Document zoMKGaVeyrEOdK2xmLw8ZOZ53

JSje *7 D 1 Robert D. Bjork, Jr. Dorine R. Kohn 2 BJORK, FLEER & LAWRENCE 483 Ninth Street 3 Oakland, California 94607 Telephone: (415) 832-8134 4 Attorneys for Defendant 5 The Rockbestos Company 6 7 -- Pg*____ BRAYTON 4 AJ MAY 2 8 391 RBcer.c. To File_____________ CUSS.!:: MVS: WC/DEF 7030 fofiteL/ MlIC j : : 5 I '\ | | 6 SUPERIOR COURT OF CALIFORNIA - COUNTY OF SOLANO 9 10 In Re: No. 2830 11 COMPLEX ASBESTOS LITIGATION 12 TBE ROCKBESTOS COMPANY'S RESPONSES TO GENERAL ORDER NO. 30.00 INTERROGATORIES 13 / 14 15 The Rockbestos Company ("Rockbestos"), responds to 16 plaintiffs' standard interrogatories pursuant to General Order 17 No. 30.00 as follows: 18 19 20 21 PRELIMINARY STATEMENT AND GENERAL OBJECTIONS 22 23 Rockbestos objects to the interrogatories on the 24 grounds that they exceed the permissible scope of discovery as 25 defined by CCP 2017, and seek information which is neither 26 relevant to the subject matter of this action nor reasonably 27 calculated to lead to the discovery of admissible evidence. 28 1 at the hearing on the motion for the order consolidating 2 discovery and has had no opportunity to be heard with regard to 3 that order or to the form of discovery propounded, Rockbestos 4 further objects on the ground that it has never stipulated to 5 adoption of these interrogatories by the Solano County Superior 6 Court. As such Rockbestos asserts that any obligation to respond 7 to plaintiff's standard interrogatories is unenforceable under 6 the Code of Civil Procedure and is a denial of due process of 9 law. Thus, to the extent the interrogatories do not comply with 10 the Civil Discovery Act of 1986, C.C.P. Section 2016 et sea.. 11 which sets forth the California legislature's governing 12 provisions pertaining to interrogatories, Rockbestos objects. 13 14 More specifically, Rockbestos objects to the 15 interrogatories in that the interrogatories and their subparts 16 exceed the Statutory number permitted by CCP 2030(c). In 17 addition, Rockbestos objects to the interrogatories to the extent 18 that many of the interrogatories are not complete in and of 19 themselves, or contain subparts, are compound, conjunctive or 20 disjunctive in violation of CCP 2030(c)(5). Moreover, the 21 interrogatories contain instructions and "definitions" which do 22 not comply with CCP 2030(c)(5), are overbroad, vague, 23 inconsistent with normal usage and meaning and are 24 unintelligible. Accordingly, the responses utilize those terms 25 as they are commonly understood. 26 27 Rockbestos objects to the interrogatories on the 26 grounds that they seek "corporate knowledge" because it is 3 1 impossible for Rockbestos to set forth a collective knowledge of 2 all Rockbestos employees, past and present. The information 3 contained in the interrogatory responses has been assembled by ; 4 authorized employees and counsel for Rockbestos. It is i 5 impossible to reconstruct each step in the information gathering 6 process or to state that all pertinent documents have been i 7 discovered and examined. It is also impossible to state that all 8 individuals with relevant knowledge have been contacted to this 9 point. Investigation continues and Rockbestos specifically 10 reserves the right to revise, correct, supplement and amend these 11 interrogatory responses. 12 13 Rockbestos has never mined asbestos fiber or 14 manufactured asbestos thermal insulation. Many of the 15 interrogatories request information relating to the mining of 16 asbestos and the processes utilized in manufacturing raw 17 asbestos. Rockbestos objects to these and other interrogatories, 18 propounded as a boilerplate set of interrogatories in that they 19 are not designed to'elicit discoverable information from 20 Rockbestos. 21 22 Rockbestos does not waive any objection, on any ground, 23 whether or not asserted herein, to the interrogatories or to the 24 admission of the interrogatories and responses at trial. 25 Furthermore, Rockbestos reserves the right to assert further 26 objections to the interrogatories. The preliminary statement and 27 Ij general objections contained herein are specifically made a part 28 4 i 1 of and incorporated by reference into each of the responses set 2 forth below. 3 4 Response to Interrogatory No. is 5 6 See Preliminary Statement and General Objections. 7 Notwithstanding these objections, Rockbestos responds: 8 9 a. George Littlehales; 10 11 b. The Rockbestos Company, 285 Nicoll Street, New 12 Haven, Connecticut 06504? 13 14 c. Quality Assurance Manager; 15 16 d. Dates of Employment Position Held 17 18 1967-1968 Personnel Mgr. 19 1968-1971 Materials Mgr. 20 1971-1973 Superintendent 21 1973-Present Quality Assurance Mgr. 22 23 24 Response to Interrogatory No. g: 25 26 See preliminary statement and general objections. 27 Notwithstanding these objections, Rockbestos responds: 28 5 OAKLAND. CALIFORNIA 94801 1 a. - e. The Rockbestos Company was incorporated on 2 March 1, 1923. It is a Delaware Corporation with its principal 3 place of business at 285 Nicoll Street, New Haven, Connecticut 4 06504. 5 6 Response to Interrogatory No. 3: 7 8 See Preliminary Statement and General Objections. 9 Notwithstanding these objections, Rockbestos responds: 10 11 Rockbestos was known as Rockbestos Products Corporation 12 dating from March 1> 1923. In 1959 it became a division of Cerro * 13 Corporation. In 1984, it became The Rockbestos Company. i, i 14 M Af<t c ii r 15 j | Response to Interrogatory No. 4: i l! 16 !!i 17 See Preliminary Statement and General Objections. 18 i! Notwithstanding these objections, Rockbestos responds: II 19 20 ! Rockbestos has maintained a Certificate of Authority to i! 21 do business in California from January 29, 1981 to the present 22 i date. ]i 23 j! I. 24 Response to Interrogatory No. 5: 25 26 i See Preliminary Statement and General Objections. 27 Rockbestos further objects to this interrogatory on the grounds 28 6 1 that it is overbroad, burdensome and oppressive. Notwithstanding 2 these objections, Rockbestos responds: 3 4 Rockbestos has never had a department, division, 5 subdivision, branch or group specifically responsible for the 6 design, development, manufacture, testing and use of 7 asbestos-containing products. Refer to Response to Interrogatory e No. 8. 9 10 Response to Interrogatory No. 6: O A K L A N D . C A L IF O R N IA 9 4 0 J 11 J 12 See Preliminary Statement and General Objections. 