those products (Red Top Trowel Finish; Oriental Interior Finish Plaster; Red Top Cover Coat Finish Plaster; Red Top Patching Plaster; Red Top Wood Fiber Plaster Regular Basecoat; Red Top Wood Fiber Plaster Machine Application Basccoat; "Cement Plaster - Regular, Name changed to Gypsum Plaster 7/67, to Red Top Gypsum Plaster Basecoat 11/68; Red Top Cement Plaster for Machine Application - Name " changed to Red Top Gypsum Basecoat for Machine Application; Red Top Structo-Lite Gypsum Plaster for Machine Application Basecoat; Oriental Exterior Finish Stucco; Pyrobar Mortar Mix; Sheetrock. Radiant Heat Filler - Machine Application) did not have asbestos as part of their formulation at all manufacturing locations at all times. **** Some of these products did not have asbestos as part of their formulation. Most of the products identified in this Exhibit have a shelf life of approximately six months, with some variation due to humidity and storage conditions. It is the policy of the defendant to provide this information to all customers. Therefore, date of last production approximates date of last sale, though U. S. Gypsum is not certain whether shelf life guidelines were adhered to by its customers. Reasonable investigation continuing. Page 7 of 7 HRV --PL.- 12 18 Exhibit 2 ( U. S. Gypsum does not maintain examples of actual packaging in the normal course of business. All packaging contained the product name, this defendant's name, directions and instructions for use. To this defendant's best knowledge, information and belief, the product packaging for its asbestos-containing products was as follows: Acoustical Plaster Kraft Paper Bags Miscellaneous Plasters Kraft Paper Bags Stucco Kraft Paper Bags Fireproofing Plaster Kraft Paper Bags Joint Compound Kraft Paper Bags, metal and plastic buckets and cardboard cartons Spray Textures Kraft Paper Bags, metal and plastic buckets and cardboard cartons Block Insulation Cardboard Cartons Pipecovering Cardboard Cartons Spackling Paste Metal and plastic cans buckets and pails Ceiling Tile Cardboard Cartons Asbestos Cement Burlap bags, cardboard cartons Available packaging bulletins dealing with products which plaintiff can establish were relevant to this lawsuit will be made available to the plaintiff for inspection at a mutually convenient time at 101 South Wacker Drive. Chicago. IL 60606. HRV-PL-1219 L-XiilUx i_ J ( The following appeared on joint compound packaging, consistent with proposed OSHA standards, in 1972 and on textures in 1973: "Caution: Contains Asbestos Fibers. Avoid Creating Dust. Breathing Asbestos Dust May Cause Serious Bodily Harm." Additionally, the following was imprinted on joint compound packaging in approximately 1974: "Observe the following precautions: Wet sanding or sponging finished joints is recommended rather than dry sanding to avoid creating dust. If dry sanding, mixing, or otherwise working in a dusty atmosphere containing this material, ventilate, use dust collector, or wear eye protection and a respirator approved by the Bureau of Mines, or NIOSH. to remove nuisance dust." Concerning SprayDon. a product sold and distributed by Sprayon Research Corporation, manufactured by U. S. Gypsum according to that company's specifications, the following appeared on SprayDon bags in approximately June. 1966. "Contains Asbestos" The following appeared on SprayDon in subsequent years. "Caution: This product contains asbestos (1968) "Caution: This product contains asbestos, which may be harmful to lungs if inhaled." (1969) hrv-pl_ 12 2 0 LAllxOl O (( ASBESTOS CONTAINING PRODUCTS Acoustical Plasters - grayish-white; Miscellaneous Specialty Plasters - white to off-white plus some pastels for two products; Fireproofing - grayish-white; Fireproofing Plasters - white to off-white; Ceiling Tile - white to off-white Texture Products - white to off-white; Paste Spackling Putty, Pipecoverings, Joint Compounds, Rigid Block Insulation, Mortar - white to