Document zdx7Q4npDEvEEagmxqN6wxRV0

CAUSE NO. B-126,986 PLAINTIFF'S EXHIBIT.. API-42 RUSSELL ALLEN, ET AL. VS. AMERICANPETROFINA, INC., ET AL. IN THE DISTRICT COURT OF JEFFERSON COUNTY, TEXAS 60TH JUDICIAL DISTRICT DEFENDANT'S RESPONSE TO REQUEST FOR PRODUCTION TO: Russell H. Allen, et ux, et al by and through their attorneys of record, Joseph C. Blanks, Reaud, Morgan & Quinn, 909 Laurel Street, Beaumont, Texas 77701 and Herschel L. Hobson, 2190 Harrison, Beaumont, Texas 77701. COMES NOW, Defendant, American Petroleum Institute, and pursuant to Rule 167, Texas Rules of Civil Procedure, files these its Responses to Request for Production filed by Plaintiffs. Respectfully submitted. STUBBEMAN, McRAE, SEALY, LAUGHLIN & BROWDER, INC. By State Bar #17876000 Reginald H. Wood State Bar #21905500 700 Louisiana, Suite 2400 Houston, TX 77002 (713) 237-1100 (713) 222-2842 (telecopier) ATTORNEYS FOR AMERICAN PETROLEUM INSTITUTE 012068 L JL SC-API-6305 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing Defendant's Response to Request for Production was forwarded by certified mail, return receipt requested or by overnight mail Joseph P. Blanks, Reaud, Morgan & Quinn, 909 Laurel Street, Beaumont, Texas 77701 and Herschel L. Hobson, 2190 Harrison, Beaumont,- Texas 77701 and to all other counsel of record by regular mail on this "3 / day of AhJq 7--` , 1990. 2787L/75--77 012063 2- - RESPONSE TO REQUEST FOR PRODUCTION Request for Production No. 1: Please produce a copy of your document retention policies this Defendant has used since it began such a policy, but not before 1945. This request seeks # sufficient information to determine when a document retention ' policy began (or if one existed in 1945) what each policy was and each change and when each change became effective. Response: Please see attached copy of six-page document dated August 23, 1976 and entitled Policy Number: 804 as well as an eight page document dated August 15, 1983 and designated as API Policy Number: 804. The foregoing documents comprise all of the documents responsive to this request. 012070 3- -