13 Rockbestos further objects to this interrogatory on the grounds 14 that it is overbroad, burdensome and oppressive. The 15 interrogatory requests detailed information not reasonably 16 calculated to lead to the discovery of admissible evidence and 17 which falls outside the scope of this litigation. v 0 16 Notwithstanding these objections, Rockbestos responds: 19 20 j' i 21 ; < 22 I i 23 1 No. Response to Interrogatory No. 7: 24 See Preliminary Statement and General Objections. 25 Rockbestos further objects to this interrogatory on the grounds 26 that it is overbroad, burdensome and oppressive. The 27 interrogatory requests detailed information not reasonably 26 calculated to lead to the discovery of admissible evidence and 7 1 which falls outside the scope of this litigation. 2 Notwithstanding these objections, Rockbestos responds: 3 4 NO. 5 6 Response to Interrogatory No. 8: 7 8 See Preliminary Statement and General Objections. The 9 subparts of this interrogatory request information so burdensome 10 to ascertain, as to be unjust, harassing, annoying and oppressive 11 because the information relates to numerous products manufactured 12 during a 61 year period and the request is not limited to 13 products allegedly used by plaintiff/plaintiff's decedent or 14 allegedly sold and/or supplied to plaintiff 's/plaintiff's 15 decedent's employers during the period of plaintiff's/plaintiff's 16 decedent's employment. In addition, the interrogatory requests 17 detailed information not reasonably calculated to lead to the 18 discovery of admissible evidence and which falls outside the 19 scope of this litigation. Notwithstanding these objections, 20 Rockbestos responds: 21 22 Plaintiff has not established that 23 plaintiff/plaintiff's decedent utilized any product manufactured 24 by Rockbestos. Rockbestos will attempt to provide all known, 25 pertinent information for products identified by 26 plaintiff/plaintiff's decedent. 27 28 a. Since 1930 Rockbestos has manufactured and marketed 8 1 wire and cable products, some of which contained encapsulated and 2 saturated asbestos. These products included: apparatus and \ 3 motor lead wire, appliance and fixture wire, control cable, power ! 4 cable, switchboard wire, high temperature wire, furnace and mud I 5 gun cable, shipboard cable and instrumentation cable, and may f 6 also have been referenced by National Electric Code and other 7 specifications and designations. Rockbestos utilized various 8 brand names and trademarks during this period, including, 9 Firezone, Firewall, Rocktherm, Pyrotrol, Phosroc, Cryozone and 10 H-Zone; 11 12 b. - c. Refer to Response to Interrogatory No. 8 a.; 13 14 Some of the following wire and cable products contained 15 encapsulated and saturated asbestos during the indicated periods. 16 17 Wire/Cable Products Approx. Dates of Manufacture 18 19 Apparatus wire 20 Motor lead wire 21 Appliance and fixture wire 22 Control cable 23 Power cable 24 Switchboard wire 25 High temperature wire 26 Furnace and mud gun cable 27 Shipboard cable 28 Instrument cable 1936 to 1985 1930 to 1985 1930 to 1985 1930 to 1985 1930 to 1985 1930 to 1985 1938 to 1985 1974 to 1980 1930 to 1979 1930 to 1977 9 1 d. (i)-(iii) It would be unduly burdensome to provide the 2 chemical composition of each such product because Rockbestos 3 manufactured many different wire and cable products during the 4 sixty-one year period and the percentage of asbestos utilized in 5 each product varied broadly over time and with the size of the 6 wire and cable. To the extent possible, Rockbestos will atter.pt 7 to provide this information for products to which 8 plaintiff/plaintiff's decedent alleges exposure. Rockbestos used 9 only chrysotile asbestos in manufacturing wire and cable products 10 with insulation containing encapsulated and saturated asbestos. a 11 i J 12 The following are examples: OAKLAND. C*tirON*A 9490' 13 ii 14 YEAR 1981 ii 15 |l is ii Product ij 17 |i #14 Firezone 101 > Q ii 18 f (High Temperature TAGT) ll 19 I: Components Ii i 20 ii Nickel clad conductor ii 21 Teflon tape ii 22 Ii Teflon coated glass yarn 23 !. i Teflon finish compound l! 24 :! Glass yarn ii 25 :! I4 Silicone and resin finish compounds n 26 i' Lap: Asbestos i! 27 \\ lj Other nonasbestoscomponents 28 !i % 47.4 9.3 13.0 1.6 4.9. 9.7 12.1 2.0 i 10 1 YEAR: 1979 2 3 Product: 4 #14 AVA 5 Components 6 Copper conductor 7 Tape . 8 Mylar 9 Saturant 10 Varnished cambric tape 11 Lap and yarn: Asbestos 12 Other non-asbestos components 13 14 YEAR: 1981: 15 16 Product 17 #8 AVA . 18 Components 19 Copper conductor 20 Nomex tape . 21 Mylar 22 Varnished cambric tape 23 Saturant 24 Lap and yarn: Asbestos 25 Other non-asbestos components 26 27 26 e. Wire and cable; 11 % 55.5 ,5 .7 29.5 12.8 23.6 4.1 % 55.5 .4 .5 9.2 18.4 13.4 2.4 1 f. It would be unduly burdensome to provide a 2 description of the physical appearance and nature of each 3 product. To the extent possible, Rockbestos will attempt to 4 provide this information for products to which t 5 plaintiff/plaintiff's decedent alleges exposure. The wire and 6 cable products generally did not have any external markings, 7 although the boxes, spools or reels containing the products 6 generally were marked or tagged with the names Cerro or 9 Rockbestos, the brand or trade names Firezone, Firewall, 10 Rocktherm, Pyrotrol, Phosroc, Cryozone or H-Zone, an hourglass 11 within a circle or other distinctive markings. In general, wire 12 and cable products were marked internally with marker threads; 13 14 g. It would be unduly burdensome to provide a 15 detailed description of the intended use of each product. To the 16 extent possible, Rockbestos will attempt to provide this 17 information for products to which plaintiff/plaintiff's decedent 18 alleges exposure. The intended use of wire and cable products 19 with insulation containing encapsulated and saturated asbestos is 20 in those applications requiring resistance to high temperature 21 and flame, and as required in military, government and trade 22 specifications for certain wire and cable construction; 23 24 h. - i. The suppliers of asbestos containing products 25 include: * 26 1. Raybestos-Manhattan Corp. 27 Products: Lap, roving yarn. 26 Oates: 1945-1986 12 1 2. Amatex Corp. 2 Products: Roving yarn. 3 Dates: 1976-1986 4 3. Harco Chemical 5 Products: Cable filler 6 Dates: 1950-1986 7 4. Manning Paper Co. 8 Products: S.A. Asbestos tape 9 Dates: 1970-1986 10 5. Facile Div. Sun Chemical Corp. 11 Products: AM - Asbestos Mylar Tape 12 Dates: 1970-1986 13 6. Johns-Manville Corp. 14 Products: AM - Asbestos Mylar Tape 15 Dates: 1976-1986 18 17 j. Currently unknown, but investigation is continuing. 18 19 Response to Interrogatory Ho. 9: 20 21 See Preliminary Statement and General Objections. 