off-white; Siding - white, gray, ivory, green, brown; Roofing - red, green, blue, brown, black and gray HRV -- PL-- 12 3 1 :( Asbestos-Containing Products - Reasons for Discontinuation: I. Sabinite was replaced by Audicote and Hi-Lite in the marketplace. Audicote and Hi-Lite were discontinued because the low profitability of these products did not justify the expense of research efforts to reformulate without asbestos. II. Cost of Compliance with proposed lower OSHA standards within the plant. III. At the direction of Sprayon Research Corporation. IV. The low profitability of these products did not justify the expense of research efforts to reformulate without asbestos. V. Low Profitability. Product Categories Acoustical Plasters Plasters Fireproofing Plasters Fireproofing Thermal Insulation Ceiling Tile Textures Roofing Joint Compounds Pipe Covering Asbestos Cement Rigid Block Insulation Block Insulation Cement Siding Paste Spackling Putty Reason for Discontinuation Last Date of Manufacture I II V III III II II II II V V V IV II & IV II 1974 1972 1970 1972 1971 1976 1976 1976 1976 1938 1939 1950 1971 1975 ' 1975 * Includes production by subsidiary. ** U. S. Gypsum Company manufactured this product pursuant to the specifications of Sprayon Research Corporation. HRV-PL--1232 1 The following represents this defendant's best current information: Exhibit 8 DATES OF ORGANIZATION MEMBERSHIP Gypsum Association 1930-present . HEALTH HAZARDS OF ASBESTOS DISCUSSED AT MEETINGS ATTENDED BY UNITED STATES GYPSUM COMPANY PERSONNEL DOCUMENTS AVA UNITED STATES G COMPANY Asbestos discussed at all of the following: Membership meetings: 10/27/71 - 10/28/71 E. W. Duffy. W. W. Holloway. A. J. Watt 4/5/72 - J. H. Crumbaugh, A. R. Rump, C. G. Gramor, A. J. Watt. M. L. Hepsher, W. W. Holloway 4/4/73 - J. S. Bush. W. W. Holloway, A. J. Watt. C. G. Gramor. J. D. May, J. J. McLaughlin Minutes of meeting: these documents ar< in this defendant's f produced to this def in litigation by Gyps Association. This defendant does : know if such individu actually attended me listed in documents p to this defendant by ( Association in other litigation. Also, some test result are in this defendant's files. 10/10/73 - 10/12/73 W. W. Holloway, A. J. Watt Safety Committee Mcetincs: 9/20/66 - P. D. Fix, G. R. Krug 9/17/67 - C. P. Kipp 3/19/68 - 3/20/68 - G. R. Krug 10/2S/71 - W. E. Halley, J. D. Cornell, J. M. Rochcrs 9/19/73 - J. D. Cornell 3/7/74 - J. D. Cornell, M. R. Helton 8/14/74 - J. D. Cornell Manutacturing & Mining Committee: 4/3/73 - W. W. Holloway, H. D. Gobrccht HRV-PL-12 3 3 Page 1 of 6 ( DATES OF ORGANIZATION MEMBERSHIP Gypsum -Association (cont.) Industrial Health Foundation (But not Industrial Hygiene Foundation) 1974-19S1 (budget cut backs forced United States Gypsum Company to drop membership) HEALTH HAZARDS OF ASBESTOS DISCUSSED AT MEETINGS ATTENDED BY UNITED STATES GYPSUM COMPANY PERSONNEL DOCUMENTS AVA UNITED STATES G COMPANY Manufacturing & Mining Committee: 4/9/74 _ w. W. Holloway 10/8/74 - W. W. Holloway. H. D. Gobrecht 8/10/76 - J. D. Cornell. K. E. Mohler, W. Lewis Technical Committee: 2/14/73 - 12/16/73 J. H. Crumbaugh 8/1/73 - 8/3/73 J. H. Crumbaugh. A. L. Hampton. R. L. Selbe 11/73 and 1/74 - unknown 2/13/74 - 2/15/74 J. H. Crumbaugh 8/7/74 - 8/9/74 J. H. Crumbaugh. R. L. Sclbc Board of Directors: 4/5/73. 10/12/73 A. J. Watt No business meetings Some "discussionals" Industrial Hvalene D Monthly Abstracts 1/74 - 12/81 (JDC's) Asbestos was discussed at the following meetings: Annual Business Re (JDC's) Introduction to Industrial Hygiene Asbestos Sampling Chemicals for Industrial Hygiene C. Roc 197S-1979 Toxicology Chemicals and Engineering S. H. Berning - 1/10/79 - 1/21/79 X 2 34 HBV-PL' 'age 2 of 6 ( DATES OF ORGANIZATION MEMBERSHIP Lime Association `National Insulation Manufacturers Association (Founded in I9S8) (Now TIMA) Thermal Insulation Manufacturers Association exact date unknown 1973-1974 1974-present National Insulation Contractors Association (AssociateMember) National Safety Council unknown (perhaps 1972-present?) 