FILE NAME Kaiser Gypsum KG DATE 1985 DOC KG040 DOCUMENT DESCRIPTION Legal - Interrogatories Propounded & Served Concurrently with Requests for Admission to All Defendants GREENE O'REILLY BROILLET PAUL SIMON MCMILLAN WHEELER & ROSENBERG LAWYERS LOS ANGELES OFFICE 816 SOUTH FIGUEROA STREET LOS ANGELES CALIFORNIA 90017-2516 213 482-1122 213 482-1350 SPACE BELOW FOR FILING STAMP ONLY 5 Attorneys for Plaintiff 6 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES 9 10 LOS ANGELES UNIFIED SCHOOL 11 DISTRICT ) CASE NO C 440 317 ) ) INTERROGATORIES PROPOUNDED AND 12 Plaintiff ) SERVED CONCURRENTLY WITH ) REQUESTS FOR ADMISSION TO 13 (: VS. ) ALL DEFENDANTS ) *, 1 14 CORNING FIBERGLAS et ) 15 al ) ) 16 Defendants ) ) 18 TO DEFENDANT KAISER GYPSUM COMPANY INC 19 AND TO ITS ATTORNEYS OF RECORD HEREIN These interrogatories are being served on each and every 21 defendant herein 22 Plaintiff requests that you answer the following interrog- 23 atories pursuant to Section 2030 of the California Code of Civil 24 Procedure within thirty 30 days of service thereof GENERAL PROVISIONS 26 27 These interrogatories ask not only for your knowledge and the contents of your own books and records but also knowlege ^' of all other persons with whom made from the contents of books inquiry may and records reasonably have been available to you for examination Your answers to these interrogatories should be based on all the aforementioned sources 10 11 KOSENBRG 9017-258 12 NICE STRET 13 NICE 482-1350482-12 ae &a fe ~ 14 CALIFORNWHELRLAWY ANGELFIGU 15 213 213 LOS SOUTH 16 ANGELS918 17 MCILAN LOS 18 19 If following your exercise of due diligence to answer any interrogatory you are still unable to provide the information requested please state in detail a your answer to the fullest extent possible b why you are unable to answer more fully c d what efforts you have made to answer fully the anticipated date of your completion of said investigation and discovery necessary to answer fully When an interrogatory asks you to identify a writing you may in lieu of answering that interrogatory attach a copy of that writing with a statement in answer to the interrogatory that such copy is attached and such copy is a true copy of the original of the writing 20 2 If you refuse to voluntarily attach a copy of that 2 writing then identify each such writing in detail so that it may 2 be produced by you in response to plaintiff's Notice to Produce 2 or other discovery device 25 26 If objections to these interrogatories are not filed 27 within thirty 30 days as provided in Code of Civil Procedure 28 Section 2030 said objections will be waived DEFINITION You means and refers to you your agents your employees your servants your representatives and anyone else acting on your behalf or at your request INTERROGATORIES 1.

FILE NAME Owens Illinois OWILL DATE 1980 Aug 19 DOC OWILL089 DOCUMENT DESCRIPTION Legal - Deposition of Everett C.

FILE NAME: National Gypsum (NG) DATE: 1981 Jan 16 DOC#: NG014 DOCUMENT DESCRIPTION: Letter to Gold Bond from Architects Requesting Info Possible Past Use of Asbestos Product in School District F R A N G K ISER & U TCHE NS architects inc ; < in >j * i T: iin n *80 4306 Doctor Greaves Road Grandview, Missouri 64030 Phon 816-761-8900 January 16# 1981 V TO: JOE VOLK - RESEARCH 1/19/81 Mr.

FILE NAME: Thane (THAN) DATE: 1980 May 28 DOC#: THAN043 DOCUMENT DESCRIPTION: Letter to Carey Canadian RE Discontinuing Being a Third Party Distributor of Asbestos Products Thompson-Hayward Chemical Company * May 28, 1980 bcc: Ray Fitzgerald Ralph Ripley Carl Segraves Carter Marberry - Memphis Reg Chuck Jensen - Memphis Mr, Joseph A.