22 Rockbestos further objects to this interrogatory on the grounds 23 that it is overbroad, burdensome and oppressive. The 24 interrogatory requests detailed information not reasonably 25 calculated to lead to the discovery of admissible evidence and 26 which falls outside the scope of this litigation. 27 Notwithstanding these objections, Rockbestos responds: 28 NO. 13 1 Response to Interrogatory Wo. IQs 2 3 See Preliminary Statement and General Objections. ' 4 Rockbestos further objects to this interrogatory on the grounds 5 that it is overbroad, burdensome and oppressive. The 6 interrogatory requests detailed information not reasonably 7 calculated to lead to the discovery of admissible evidence and 6 which falls outside the scope of this litigation. Notwithstanding 9 these objections, Rockbestos responds: 10 11 No. 12 13 Response to interrogatory No. 11: 14 15 See Preliminary Statement and General Objections. 16 Rockbestos further objects to this interrogatory on the grounds 17 that it is overbroad, burdensome and oppressive. The 18 interrogatory requests detailed information not_reasonably 19 calculated to lead to the discovery of admissible evidence and 20 which falls outside the scope of this litigation. 21 Notwithstanding these objections, Rockbestos responds: 22 23 No. 24 25 Response to Interrogatory No. 12s 26 27 See Preliminary Statement and General Objections. 26 Rockbestos further objects to this interrogatory on the grounds 14 1 that it is overbroad, burdensome and oppressive. The 2 interrogatory requests detailed information not reasonably 3 calculated to lead to the discovery of admissible evidence and 4 which falls outside the scope of this litigation. 5 Notwithstanding these objections, Rockbestos responds: 6 7 No. e 9 Response to Interrogatory No. 13: 10 ii See Preliminary Statement and General Objections. 12 Rockbestos further objects to this interrogatory on the grounds 13 that it is overbroad, burdensome and oppressive. The 14 interrogatory requests detailed information not reasonably 15 calculated to lead to the discovery of admissible evidence and 16 which falls outside the scope of this litigation. 17 Notwithstanding these objections, Rockbestos responds: 18 19 No. 20 21 Response to interrogatory Ko. 14; 22 23 See Preliminary Statement and General Objections. 24 Rockbestos further objects to this interrogatory on the grounds 25 that it is overbroad, burdensome and oppressive. The 26 interrogatory requests detailed information not reasonably 27 calculated to lead to the discovery of admissible evidence and 28 which falls outside the scope of this litigation. ' 15 1 Notwithstanding these objections, Rockbestos responds: 2 3 Currently unknown, but investigation is continuing. 4 5 Response to Interrogatory No. IS: 6 7 See Preliminary Statement and General Objections. 8 Rockbestos further objects to this interrogatory on the grounds 9 that it is overbroad, burdensome and oppressive. The 10 interrogatory requests detailed information not reasonably 11 calculated to lead to the discovery of admissible evidence and 12 which falls outside the scope of this litigation. 13 Notwithstanding these objections, Rockbestos responds: Id 15 285 Nicoll Street 16 New Haven, Connecticut 06504 17 18 Response to Interrogatory No. 16; _ 19 20 See Preliminary Statement and General Objections. 21 Rockbestos further objects to this interrogatory on the grounds 22 that it is overbroad, burdensome and oppressive. The 23 interrogatory requests detailed information not reasonably 24 calculated to lead to the discovery of admissible evidence and 25 which falls outside the scope of this litigation. 26 Notwithstanding these objections, Rockbestos responds: 27 28 a. Approximately 1920; 16 1 b. They continue to operate today? 2 c. Refer to Response to Interrogatory No. 8. 3 4 Response to Interrogatory No. 17: 5 6 See Preliminary Statement and General Objections. 7 Rockbestos further objects to this interrogatory on the grounds B that it is overbroad, burdensome and oppressive. The 9 interrogatory requests detailed information not reasonably 10 calculated to lead to the discovery of admissible evidence and 11 which falls outside the scope of this litigation. 12 Notwithstanding these objections, Rockbestos responds: 13 14 Currently unknown, but investigation is continuing. 15 16 Response to Interrogatory No. 16: 17 IB See Preliminary Statement and General .Objections. 19 Rockbestos further objects to this interrogatory on the grounds 20 that it is overbroad, burdensome and oppressive. The 21 interrogatory requests detailed information not reasonably 22 calculated to lead to the discovery of admissible evidence and 23 which falls outside the scope of this litigation. 24 Notwithstanding these objections, Rockbestos responds: 25 26 a. - g. February 7, 1967; Patent # 3,303,270 27 26 ! i j j i t 17 1 Response te Interrogatory No. 19 2 3 See Preliminary Statement and General Objections. 4 Rockbestos further objects to this interrogatory on the grounds 5 that it is overbroad, burdensome and oppressive. The 6 interrogatory requests detailed information not reasonably 7 calculated to lead to the discovery of admissible evidence and a which falls outside the scope of this litigation. In addition, 9 this information is equally available to plaintiffs by inguiry to 10 the United States Patent and Trademark Office in Washington, D.C. ii Notwithstanding these objections, Rockbestos responds: 12 13 Refer to Response to Interrogatory No. 8 for trademark 14 names. Other information is currently unknown, but investigation 15 is continuing. 16 17 Response to Interrogatory No. 20: 16 19 See Preliminary Statement and General Objections. 20 Rockbestos further objects to this interrogatory on the grounds 21 that it is overbroad, burdensome and oppressive. The 22 interrogatory requests detailed information not reasonably 23 calculated to lead to the discovery of admissible evidence and 24 which falls outside the scope of this litigation. 25 Notwithstanding these objections, Rockbestos responds: 26 27 No. 28 18 1 Response to Interrogatory No. 21: 2 3 See Preliminary statement and General Objections. 4 Rockbestos further objects to this interrogatory on the grounds 5 that it is overbroad, burdensome and oppressive. The 6 interrogatory requests detailed information not reasonably 7 calculated to lead to the discovery of admissible evidence and j 8 which falls outside the scope of this litigation. 9 Notwithstanding these objections, Rockbestos responds: 10 11 Currently unknown, but investigation is continuing. 12 13 Response to Interrogatory No. 22; 14 15 See Preliminary Statement and General Objections. 