FILE NAME Cape Asbestos CAPE DATE 2023 DOC CAPE102 DOCUMENT DESCRIPTION Legal - Tibbs Case - Cape Third Party Complaint ELECTRONICAL Y ELECTRONICALY ELCTRONIAY STATE OF SOUTH CAROLINA COUNTY OF RICHLAND JOHN A.
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FILE NAME DuPont Remington DRM DATE 2021 Oct 18 DOC DRM029 DOCUMENT DESCRIPTION Legal - Plaintiff's answering brief in opposition to defendant's motion to exclude testimony EFiled Oct 18 2024 06:30 Transaction ID 74798642 Case No.
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FILE NAME Brakes BRK DATE 2020 DOC BRK262 DOCUMENT DESCRIPTION Report on William M.
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FILE NAME: PPG (PPG) DATE: 2020 DOC#: PPG018 DOCUMENT DESCRIPTION: PPG History - Barry Castleman Notes PPG Industries PPG Industries, Inc. was originally Incorporated as Pittsburgh Plate Glass Company In 1883.
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FILE NAME Newspaper & Magazine Articles NMA DATE 2023 Feb 10 DOC NMA205 DOCUMENT DESCRIPTION Newspaper Article - Life Sentence Asked for the Former Eternit Tycoon Stephan Schmidheiny by Prosecutor Colace 10/02/23 20:21 Life sentence asked for the former Eternit tycoon in Casale Aware that it would have been a massacre - News in France https://newsinfrance.com/ https powerstation.co.uk/shop/ CultureEconomyHistory PoliticsScienceSocietySportTechnologyTelevision PoliticsScienceSocietySportTechnologyTelevision Q HOME HTTPS://NEWSINFRANCE.COM HTTPS://NEWSINFRANCE.COM WORLD HTTPS://NEWSINFRANCE.COM/CATEGORY/WORLD/)/ LIFE SENTENCE ASKED FOR THE FORMER ETERNIT TYCOON IN CASALE AWARE THAT IT WOULD HAVE BEEN A MASSACRE HTTPS INFRANCE.COM/LIFE-SENTENCE-ASKED-FOR-THE-FORMER-ETERNIT-TYCO N-IN-CASALE-AWARE-THAT-IT-WOULD-HAVE- INFRANCE.COM/LIFE-SENTENCE-ASKED-FOR-THE-FORMER-ETERNIT-TYCOON-IN-CASALE-AWARE-THAT-IT-WOULD-HAVE- INFRANCE.COM/LIFE-SENTENCE-ASKED-FOR-THE-FORMER-ETERNIT-TYCO N-IN-CASALE-AWARE-THAT-IT-WOULD-HAVE- MASSACRE World htps:/newsinfrance.com/category/world/https://newsinfrance.com/category/world/ Life Life sentence sentence sentence sentence asked asked asked for for the the former Eternit tycoon in Casale Aware Aware that it would have been " a massacre massacre massacre massacre '4 hours ago AVIS IMPORTANT Tous les articles sont traduits de la source originale Nous exploitons un service de traduction pour aider les anglophones qui se passe dans toute la France Tout le contenu et les photos sont la propri^'t^d'e la source originale Chaque article a un lien vers la source originale au bas de l'article Nous ne stockons aucune image de la source d'origine sur notre serveur De nombreux expatri^'sretrait^'set touristes anglophones font confiance ^ notre service De nombreux r^'sidents anglophones de France n'ont pas acc^s^ ces informations Notre service facilite la compr^'hensionentre les r^'sidents anglophones et les m^'diasfrancophones tout en offrant plus de visiteurs ^ chaque article original Si vous souhaitez qu'un ^'l^'menstoit supprim^'vous pouvez nous contacter avec l'URL et la preuve des droits de propri^'t^p'our supprimer tout ^'l^'ment de notre syst^me Life sentence for Stephan Schmidheiny Here it is after a year and a half of hearings the request of the magistrate Gianfranco Colace in the Eternit bis trial that is being celebrated against the former owner of the factory that operated in Casale Monferrato for decades until 1986.
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No Shepard's SignalTM As of: July 14, 2021 12:29 PM Z Mullins v.
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FILE NAME Cape Asbestos CAPE DATE 2023 Oct 13 DOC CAPE193 DOCUMENT DESCRIPTION Affidavit of James T.H.
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CALLEN DEMPSTER, et al. v.
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FILE NAME Paccar PAC DATE 2025 Mar 10 DOC PAC013 DOCUMENT DESCRIPTION Email re requested documents for Morris v Paccar Ex J EXHIBITJ Monday March 10 2025 at 16:00:55 Eastern Daylight Time Subject Date From To PACCAR - Response Regarding Documents Tuesday March 4 2025 at 6:13:10 PM Eastern Standard Time Eric Hawkins Jonathan Ruckdeschel CC Jason Irvin Bernier Thomas P.