1914-present National Mineral Wool Association 19437-1957 mid-1960's mid-1970's ( HEALTH HAZARDS OF ASBESTOS DISCUSSED AT MEETINGS ATTENDED BY UNITED STATES GYPSUM COMPANY PERSONNEL DOCUMENTS AVAIL/ UNITED STATES GYP COMPANY Industrial Hygiene Techniques Update, Advanced Industrial Hygiene S. H. Beming - 11/12/79 - 11/14/79 Seminar Regarding Industrial Health J. D. Cornell - 6/8/75 - 6/9/7S Other personnel involved: J. D. Cornell, S. H. Beming, K. S. Freeman. C. Roe unknown none unknown none none Minutes produced in ot litigation (Wm. Simpsoi deposition) (1958-?) Some mass corresponde letters regarding comm J. D. Cornell was on health and safety, publi information, medical ar scientific dated 1978 to present. . NIC A by Laws dated 19! NTCA's 1981 Annual Rep none none Transactions from 1912-1 records of all presentati and papers produced at Phillip E. Schmidt, depo and document productio April 17. 1984. in Neil \V< none X235 Page 3 of 6 ( DATES OF ORGANIZATION MEMBERSHIP ".Contracting Plaster and Lathers International (Associate Member) 1960-1969 International Association Wall and Ceiling Contractors (Associate Member) 1970-1976 "Gypsum Drywall Contractors International (Associate Member) 1960-1976 unknown Association of Wall and Ceiling Contractors Industries . International Gypsum Drywall Contractors International (Associate Member) 1976-1979 Association of Wall and Ceiling Contractors Industries International 1980-present American Society of Safety Engineers exact dates unknown American Industrial Hygienists Association exact dates unknown ( HEALTH HAZARDS OF ASBESTOS DISCUSSED AT MEETINGS ATTENDED BY UNITED STATES GYPSUM COMPANY PERSONNEL none none none none none unknown unknown DOCUMENTS AVAIl UNITED STATES G'l COMPANY Some documents in Cook's and J. Edwari Some documents rn-N Cook's and J. Edward Some documents in M Cook's and J. Edward: Some documents in M. Cook's and J. Edwards none none *2 3 ^ Page of 6 DATES OF ORGANIZATION MEMBERSHIP Employing Plasterers Association {Associate Member) present Metal Lath Association I950's-1964 Pulp and Paper Institute 19S0's-I964 Hardboard Association I950's-1964 Health and Safety Council of Asbestos Cement Products Association 19677-1971? Asbestos Information Association of North America Unknown if a member. National Bureau . of Standards not a member not a member American Standards Association (never a member; served on committees) became ANSI 1969 similar to ASTM {sustaining member) unknown; involvement at least 15 years ago ( HEALTH HAZARDS OF ASBESTOS DISCUSSED AT MEETINGS ATTENDED BY UNITED STATES GYPSUM COMPANY PERSONNEL unknown unknown unknown unknown G. R. Krug - 11/19/68 C. P. Kipp (deceased) or L. A. Tobey (deceased) 2/17/70; 2/18/70; 3/19/70; S/19/70; 11/19/70 . none . 197S - J. D. Cornell. K. S. Freeman (retired) Rockville. MD. jointly sponsored by NBS and NIOSH re: Asbestos and Health unknown DOCUMENTS AVAILAI UNITED STATES GYPS COMPANY none none none none November 21. 1968 mem Krug to Kipp re: meetii and various minutes frot other meetings. none none HRV -- P L.-- 1 23*7 Page 5 of 6 DATES OF ORGANIZATION MEMBERSHIP Asbestos Textile Institute never a member SOEH/IOEH never a member HEALTH HAZARDS OF ASBESTOS DISCUSSED AT MEETINGS ATTENDED BY UNITED STATES GYPSUM COMPANY PERSONNEL none "Occupational Exposures to Fibrous and Particulate Dust and Their Extentions into the Environment" 12/5/77 - 12/7/77 J. D. Cornell (others?) DOCUMENTS A VAIL A1 UNITED STATES GYPS COMPANY none Membership information pertaining to these organizations is not available in this defendant's files. United States Gypsum Company does not and has not belonged to: Quebec Asbestos Mining Association - QAMA Asbestos Research Council of England Public Health Bulletin Service Plastering and Lath Association Chicago Plastering Institute Perlite Institute HRV -- PL-- 12 3 8 Page 6 of 6