16 Rockbestos further objects to this interrogatory on the grounds 17 that it is overbroad, burdensome and oppressive. The 18 interrogatory requests detailed information not reasonably 19 calculated to lead to the discovery of admissible evidence and 20 which falls outside the scope of this litigation. 21 Notwithstanding these objections, Rockbestos responds: 22 23 a. A compilation of sales data for the period 1981 to 24 1985 is maintained by Rockbestos. Pre-1980 sales records and 25 data for California are not in existence with the exception of 26 some records reflecting sales of wire and cable products, some of 27 which contained encapsulated and saturated asbestos, to nuclear 26 power plants; \ i 19 1 b. The Rockbestos Company, 285 Nicoll Street, New 2 Haven Connecticut, 06504? 3 4 c. Edward Randall. 5 6 Response to Interrogatory Wo. 23: ; 7 iI ii 8 See Preliminary Statement and General Objections. ' 9 Rockbestos further objects to this interrogatory on the grounds 10 that it is overbroad, burdensome and oppressive. The 11 interrogatory requests detailed information not reasonably 12 calculated to lead to the discovery of admissible evidence and 13 which falls outside the scope of this litigation. 14 Notwithstanding these objections, Rockbestos responds: 15 16 Numerous uncatalogued documents responsive to this 17 request are maintained at The Rockbestos Company, 285 Nicoll 18 Street, New Haven, Connecticut 06504 and arrangements may be made 19 to inspect these documents at that location. # 20 21 Response to Interrogatory Ko. 24t 22 23 See Preliminary Statement and General Objections. 24 Rockbestos further objects to this interrogatory on the grounds 25 that it is overbroad, burdensome and oppressive. The 26 interrogatory requests detailed information not reasonably 27 calculated to lead to the discovery of admissible evidence and 26 which falls outside the scope of this litigation. 20 1 notwithstanding these objections, Rockbestos responds: 2 3 Numerous uncatalogued documents responsive to this 4 request are maintained at The Rockbestos Company, 285 Nicoll 5 Street, New Haven, Connecticut 06504 and arrangements may be made 6 to inspect these documents at that location. 7 8 Response to Interrogatory No, 25: i ! i 9 10 See Preliminary Statement and General Objections. 11 Rockbestos further objects to this interrogatory on the grounds 12 that it is overbroad, burdensome and oppressive. The 13 interrogatory requests detailed information not reasonably 14 calculated to lead to the discovery of admissible evidence and 15 which falls outside the scope of this litigation. 16 Notwithstanding these objections, Rockbestos responds: 17 18 a. The Rockbestos -Company, 285 Nicoll Street, New 19 Haven, Connecticut, 06504; 20 b. Edward Randall. 21 22 Response to Interrogatory No. 26t 23 24 See Preliminary statement and General Objections. 25 Rockbestos further objects to this interrogatory on the grounds 26 that it is overbroad, burdensome and oppressive. The 27 interrogatory requests detailed information not reasonably 28 calculated to lead to the discovery of admissible evidence and 21 1 which falls outside the scope of this litigation. 2 Notwithstanding these objections, Rockbestos responds; 3 4 Not applicable. 5 6 Response to Interrogatory No. 27; 7 6 See Preliminary Statement and General Objections. 9 Rockbestos further objects to this interrogatory on the grounds 10 that it is overbroad, burdensome and oppressive. The 11 interrogatory requests detailed information not reasonably 12 calculated to lead to the discovery of admissible evidence and 13 which falls outside*the scope of this litigation. 14 Notwithstanding these objections, Rockbestos responds: 15 16 Not applicable. 17 18 Response to Interrogatory No. 28t 19 20 See Preliminary statement and General Objections. The 21 interrogatory requests detailed information not reasonably 22 calculated to lead to the discovery of admissible evidence and 23 which falls outside the scope of this litigation. In addition, 24 the information sought is so burdensome to ascertain as to be 25 unjust, harassing, annoying and oppressive because it relates to 26 numerous products manufactured during a 61 year period and is not 27 limited to products allegedly used by plaintiff/plaintiff*s 28 decedent or allegedly sold and/or supplied to 22 1 plaintiff's/plaintiff's decedent*s employer during the period of 2 plaintiff's/plaintiff's decedent*s employment. Notwithstanding 3 these objections, Rockbestos responds: 4 5 Rockbestos is without sufficient information to 6 describe each package or container which contained products sold 7 and/or distributed by Rockbestos. Over the years the containers & consisted of boxes, spools, or reels in various materials, 9 dimensions, shapes and colors which were marked or tagged with 10 the names Cerro or Rockbestos, or the brand or trade names 11 previously identified. 12 13 Plaintiff has not established that 14 plaintiff/plaintiff's decedent utilized any product manufactured 15 by Rockbestos. Rockbestos will attempt to provide all known, 16 pertinent information for products identified by 17 plaintiff/plaintiff's decedent. 18 19 Response to Interrogatory No. 29s 20 21 See Preliminary Statement and General Objections. The 22 interrogatory requests detailed information not reasonably 23 calculated to lead to the discovery of admissible evidence and 24 which falls outside the scope of this litigation. In addition, 25 the information sought is so burdensome to ascertain as to be 26 unjust, harassing, annoying and oppressive because it relates to 27 numerous products manufactured during a 61 year period and is not 26 limited to products allegedly used by plaintiff/plaintiff's 23 1 decedent or allegedly sold and/or supplied to 2 plaintiff's/plaintiff's decedent's employer during the period of 3 plaintiff's/plaintiff's decedent's employment. Notwithstanding 4 these objections, Rockbestos responds: 5 6 Rockbestos is without sufficient information to 7 describe each product's logo, design, marking or printing. B During the defined time period packaging or containers for 9 Rockbestos products, some of which contained encapsulated and 10 saturated asbestos, included boxes, spools, or reels which were 11 marked or tagged with the names Cerro or Rockbestos, the brand or 12 trade names Firezone, Firewall, Rocktherm, Pyrotrol, Phosroc, 13 Cryozone or H-zone, an hourglass within a circle or other 14 distinctive markings. 15 16 Plaintiff has not established that 17 plaintiff/plaintiff.'s decedent utilized any product manufactured 18 by Rockbestos. Rockbestos will attempt to provide all known, 19 pertinent information for products identified by 20 plaintiff/plaintiff's decedent. 21 22 Response to Interrogatory No. 30: 23 24 See Preliminary Statement and General Objections. 