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FILE NAME Kerr KR DATE 2021 Apr 4 DOC KR104 DOCUMENT DESCRIPTION Declaration of Plaintiff's Expert Barry Castleman ROGER E.
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FILE NAME Paccar PAC DATE 2025 Jan 3 DOC PAC018 DOCUMENT DESCRIPTION Legal - Paccar's Supplemental Responses to Plaintiffs Interrogatories Morris v Bel Air Auto Ex 0 EXHIBIT O IN THE CIRCUIT COURT FOR BALTIMORE CITY ESERVICE 75371743 Jan 03 2025 04:17 IN RE BALTIMORE CITY * * ASBESTOS LITIGATION * * * * * * * * * * ROSALIND MORRIS Individually and as Personal Representative of the Estate of John Alan Morris et al * CASE NO 23-000029 * * April 8 2025 Trial Date * * Plaintiffs * * VS. * * BEL AIR AUTO PARTS INC et al * * Defendants * * * * * * * * * * * * * * DEFENDANT PACCAR INC'S FIRST SUPPLEMENTAL OBJECTIONS AND RESPONSES TO PLAINTIFF ROSALIND MORRIS FIRST SET OF INTERROGATORIES TO Plaintiff ROSALIND MORRIS AND NOW Comes Defendant PACCAR Inc Defendant or PACCAR by and through its counsel of record DeHay & Elliston LLP and responses to Plaintiff Rosalind Morris First Set of Interrogatories as follows PRELIMINARY STATEMENT These discovery responses are provided only for those products identified by Plaintiff and to which Plaintiff alleges exposure These discovery responses are based on an ongoing review of PACCAR's documents and information obtained from ongoing discussions with various PACCAR personnel Much of the information requested dates back many years and is difficult or impossible to reconstruct or retrieve These discovery responses are made pursuant to a reasonable and diligent investigation and search for the information requested PACCAR reserves the right to amen these discovery responses if new or additional information becomes available to it PACCAR prepared these discovery responses with the assistance of counsel No single employee officer or agent of PACCAR has hand knowledge regarding each and every response The person signing these responses does so to satisfy whatever requirement may exist under the applicable rules regarding verification That person is informed and believes that the information known as of the date of his signature supports the discovery responses below INSTRUCTIONS Plaintiff's definitions and instructions are not repeated herein for the sake of brevity PACCAR objects to Plaintiff's definitions and instructions to the extent they are overbroad unduly burdensome and not reasonable calculated to lead to the discovery of admissible evidence PACCAR further objects to Plaintiff's definitions and instructions to the extent they include meanings and characterizations inconsistent with PACCAR's interpretation of the defined terms and phrases GENERAL OBJECTIONS PACCAR asserts the following objections and incorporates each by reference into each and every Answer to Plaintiff's Interrogatories set forth herein a PACCAR objects to Plaintiff's Interrogatories to the extent that they seek corporate knowledge as it is extremely difficult for PACCAR to set forth the collective knowledge of all of its past or present employees PACCAR reserves the right to revise correct supplement and amend its discovery responses to provide information discovered subsequent to the responses contained herein b PACCAR asserts the right to object on the grounds of competency privilege relevancy materiality or any other proper ground to the use of any said discovery response for any purpose in whole or in part in any subsequent step or proceeding in this litigation c PACCAR asserts the right to object on any other ground to other interrogatories or other discovery procedures involving or relating to the subject matter of the Interrogatories answered herein d PACCAR asserts the right to revise correct supplement or clarify any of its discovery responses set forth herein at any time and PACCAR reserves the right to object to the use of these discovery responses at trial or any other proceeding as deemed necessary and appropriate by PACCAR e PACCAR objects to the extent Plaintiff seeks documents no longer in PACCAR's possession PACCAR's document retention policy is 7 years save for documents that fall under specific categories As such PACCAR may no longer possess documents responsive to certain Interrogatories f PACCAR objects to Plaintiff's Interrogatories to the extent that they involve matters outside of the geographical area at issue in this litigation and limits its discovery responses to said area g Furthermore these Interrogatories ask PACCAR to disclose information of which may no longer exist or may not be readily available is unrelated to the products at issue in this case Such information is also unrelated to the locations at which Decedent may have used any PACCAR product the conditions under which Decedent may have used any PACCAR product the time period during which Decedent may have used any PACCAR product or the time period during which Decedent alleges exposure to any PACCAR product Thus Plaintiff's Interrogatories seek information which is neither material nor relevant to the issues in this litigation are overbroad in time scope and location and are otherwise not reasonably calculated to lead to the discovery of admissible evidence h Plaintiff's Interrogatories are oppressive burdensome and would require PACCAR to undertake a massive and extraordinary document search the results of which would have little to no demonstrable bearing on this litigation in light of the alleged exposure Moreover many of these Interrogatories are not susceptible to a response because they request information which dates back many years and is now virtually impossible for PACCAR to reconstruct or retrieve in its entirety ( PACCAR objects to Plaintiff's Interrogatories because they were propounded to