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
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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
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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.
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