25 Rockbestos further objects to this interrogatory on the grounds 26 that it is overbroad, burdensome and oppressive. The 27 interrogatory requests detailed information not reasonably 28 calculated to lead to the discovery of admissible evidence and 24 1 which falls outside the scope of this litigation. 2 Notwithstanding these objections, Rockbestos responds: 3 4 a. ~ b. Examples of packaging or containers 5 substantially similar to those utilized by Rockbestos during the 6 defined time period may be inspected at the Rockbestos Company, 7 285 Nicoll Street, New Haven Connecticut 06504; 8 9 c. Edward Randall. 10 11 Response to interrogatory No. 3lt 12 13 See Preliminary Statement and General Objections. 14 Rockbestos further objects to this interrogatory on the grounds 15 that it is overbroad, burdensome and oppressive. The 16 interrogatory requests detailed information not reasonably 17 calculated to lead to the discovery of admissible evidence and 18 which falls outside the scope of this litigation. 19 Notwithstanding these objections, Rockbestos responds: 20 21 Not applicable. 22 23 Response to Interrogatory No. 32; 24 25 See Preliminary Statement and General Objections. 26 Rockbestos further objects to this interrogatory on the grounds 27 that it is overbroad, burdensome and oppressive. The 26 interrogatory requests detailed information not reasonably 25 1 calculated to lead to the discovery of admissible evidence and 2 which falls outside the scope of this litigation. This 3 interrogatory incorrectly assumes that wire and cable products; 4 with insulation containing encapsulated and saturated asbestos, 5 | were hazardous. Notwithstanding these objections, Rockbestos I l 6 1 responds: 7 8 a. - c. A warning was included between 1979 and 1986. 9 Refer to Exhibit 1; Between 1979 and 1986 a warning was included 10 on all boxes, spools or reels of cable and wire products 11 containing insulation with encapsulated and saturated asbestos. 12 13 Response to Interrogatory No. 33: 14 15 See Preliminary Statement and General Objections. 16 Rockbestos further objects to this interrogatory on the grounds 17 that it is overbroad, burdensome and oppressive. The 18 interrogatory requests detailed information not reasonably 19 calculated to lead to the discovery of admissible evidence and 20 which falls outside the scope of this litigation. In addition, 21 this interrogatory incorrectly assumes that wire and cable 22 products, with insulation containing encapsulated and saturated 23 asbestos, were hazardous. Notwithstanding these objections, 24 Rockbestos responds: 25 26 No such brochures or pamphlets relating to Rockbestos 27 products were distributed. 28 t 26 1 Response to interrogatory Wo. 34 2 3 See Preliminary Statement and General Objections. 4 Rockbestos further objects to this interrogatory on the grounds 5 that it is overbroad, burdensome and oppressive. The 6 interrogatory requests detailed information not reasonably 7 calculated to lead to the discovery of admissible evidence and 8 which falls outside the scope of this litigation. 9 Notwithstanding these objections, Rockbestos responds: 10 11 Rockbestos has never had contract units. Refer to 12 Response to Interrogatory No. 32, a. - c. relating to warnings. 13 14 Response to Interrogatory No. 35s 15 16 See Preliminary Statement and General Objections. 17 Rockbestos further objects to this interrogatory on the grounds 16 that it is overbroad, burdensome and oppressiveL The 19 interrogatory requests detailed information not reasonably 20 calculated to lead to the discovery of admissible evidence and 21 which falls outside the scope of this litigation. Notwithstanding 22 these objections, Rockbestos responds: 23 24 Not as far as is currently known, but investigation is 25 continuing. 26 27 28 27 1 Response to .Interrogatory No^36: 2 3 See Preliminary Statement and General Objections. 4 Rockbestos further objects to this interrogatory on the grounds 5 that it is overbroad, burdensome and oppressive. The 6 interrogatory requests detailed information not reasonably 7 calculated to lead to the discovery of admissible evidence and 8 which falls outside the scope of this litigation. 9 Notwithstanding these objections, Rockbestos responds: 10 11 None. 12 13 Response to Interrogatory No. 37s 14 15 See Preliminary Statement and General Objections. 16 Rockbestos further objects to this interrogatory on the grounds 17 that it is overbroad, burdensome and oppressive. The 18 interrogatory requests detailed information not treasonably 19 calculated to lead to the discovery of admissible evidence and 20 which falls outside the scope of this litigation. 21 Notwithstanding these objections, Rockbestos responds: 22 23 (i) b. IHF 1987 to currently unknown, 24 h. AXA 1979 to 1982. 25 26 Response to interrogatory No. ae; 27 26 See Preliminary Statement and General Objections. 28 1 Rockbestos further objects to this interrogatory on the grounds 2 that it is overbroad, burdensome and oppressive. The 3 interrogatory requests detailed information not reasonably 4 calculated to lead to the discovery of admissible evidence and 5 which falls outside the scope of this litigation. 6 Notwithstanding these objections, Rockbestos responds: 7 e a. Refer to Response to Interrogatory No. 37: 9 10 b. - c. Currently unknown, but investigation is ii continuing. . 12 13 Response to Interrogatory No. 39s 14 15 See Preliminary Statement and General Objections. 16 Rockbestos further objects to this interrogatory on the grounds 17 that it is overbroad, burdensome and oppressive. The 18 interrogatory requests detailed information not reasonably 19 calculated to lead to the discovery of admissible evidence and 20 which falls outside the scope of this litigation. 21 Notwithstanding these objections, Rockbestos responds: 22 23 No such documents were received by Rockbestos on or 24 near the dates of their dissemination by the Saranac Laboratory 25 at the Trudeau Foundation. 26 27 a. Not applicable; 28 29 1 b. - c. Currently unknown, but investigation is 2 continuing; 3 4 Response to Interrogatory Mo. 40: 5 6 See Preliminary Statement and General Objections. 7 Rockbestos further objects to this interrogatory on the grounds 8 that it is overbroad, burdensome and oppressive. The 9 interrogatory requests detailed information not reasonably 10 calculated to lead to the discovery of admissible evidence and 11 which falls outside the scope of this litigation. 12 Notwithstanding these objections, Rockbestos responds: 13 14 No. 15 16 Response to Interrogatory Ko. 41: 17 18 See Preliminary Statement and General Objections. 