harass and coerce a settlement despite the lack or complete absence of verifiable product identification and the lack of evidence of injury as a result of alleged exposure to or use of any product which PACCAR may or may not have assembled j PACCAR objects to these Interrogatories because they are propounded for an additional improper purpose namely as a fishing expedition for the purposes of obtaining information that may be taken out of context by Plaintiff's counsel to create allegations against PACCAR where none may legitimately exist k PACCAR objects to Plaintiff's Interrogatories as overbroad in that they seek information from entities other than itself or its predecessors PACCAR over the course of its long history has owned several businesses which are not involved in the instant litigation Therefore all references in Plaintiff's Interrogatories to DEFENDANT YOU or YOUR and the like are assumed to refer only to PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company 1 PACCAR objects to each and every Interrogatory that seeks production of any information constituting a trade secret confidential financial data or other confidential research development or commercial information m PACCAR objects to Plaintiff's Interrogatories as argumentative because they assume that a health hazard is created by the PACCAR products that may have incorporated asbestoscontaining component parts which PACCAR denies n PACCAR objects to Plaintiff's Interrogatories on the basis that they are vague and ambiguous Interrogatories relating to certain diseases fail to provide facts relating to the amount of exposure duration of exposure fiber type in exposure and latency period o PACCAR objects to Plaintiff's Interrogatories in that they tend to group together all of Defendants in this litigation and are therefore overbroad unduly burdensome harassing and not calculated to lead to the discovery of relevant and material evidence p PACCAR objects to each and every Interrogatory that calls for either pure speculation or legal conclusions on the part of PACCAR q PACCAR objects to each and every Interrogatory that calls for a medical conclusion beyond the scope of PACCAR's knowledge and capability r PACCAR objects to each and every Interrogatory that purports to impose any obligations on it that are not set forth in the Maryland Rules of Civil Procedure PACCAR objects that Plaintiff has propounded more than 30 interrogatories in violation of Maryland Rule of Civil Procedure 2-421 These responses are made without waiving its objection based on Rule 2-421 a s PACCAR objects to each and every Interrogatory that seeks information protected by the attorney privilege or attorney work product doctrine t PACCAR objects to each and every Interrogatory that seeks disclosure of information generated by persons other than PACCAR that has come into the possession of PACCAR's counsel during the course of discovery and trial preparation in asbestos litigation u PACCAR objects to each and every Interrogatory that seeks information for any time period unrelated to Plaintiff's alleged exposure v PACCAR objects to each and every Interrogatory that seeks information that is not under PACCAR's custody or control or which is within the public domain or otherwise equally available to Plaintiff or their counsel Subject to and without waiving any of the foregoing objections PACCAR states as follows FIRST SUPPLEMENTAL RESPONSES TO INTERROGATORIES INTERROGATORY NO RM Identify each person other than a person intended to be called as an expert witness at trial having discoverable information that tends to support a position that you have taken or intend to take in this action including any claim for damages and state the subject matter of the information possessed by that person Standard General Interrogatory No. 1.
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No Shepard's SignalTM As of: July 14, 2021 12:29 PM Z Mullins v.
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FILE NAM E: Foseco (FOS) DATE: 2021 DOC#: FOSOOl DOCUMENT DESCRIPTION: BC N otes if * / / ?
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FILE NAME Johnson & Johnson JAJ DATE 2025 Sept 25 DOC JAJ225 DOCUMENT DESCRIPTION Legal - Testimony of Barry Castleman Casaretto Case Casaretto v & Barry Castleman Comments - Legal - 2025 Sept. 25 Castleman testimony as fact witness Casaretto Broward Co.
refid# YDop1j5EnXxzyOaypGN78Z51y225 pages
FILE NAME Talc TALC DATE 2020 Oct DOC TALC311 DOCUMENT DESCRIPTION Article - Asbestos Contamination in TalcBased Cosmetics An Invisible Cancer Risk W) Check for updates Asbestos Contamination in Based Cosmetics An Invisible Cancer Risk Tasha Stoiber,,Sean Fitzgeraldand Nneka S Leiba,, ,,EnvironmentalWorking Group Washington DC USA 2Scientific Analytical Institute Greensboro NC USA Environmental Health Insights Volume 14 1-3 O The Author 2020 Article reuse guidelines sagepub.com/journals-permissions DOI 1178630220976558 SSAGE ABSTRACT The lack of regulation and adequate testing of containing personal care products in the U.S. has resulted in the contamination of cosmetics with asbestos As such the true exposure of consumers to asbestos is poorly characterized and likely underestimated In this study transmission electron microscopy analysis revealed that 3 of 21 powder cosmetic products tested were contaminated with amphibole asbestos One of these contaminated products is expressly marketed for use by children The presence of asbestos found in products demonstrates the urgency to revise cosmetics policy Further based cosmetics may be an overlooked and difficult to characterize source of exposure to asbestos a known carcinogen KEYWORDS Asbestos talc personal care products cancer risk RECEIVED October 27 2020.
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