FILE NAME: Talc (TALC) DATE: 1992 DOC#: TALC173 DOCUMENT DESCRIPTION: Journal Article - Biological Effects of Inhaled Minerals SluXUr\< y Q j).

PAGE Citation 61 FR 28666-01 1996 WL 293878 (F.R.) bite as: 61 FR 28666) Rank(R) R 1 OF 1 Database FR Mode Page RULES and REGULATIONS DEPARTMENT OF TRANSPORTATION Research and Special Programs Administration 49 CFR Parts 171, 172, 173, 174, 178, and 179 [Docket No.

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.

A Division of The Society of The Plastics Industry, Inc.

As a matter of fact, they have been in each year leading up to that time as well; weren't they?

FILE NAME Talc TALC DATE 1992 DOC TALC173 DOCUMENT DESCRIPTION Journal Article - Biological Effects of Inhaled Minerals 33 Guthrie GD 1992.

: ft*:. 1 'c T'vv"^- ' fmafgiri specialty products. ' lli/AZ&iS&befnica/s Georgia-Pacific is a leading supplier of resins, adhesives and specialty V: `'i . chemicals to the forest products industry.

A HISTORY OF UNION CARBIDE CORPORATION PLAINTIFF'S EXHIBIT UC-5359 TIME LINE A Chronology of Significant Events Relating to the History of Union Carbide Corporation Compiled by George H.

1 1 STATE OF MICHIGAN 2 IN THE CIRCUIT COURT FOR THE COUNTY OF WAYNE 3 4 MIKE NORMAN, ) 5 Plaintiff, ) 6 vs. ) No. 94-421061 NP 7 A-C PRODUCT LIABILITY TRUST, ) 8 et a1 . , ) 9 Defendants. ) 10 11 The discovery deposition of WILLIAM N. 12 McLEAN, taken in the above-entitled cause before 1 3 PAMELA L.

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Quality Assurance Project Plan Multi-City Study Sampling Task (NJ00666) BACK TO MAIN Revision No. : 1 Effective Date: M ay 14, 1999 Page i o f iv Quality Assurance Project Plan for Empirical Human Exposure Assessment Multi-City Study Sampling Task To May 14,1999 Prepared by Battelle 397 Washington Street Duxbury, MA 02332 (781) 934-0571 APPROVALS Sampling Task Leader Rosanna Buhl Battelle Sampling Task QA Officer __f l / ; JtjJy/,ATJl& Marcia Nishioka * Battelle Project Manager Susan bbgy Battelle Program QA Officer Date Date q n /n Date s litto Date Date Quality Assurance Project Plan Multi-City Study Sampling Task (N100666) Joseph Fiksel Marcia Nishioka Suan Abbgy Donald Gunster Rosanna Buhl Wayne Trulli Scott Macomber Chris Gagnon Kelly Irizarry Robert Mandeville Richard Restucci Kim Andrews Distribution List BACK TO MAIN Revision No.: 1 Effective Date: May 14, 1999 Page ii o f v BACK TO MAIN Quality Assurance Project Plan Multi-City Study Sampling Task (N100666) Revision No.: 1 Effective Date: May 14, 1999 Page iii o f v CONTENTS 1.

OhemRisk A Division of McLaren/Hart Environmental Engineering The Couriland East Building 29225 Chagrin Boulevard Cleveland, OH 44122 (216) 464-6564 FAX (216) 46-4 6101 April 30, 1996 Robert Venezia, Ph.D.

TO: Distribution XF> Interoffice Communication FROM: DATE: SUBJ: T.

STATE OF WISCONSIN CIRCUIT COURT BRANCH 8 MILWAUKEE COUNTY STROH DIE CASTING COMPANY, Plaintiff, v.

a Adams Research TI N C O R P a R A T E D Anniston Community Survey: January 1995 Adams Research Inc. 1200 N.