19 Rockbestos further objects to this interrogatory on the grounds 20 that it is overbroad, burdensome and oppressive. The 21 interrogatory requests detailed information not reasonably 22 calculated to lead to the discovery of admissible evidence and 23 which falls outside the scope of this litigation. 24 Notwithstanding these objections, Rockbestos responds: 25 26 No. 27 28 30 i 1 Response to Interrogatory Wo. 42: 2 3 See Preliminary Statement and General Objections. 4 Rockbestos further objects to this interrogatory on the grounds 5 that it is overbroad, burdensome and oppressive. The 6 interrogatory requests detailed information not reasonably 7 calculated to lead to the discovery of admissible evidence and e which falls outside the scope of this litigation. 9 Notwithstanding these objections, Rockbestos responds: 10 ii No. 12 13 Response to Interrogatory No. 43s 14 15 See Preliminary Statement and General Objections. 16 Rockbestos further objects to this interrogatory on the grounds 17 that it is overbroad, burdensome and oppressive. The 18 interrogatory requests detailed information not reasonably 19 calculated to lead to the discovery of admissible evidence and 20 which falls outside the scope of this litigation. 21 22 Response to Interrogatory No. 44: 23 24 See Preliminary Statement and General Objections. 25 Rockbestos further objects to this interrogatory on the grounds 26 that it is overbroad, burdensome and oppressive. The 27 interrogatory requests detailed information not reasonably 28 calculated to lead to the discovery of admissible evidence and 31 1 which falls outside*the scope of this litigation. 2 Notwithstanding these objections, Rockbestos responds: 3 4 No. 5 6 Response to Interrogatory No. 45: 7 8 See Preliminary Statement and General Objections. 9 Rockbestos further objects to this interrogatory on the grounds 10 that it is overbroad, burdensome and oppressive. The 11 interrogatory requests detailed information not reasonably 12 calculated to lead to the discovery of admissible evidence, is 13 violative of the critical self-evaluation privilege and which 14 falls outside the scope of this litigation. 15 16 Response to Interrogatory No. 47: 17 16 See Preliminary Statement and General-Objections. 19 Rockbestos further objects to this interrogatory on the grounds 20 that it is overbroad, burdensome and oppressive. The 21 interrogatory requests detailed information not reasonably 22 calculated to lead to the discovery of admissible evidence and 23 which falls outside.the scope of this litigation. 24 Notwithstanding these objections, Rockbestos responds: 25 26 Refer to Response to Interrogatory No. 32, a. - c. 27 26 32 1 Response to Interrogatory No. 48: 2 3 See Preliminary Statement and General Objections. 4 Rockbestos further objects to this interrogatory on the grounds 5 that it is overbroad, burdensome and oppressive. The 6 interrogatory requests detailed information not reasonably 7 calculated to lead to the discovery of admissible evidence and 6 which falls outside the scope of this litigation. 9 Notwithstanding these objections, Rockbestos responds: 10 11 No. 12 13 Response to Interrogatory Mo. 49s 14 15 See Preliminary Statement and General Objections. 16 Rockbestos further objects to this interrogatory on the grounds 17 that it is overbroad, burdensome and oppressive. The 16 interrogatory requests detailed information not reasonably 19 calculated to lead to the discovery of admissible evidence and 20 which falls outside the scope of this litigation. 21 Notwithstanding these objections, Rockbestos responds: 22 23 No. 24 25 Response to Interrogatory No. sot 26 27 See Preliminary Statement and General Objections. 28 Rockbestos further objects to this interrogatory on the grounds 33 1 that it is overbroad, burdensome and oppressive. The 2 interrogatory requests detailed information not reasonably 3 calculated to lead to the discovery of admissible evidence and 4 which falls outside the scope of this litigation. 5 Notwithstanding these objections, Rockbestos responds: 6 7 Rockbestos has received numerous written communications 8 relating to lawsuits in which such allegations have purportedly 9 been made. 10 11 Rockbestos is currently unable to identify the first 12 such written communication, but investigation is continuing. 13 14 Response to Interrogatory Ko. SI: 15 16 See Preliminary Statement and General Objections. 17 Rockbestos further objects to this interrogatory on the grounds 18 that it is overbroad, burdensome and oppressive. The 19 interrogatory requests detailed information not reasonably 20 calculated to lead to the discovery of admissible evidence and 21 which falls outside the scope of this litigation. 22 Notwithstanding these objections, Rockbestos responds: 23 24 Yes 25 26 a. - f. Currently unknown, but investigation is 27 continuing. 28 ! 34 1 Response to-^nterrogatogy .No. 52: 2 3 See Preliminary Statement and General Objections. 4 Rockbestos further objects to this interrogatory on the grounds 5 that it is overbroad, burdensome and oppressive. The 6 interrogatory requests detailed information not reasonably 7 calculated to lead to the discovery of admissible evidence and 8 which falls outside the scope of this litigation. 9 Notwithstanding these objections, Rockbestos responds: 10 11 Yes. 12 13 a. - f. Currently unknown, but investigation is 14 continuing. 15 16 Response to Interrogatory No. 53s 17 18 See Preliminary Statement and General Objections. 19 Rockbestos further objects to this interrogatory on the grounds 20 that it is overbroad, burdensome and oppressive. The 21 interrogatory requests detailed information not reasonably 22 calculated to lead to the discovery of admissible evidence and 23 which falls outside the scope of this litigation. 24 Notwithstanding thefee objections, Rockbestos responds: 25 26 27 28 35 O A K LA N D . C A U rO B N IA *450* <tC T 419 .1 N IM T . A f T O B N t' I AW Rockbestos contends it had general liability coverage 2 for the relevant tiae periods; the extent and application of 3 insurance coverage is currently disputed. 4. 5 1930 - 1943, unknown; 6 1943 - 1959, Travelers; 7 1959 - 1976, Liberty Mutual; 8 1/1/76 - 9/1/76, Hoae; 9 9/1/76- Present, Self insured. 10 11 Response to Interrogatory No. 54: . 12 13 See Preliainary Stateaent and General Objections. 14 Rockbestos further objects to this interrogatory on the grounds 15 that it is overbroad, burdensoae and oppressive. The 16 interrogatory requests detailed information not reasonably 17 calculated to lead to the discovery of adaissible evidence and 18 which falls outside the scope of this litigation-. 