1 1 IN THE COMMONWEALTH COURT OF PENNSYLVANIA PENNSYLVANIA DEPARTMENT OF : NO. 284 2 GENERAL SERVICES, : PENNSYLVANIA DEPARTMENT OF : M.D. 1990 3 TRANSPORTATION, PENNSYLVANIA : PUBLIC UTILITY COMMISSION, : 4 PENNSYLVANIA EMERGENCY : MANAGEMENT AGENCY, and : 5 PENNSYLVANIA DEPARTMENT OF STATE: Vs

Page 1 Page 3 1 IN THE CIRCUIT COURT OF THE CITY OF ST.

' Depo of Thomas M.

1 1 IN THE CIRCUIT COURT OF THE CITY OF ST.

18 to form or leading questions and that counsel 18 A.

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEVADA NEVADA POWER COMPANY, A NEVADA CORPORATION, PLAINTIFF, VS.

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Standard DATE COMES NOW defendant Kaiser Gypsum Company Inc. hereinafter Kaiser Gypsum and provides the following responses to Plaintiffs Standard Interrogatories To All Defendants propounded pursuant to San Francisco County Complex Asbestos 24 Litigation General Order No. 129 25 KAISER GYPSUM'S PRELIMINARY STATEMENT 26 Kaiser Gypsum submits this preliminary statement to memorialize certain steps 27 taken to implement the standard discovery regime adopted pursuant to the revised 28 General Orders filed November 15 1996 governing asbestos personal injury 1 ft Be and wrongful death cases filed in San Francisco County Superior Court Under the terms of General Order No. 129 all defendants must respond to the Plaintiffs Standard Interrogatories To All Defendants without objection even where those interrogatories appear objectionable under the rules defined by California statutes and appellate precedent The General Orders do contemplate that plaintiffs counsel must meet and confer with defendants and consider a specific defendant's concerns with the standard interrogatories as applied to that defendant's factual and litigation circumstances In Kaiser Gypsum's case that process proved sufficiently successful that Kaiser Gypsum did not believe it necessary to file a motion seeking judicial relief from the 10 burdensomeness that would arise in Kaiser Gypsum's circumstances from responding . 11 to the literal terms of the discovery 12 The meet and confer process was structured pursuant to an April 24 1997 letter 13 circulated by plaintiffs counsel In accordance with that procedure Kaiser Gypsum 14 held a meet and confer session with certain plaintiffs counsel on May 15 1997 as 15 contemplated by their April 24 letter During that session agreements were reached on 16 interpretations of numerous specific provisions of the subject standard interrogatories 17 which have since been concurred in by plaintiffs counsel that did not attend the May 15 18 meeting Kaiser Gypsum's pursuiotf its burdensomeness objections remains 19 contingent on continued realization of the agreements reached at the May 15 meeting 20 Kaiser Gypsum also stated other objections to the subject Plaintiffs Standard 21 Interrogatories during the course of the proceedings leading to their adoption Those 22 objections concerned both the concept of using standard interrogatories for discovery 23 unrelated to the resolution of cases or controversies before the Court objections to the 24 procedures underlying the development and adoption of the Standard Interrogatories 25 and objections to specific aspects of the Standard Interrogatories on grounds other than 26 burdensomeness all of which objections were either accepted or implicitly rejected 27 through adoption of the final Standard Interrogatories Kaiser Gypsum hereby makes 28 express on the record that by serving its Responses to Plaintiffs Standard Spe Interrogatories To All Defendants Kaiser Cement neither intends to nor does it waive its rights to press those objections at an appropriate future opportunity both in the context of specific cases before the Superior Court and on appellate review Kaiser Gypsum objects to these interrogatories to the extent that they call for information protected by the attorney privilege or work product doctrine This Preliminary Statement and the objections contained herein are incorporated into each of the responses set forth below KAISER GYPSUM'S RESPONSES TO INTERROGATORIES Kaiser Gypsum was constituted in 1952 and has been headquartered in disposed 10 California since that date Kaiser Gypsum of its last operating manufacturing engaged 11 plant in August 1978 and subsequently has not in manufacturing or product occurred 12 sales anywhere in the United States Thus all Kaiser Gypsum product sales 13 1952 and 1978.

AR226-2815 SPONSOR APME Avenue E. van Niewenhuyse 4 BOX 3 B-l 160 Brussels Belgium TESTITEM AMMONIUM PERFLUOROOCTANOATE (APFO) STUDY TITLE ALGAL INHIBITION TEST DATA REQUIREMENT Directive 92/69/EEC C.3,31st July 1992 OECD Guideline No. 201, 7th June 1984 US EPA/OPPTS 850.5400 Guidelines, April 1996 STUDYDIRECTOR Jacques LUaridon EXPERIMENTAL COMPLETIONDATE 7 March 2003 DATE OFISSUE J<G <eo(^ TEST FACILITY CIT BP 563 - 27005 Evreux - France LABORATORYSTUDY NUMBER 23685 EAA IFM Recherche S.N.C. au Capital de 846.092 7 0 8 0 6 0 46 2 R.C.S.

February 21, 1991 FEDERAL EXPRESS DELIVERY Mr.

KAISER GYPSUM's non-pursuit of its 23 bundensomcness objections remains contingent on continued realization ofthe 24 agreements reached at the May 15.1997, meeting. 25 KAISER GYPSUM also stated other objections to the subject Plaintiffs' Standard 26 Interrogatories dunng the course of the proceedings leading ro their adoption.

The Spor. will be advised by the Study Director of all circumstances which could lead to this action in as timely a manner as possible. 5.

CONFIDENTIAL World Register of Cases of ANGIOSARCOMA OF THE LIVER (ASL) DUE TO VCM REVIEW DATE FEBRUARY 1991 ^^ ^ ^^ ^ Collated by: J.

DEC 19 '94 04:12PM SIDLEY AUSTIN NY P.10 D6C-19-1994 14:29 FROM DRPYDEH UYOC l LDQD LLP TO 12129065821-02030004 P.01 DRAYDEN, WYCHE & WOOD, L.L.P. 1360 POST OAK BLVD. surra 1650 HOUSTON, TEXAS 7705$ Tel: (713) 965-0120 F*xt (713) 960-0010 Toll Frees (900)969-0067 wwwifwiMwww<i<pifiCfl/ff.g TRANSMITTAL TO DATE: December 19, 1994 FAX NO: (212) 906-2021 PLEASE DELIVER THE FOLLOWING PAGES TO: TO: Mr.

SI-33 1 1 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF MICHIGAN 2 SOUTHERN DIVISION 3 JANE ANN GEYER, p/r/e, JEROLD G. ) GEYER, Deceased, ) 4) plaintiff, ) 5 vs. ) ) 6) BABCOCK & WILCOX COMPANY, et al., ) 7) Defendants, ) 8 )No. 92CV70075DT vs. ) 9 USX CORPORATION, f/k/a United ) ) 10 States Steel Corporation, ) ) 11 Defendant and ) Third-Party Plaintiff, ) 12 ) UNITED STATES OF AMERICA, et al., ) 13 ) _ Third-Party Defendants.) 14 15 Deposition of ROSS A.