FILE NAME Quebec Asbestos Mining Association QAMA DATE 1980 Mar 1 DOC QAMA018 DOCUMENT DESCRIPTION Notes of Albert Donnay on Visit to Biological Effects Library Montreal Quebec on Feb 26 1980 Biological EFFECTS Library Institute of Occupational and Environmental Health IOEH Qu^'bec Asbestos Mining Association QAMA Montr^'al Qu^'bec report based on a visit to the library February 26 1980 submitted March 1 1980 Albert Donnay 320 Cote St.

FILE NAME: General Electric (GE) DATE: 1980 Aug DOC#: GE186 DOCUMENT DESCRIPTION: List from CPSC Bulletin of Hair Dryers with Asbestos U.S.

FILE NAME: Talc (TALC) DATE: 1982 June DOC#: TALC099 DOCUMENT DESCRIPTION: Medical Journal Article - The Mortality Experience of Upstate NY Talc Workers From (613D 998-3280 Order # 05543491DP04581959 Mon 3un 13 20:50:18 2005 Page 2 of 6 The Mortality Experience of Upstate ?

FILE NAME: Chrysler (CHRY) DATE: 1980 Feb DOC#: CHRY096 DOCUMENT DESCRIPTION: EPA Report - Asbestos Product Test Results a.S.

FILE NAME: Crane Company (CRC) DATE: 1983 July 29 DOC#: CRC011 DOCUMENT DESCRIPTION: Memo - Foster Wheeler Energy Co Asbestos Policy ' ^ FOSTER WHEELER ENERGY CORPORATION H O s o u t h ORANGE AVENUE LIVINGSTON n e w JERSEY O 7 0 3 9 " HONE 2CV-S i l i . n o o 3uly 29, 1983 C rane Company 5000 Executive Blvd.

FILE NAME: Asbestos Cement Pipe and Sheet (ACPS) DATE: 1986 Feb 25 DOC#: ACPS121 DOCUMENT DESCRIPTION: J-M Memo Response to Feb 18 Memo - Plant Workers Exposed to Asbestos Do Not Need to Wear Respirators Subject; RECEIVED pB 28 1986 INTERNAL RECOMMENDATION AND/OR AUTHBBlZJfflffll _________________________________________________________________________Page; NEED FOR RESPIRATORS E.

FILE NAME: Asbestos in India (IND) DATE: 1981 June 13 DOC#: IND012 DOCUMENT DESCRIPTION: Journal Article - Industrial Hazards Exported to India AND POLITICAL A Samaeksha Trust Publication EXPORT OF INDUSTRIAL HAZARDS TO INDIA NEPALESE IN NORTHEAST LAW OF SEA: CHANGING SCENARIOS RISE OF SOCIAL CAPITALISM IN USSR POLITICS OF PRIMARY EDUCATION IN WEST BENGAL SIGNALLING REAGAN FROM ISLAMABAD PERSPECTIVES Industrial Hazards Exported to India Barry I Castleman Rakesh Madan Robert Mayes ASBESTOS is the name for a family of fibi ous minerals that have found wide spread use in industry over the past century.

FILE NAME: Asbestos Mining (ASMI) DATE: 1981 Aug 16 DOC#: ASMI021 DOCUMENT DESCRIPTION: Letterto Dr.

FILE NAME: Asbestos Textile Product Use (ATPU) DATE: 1984 Jan 25 DOC#: ATPU038 DOCUMENT DESCRIPTION: Correspondence between MD Senate & Grace Ziem, Johns Hopkins & Testim ony in Favor to Ban Asbestos Clothing THE JOHNS HOPKINS UNIVERSITY School of Hygiene and Public Health Department of Health Policy and Management January 25, 1984 Kon.

FILE NAME: Kaiser Gypsum (KG) DATE: 1986 DOC#: KG043 DOCUMENT DESCRIPTION: Legal - Supplemental Responses to Interrogatories ...

FILE NAME: US Government Contractor Regulations Including Shipyard Regulations (GCR) DATE: 1981 DOC#: GCR005 DOCUMENT DESCRIPTION: Memo RE Revised USAP Policy on the Use of Asbestos-Containing Materials with Attachment Z ' 1 INTERNAL CO RRESPO N D EN CE MINING AND M ETALS DIVISION To( H DirriiOR to<0/,o<i R.