19 Notwithstanding these objections, Rockbestos responds: 20 21 No. 22 23 Response to Interrogatory No. 5S: 24 25 See Preliainary Stateaent and General Objections. 26 Rockbestos further objects to this interrogatory on the grounds 27 that it is overbroad, burdensoae and oppressive. The 28 interrogatory requests detailed information not reasonably 36 1 calculated to lead to the discovery of admissible evidence and 2 which falls outside the scope of this litigation. 3 Notwithstanding these objections, Rockbestos responds: 4 5 No. 6 7 Response to Interrogatory No. 56t 8 9 See Preliminary Statement and General Objections. 10 Rockbestos further objects to this interrogatory on the grounds 11 that it is overbroad, burdensome and oppressive. The 12 interrogatory requests detailed information not reasonably 13 calculated to lead to the discovery of admissible evidence and 14 which falls outside the scope of this litigation. 15 Notwithstanding these objections, Rockbestos responds: 16 17 No. 18 19 Response to interrogatory No. 57: 20 21 See Preliminary Statement and General Objections. 22 Rockbestos further objects to this interrogatory on the grounds 23 that it is overbroad, burdensome and oppressive. The 24 interrogatory requests detailed information not reasonably 25 calculated to lead to the discovery of admissible evidence and I 26 j which falls outside the scope of this litigation. 27 iI 28 II I - 37 1 ! Notwithstanding these objections, Rockbestos responds: 2 3 ' No. 4 I 5' ( DATED: May 20, 1991 6 7 8 BJORK, FLEER & LAWRENCE 9 3V. f1--e . 1C L-- 10 Dorlne R. Kohn 11 Attorneys for Defendant The Rockbestos Company 12 13 14 i 15 16 17 18 i 19 20 i 21 22 23 24 25 26 27 j 28 t 38 CAUTION | Mraw 1 tw atmi mm w* f ! CAl TION (ONTAtHl .tfISTOS PI1IU AVOID 0. JATJHO MSY IKtATHINO A |T$ DUST MAY CAWSK IIKIC -ODltY HAIM ---------------9i-*******+*^^ CAUTION ; CONTAINS A ESTOS FIBERS AVOID CR_.flNG DUST , BREATHING ASBESTOS DUST MAY CAUSE i -? SERIOUS BODILY HARM j CAUTION . CONTAINS ASBESTOS FIBERS . AVOID CREATING DUST ' BREATHING ASBESTOS DUST MAY CAUSE SERIOUS BODILY HARM * CAUTION CONTAINS ASBESTOS FIBERS ! AVOID CREATING DUST BREATHING ASBESIpS DUST MAY : ' 'CAUSE SERIOUS BODILY HARM *.4 A -?+'* s' * % +*+*> Cv*. it! ."EXHIBIT 1" (Labels Reduced In Si2e) 1 ygfciyicxTiqg 2 9 N I, George G. Littlehales, an the Quality Assurance 4 Manager for Tha Ilockbestoa Company, a party in the above-entitled 5 action, and as sueh am authorised to make the following /; - e verification* X have reed the foregoing MSSpoxsbs to general r OlDSt VO. 30.00 ITAVCJUtO FLAIMTXW XSTBftftOGATORXBS and k-r.y th* a oontenta thereof. Mo single official/ employee, or former a employee of The JtocXbeatos Company has personal Knowledge of al\ 10 such matters. The information contained herein has been compiled ii at my direction by counsel for The Bocfcbestos Company', x an 12 informed and believe ell the responses ere true end verify the 13 responses on that basis. . 14 15 I declare under penalty of perjury under the lava of the 16 State of California that the foregoing Answers are *nd 17 correct, Insofar as it is possible to verify then. 16 19 Sxecuted this 20 Haven, Connecticut. day of May, issx, at New 21 22 &y: George LittleHales 23 24 25 26 27 26 1 J It e Sir* <41^1 n 3? OI 14 1 PROOF OF SERVICE BY MAIL 2 (C.C.P. 1013, 2015.5) 3 I am a citizen of the United States and a resident of 4 Klameda County. I am over the age of eighteen years and not a 5. i party to the within action; my business address is 483 Ninth 6 Street, Oakland, California 94607. 7 6 On the date below, I served this The Rockbestos 9 jpompany's Responses To General Order 30.00 Interrogatories by 10 Iplacing a true copy thereof enclosed in a sealed envelope with 11 11 !! . !|Jpostage thereon fully prepaid, in the United States mail at 12 ipakland, Alameda County, California, addressed as follows: 13 14 SEE ATTACHED LIST(8) 15 16 ; I declare under penalty of perjury that the above is 17 true and correct. 18 19 Executed at Oakland, California on May 24, 1991 20 21 22 23 24 25 26 27 28 IN RE COMPLEX ASBESTOS -LITIGATION - ALAMEDA COUNTY DEFENSE. COUNSEL SERVICE-LIST Otis McGee, 'Jr,, Esq. Marty Everson, Esq. Anderson, Galloway i Lucchese 1676 N. California Blvd, Ste. SOD Walnut Creek, CA 94596-4642 Attorneys for*. Babcock 4 Wilcox Company Hand Chritton, Esq. Archer, McComas t lageson 2033 N. Main Street, Suite 800 P.O. Box 6035 Walnut Creek, CA 94596 Attorneys for: CarUisle/ualdron Puffy Elaine McMahan, Esq. Berry l Berry Station D P.O. Box 70250 Oakland, CA 94612*0250 lesionated Defense Counsel Maureen Brooks, Esq. Bennett, Semuelsen, Reynolds & Allard 1951 Webster St., Ste. 200 Oakland, CA 94612*2909 Attorneys for: US Mineral Prod. Co./ Dinwiddie Construction/ - World Wide Trading/ Worth American Refractories Co Henry o. Rome, Esq. Branson, Fitzgerald l Howard 643 Bair Island Road, Suite 400 P.O. Box 2189 Redwood City, CA 94064 Attorneys for: Svnkcloid Company Bronson, Bronson i McKinnon 100 B Street, Ste. 400 Santa Rosa, CA 95401 Attorneys for: Sacomo*Sierra/ Sacomo Hfg./ParkerHannifin/ Airco Weld Kathleen Earley, Esq. Bumhilt, Morehouse, Burford, Schofield l Schiller 1220 Oakland Blvd., Ste. 200 P.O. Box 5166 Walnut Creek, CA 94S96 Attorneys for: Kelly Moore Pint_Co. John Oittoe, Esq. Crosby, Heafey, toaeh t May 1999 Harrison Street Oakland, CA 94612 Attorneys for: Worldbestos/Rovtl Ind./So. Pacific/ Chrvsler/Westinqhouse/Chevron/Shett Oil Cowpanv/American Motors Corporation Michael Bolechowski, Esq. Orevlow, Murrey l Payne 4000 Civic Center Drive, Suite 209 Sen Refeel, CA 94903 Attorneys for: Plant Insulation Co. Rod Pryor Ericksen, Arbuthnot, Brown, Kilduff l Day Toxie Tort litfsatfon Unit 1304 Willow Street Martinez, CA 94553 Attorneys for: BrJdaestone/yi restone. 1 nc./Goodyear Tire B_R^ber_Co^Swlnerton t Walbera/ American BUtrite Floyd White, Esq. Finan, White t Paetzold 150 Speer street Suite 1725 Sen Francisco, CA 94105*1541 Attorneys for: Alfca_Paekers/E.J, Bartells/Phelps feodae_torp./Phelps Dodoe Industries Tie Minor, Esq. Cities 6 Hicore 1900 Eafearcadero, Ste. 300 Oakland, CA 94606 Attorneys for: Thiokol Coro Tonda Reed, Esq. Glaspy t Ciaspy 201 No. Civic Drive, Ste. 245 Walnut Creek, CA 94596 Attorneys for: Barlock Industries/Cclt !nd./ J.T. Theroe. Ine. Michael lueey. Esq. Gordon ( Rees Eabercedero Center west 275 Battery Street, 20th Floor Sen Franeiseo, CA 94111 Attorneys for: W.R. Grace*Conn/Bendix (Allied Coro.)/Allied*Si9nal Inc./Foseco. In Reoid*American Coro./union pit Comoa of California, d/b/a uhoCAl Paul J. Killion, Esq. Maneock, Rothert l Bunshoft 4 Eebarcadero Center Suite 1000 San Francisco, CA 94111*4138 Attorneys for: General Cable Coro. Eugene Brown, Esq. Hardin, Cook, Loper, Engel G Bergez Lake Mgrritt Plaza 1999 Harrison Street, 16th Fir. Oakland, CA 94612*3506 Attorneys for: Western MacArthur/Spencer Turbine Company Bill Finney, Esq. Harrington, Fc-xx, Dubrow & Canter AT&T Center 611 W. Sixth Street 30th Floor Los Angeles, CA 90017 Attorneys for: Havistar/Internatienat Phil Ward, Esq. Hassard, Bonnington, Rogers A Huber 5 Fremont Center SO Fremont Street, Suite 3400 Sen Francisco, CA 94105 Attorneys for: Pittsburo-Corninc Haney E. Hudgins, Esq. 605 Market Street, Suite 700 San Francisco, CA 94105 Attorney for: Uniroval Gabriel A. Jacksor., Esq. Jackson, Wallace A Hayden 33 Hew Montgomery Street 16th Floor San Francisco, CA 94105 Attorneys for: Eaole-Pieher tnd./Okonite Andrew Schneider jedeikm, Green, Sprague t Bishop 300 Montgomery Street Suite 450 San Francisco, CA 94104*1906 Attorneys for: Ericsson. Inc./Asbestos Coro./ Anaconda/Cook Rubber Company William K. Bissell, Esq. Kincaid, Gianunzio, Caudle A Hubert 200 Webster Street, Suite 200 P.O. Box 1828 Oakland, CA 94604*0826 Attorneys for* Kaiser Cement/Kaiser Gvpsuxn/Gasket Spccialties/George Short Co./Domtar/ Permanente Steamship Rupert Ricksen, Esq. Knox, Ricksen, Snook, Anthony, Harper A Robbins 1999 Harrison Street, Suite 1700 Oakland, CA 94612*3500 Attorneys for: Comb. Eno/Foster Wheeler/ S.K. wetlman/J.T. Thorpe Ann Payne, Esq. landels, Ripley 6 Diamond Hills Plaza 350 Steuart Street San Francisco, CA 94105*1250 Attorneys for: The Flintkote Co.. Inc. Genstar Company/Blue Diamond Corp./ Pow Chemical Company Vincent McLcrg, Esq* McGlym, McLorg A McDowell Bayside Plait 186 Esfearcadere 1200 San Francisco, CA 94105-1211 Attorneys for: torp-Warner/Shell/Stoody Co./ Trial# A Machine Shop Douglas McClure McHamera, Houston, Dodge, McClure A Ney 1211 Newell Avenue, Suite 202 P.O. Box 5286 Walnut Creek, CA 94596 Attorneys for: Anchor Peck<no Company/ Uniroval/Btndis_(Allied Corp.l Jean Bertrand Morgenstein 8 Jubelirer Federal Reserve Bank Building 101 Market Street, Sixth Floor Son Freneiseo, CA 941Q5 Attorney# for: ACands/Owens*Illinois/ Keene John Krebs, Esq. Perichan, Berberg, Grossman 6 Harvey 2350 West Shaw, Suite 130 Fresno, CA 93711 Attorneys for: Generel Motors Corp. Daniel E. Alberti, Esq. Ropers, Mejeski, Kohn, Bentley, Wagner A Kane 1001 Marshall Street Redwood City, CA 94063 Attorneys for: Menville Trust/Westinohouse Electric Corp. J. Lawrence Judy, Esq. Shield A Smith 580 California St., Ste. 1400 San Francisco, CA 94104 Attorneys for: A*P_Green_ Refractories. Armstrono Worldlndustries. lcc^flexitattic Gasket. OAF Corp./Center for Claims Resolution Thornes J. Friel, Jr. Skjerven, Morrill, MacPherson, franki: A Friel 601 Montgomery, 1900 San Francisco, CA 94111 Attorneys for: Rome-Cable _Corp. Arad Thomas, Esq. StiAbos A Mason P.O. Box 868 Saeramento. CA 95804 Attorneys for: ;gkc*rsfor Robert E. Paterson, Esq. Sullivan, Roehe A Johnson 333 lush $t., 18th Floor San Francisco, CA 94104 Attorneys for: Abex Corporation Allison Gold, Esq. Thelen, Marrin, Johnson A Bridges One Kaiser Plaza, Suite 1950 Oakland, CA 94612 Attorneys for: Uiser At uni nun A Chemical Corp./ National Refractories A Cor Bechtel Corp. Phillip Bonotto, Esq. Thompson A Heller 3500 American River Orive Suite 101 Sacramento, CA 95864 Attorneys for: Lear Sieoler/Boval Ind./world Bestos Co./Hopeman Brothers. Inc. Eugene Brown, Esq. Hardin, Cook, toper, Engel A Bergez Lake Merritt Plaza 1999 Harrison Street, 18th Fir. Oakland, CA 94612*3508 Attorneys for: Western MtcArthur/Spencer Turbine Cowpeny Franklin E. londonno. Esq. Popelka, Allard, McCowan A jones 160 west Santa Clara Street 13th Floor San joee, CA 95113 Attorneys for: Owens-Cormna Fiberolas Core. t,r freemen Cut lorn. Esq. McDonald Cullen 63$ Sacramento St.. Ste 720 San Francisco. CA 94111 Attorneys for: Crane Packing/JohnCraneHoudaitle Wilkes Morgan. Esq. Bronson, Bronson McKinnon 100 B Street, Ste. 400 Santa Rosa, CA 95401 Attorneys for: Sacomo-Sierra/ Sacoffio Mfo./ParkerHannifin/ Airco Ucld John Ladd, Esq. 1683 fotsom Street San francisco, CA 94102 Phillip Bonotto, Esq. Thompson Heller 3500 American River Drive Suite *101 Sacramento, CA 95564 Attorneys for: Lear Sieoler/Roval Ind./World Bestos Co./Hopcman Brothers. Inc. Iichard J. Kildebrandt, Esq. tfildebrandt & Calatrello 757 West Ninth Street San Pedro, CA 90731 Attorneys for: Thorpe Insulation Co. Bob Channel, Esq. Walsworth, Franklin Bevins 111 Sutter Street, 19th floor San Francisco, CA 94104 Attorneys for: Hamilton Materials. Inc./Dee Engineering Co. Anthony Griffin, Esq. St. Clair, 2appettini, McFetridge Griffin Telesis Tower One Montgomery Street Suite 1400 San Francisco, CA 94104 Attorneys for: IN RE- COMPLEX ASBESTOS LITIGATION SOLANO COUNTY PIAINTIF_F_CQUNSX_SBVICE_^IST Law Offices of Bruce l. Ahnfeldt P.0. Box 6078 Napa, CA 94581 Alan ft. Brayton, Esq. Brayton 8 Associates 999 Grant Avenue P.O. Box 2109 Novato, CA 94948 Frank m. Finney, Esq. Brown 8 Finney Peri Executive Center 2033 North Main Street, Suite 430 Walnut Creex, CA 94596 Merry F. wartnick, Esq. Cartwright, Slobodin, Bokelman, Borowsky, Uartniek, Moore 8 Harris 101 California St., Suite 2600 San Francisco, CA 94111 ftiehard F. Gerry, Esq. sey, Gerry, Casey, Westbrook, Reed & Hughes 10 Laurel Street San 0iego, California 92101 Richard K. Brody, Esq. Casey, Gerry, Casey, Westbrook, Reed 8 Hughes 781 Tuloime Vallejo, CA 94590 law Offices of jack K. Clapper A Professional Corporation 62 Princess Street Sausalito, CA 94965 Herron 8 Herron Ronald K. Herron 600 Montgomery Street, 33rd Floor San Francisco, CA 94111 Davis 8 Thomas 2121 Avenue Of The Stars Suite 3100 Los Angeles, CA 90067-5010 Christopher Grell, Esq. The Monadnock Building 665 Market Street, Suite 540 San-Francisco, CA 94105 Law Offices of Jeffrey B. Merrison A law Corporation One Daniel Burnham Court Suite 220-C San Francisco, CA 94109*5460 Koberg, Finger, Brown, Cox 4 Molii 703 Market 19th Floor San Francisco, CA 94103 Law Office of Gloria J. Husick 7090 0onion way Suite 222 Oubltn, CA 94566 Jarvis, Miller, Brodsky 8 Bask' 21 Main Street, flOCI San Francisco, CA 94105 David M. McClain, Esq. Kazan, McClain, Edises 8 sincA Professional Law Corporation 171 Twelfth Street, Ste. 300 Oakland, California 94612 George W. Kilbourne, Esq. 3755 Alhambra Ave., #9 Martinez, CA 94S53 Kenneth L. Knapp 1109 Quail Street Newport Beach, CA 92660 McCarthy, Johnson 8 Miller 595 Market Street Suite 2200 San Francisco, CA 94105 Law Offiees of John C. Robinson A Professional Corporation 365 Notre Dame Drive Vallejo, CA 94569 Law Offiees of Sterns, Walker 8 Lods 100 First Street, Ste. 2300 San Francisco, CA 94105 Gerald J. Tiernen 165 Fell Street $an Francisco, CA 94102