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The rule also clarifies the authority of the board when it assumes full authority as the lead agency when a lead agency fails to adopt a boardcertified mining ordinance.
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Should KUBOTA be 17 ordered to produce such documentation said order will force KUBOTA to breach its confidential 18 contract with third parties This demand also requests documents that may be protected by the 19 attorney and attorney work product privileges Without waiving these objections 20 KUBOTA responds as follows 21 a KUBOTA has conducted diligent search and reasonable inquiry and is not in 22 possession custody or control of the requested documents that were created prior to December 23 exist 31 1975 and are related to asbestos pressure pipe nor are they known to 24 REQUEST FOR PRODUCTION NO 2 22 22 DOCUMENT CONCERNING YOUR Retired Employees Association Directory 27 28 4 DEFENDANT KUBOTA CORPORATION'S RESPONSES TO PLAINTIFFS REQUESTS FOR PRODUCTION OF DOCUMENTS SET RESPONSE TO REQUEST FOR PRODUCTION NO 2 2 KUBOTA objects to this request as it invades the right to privacy of third parties and 3 their families is overly broad in scope unduly burdensome oppressive harassing irrelevant and 4 not reasonably calculated to lead to the discovery of admissible evidence as to any KUBOTA 5 business documents created after December 31 1975 and as to information related to other 6 7 containing products besides asbestos pressure pipe The request is also vague ambiguous unintelligible and undefining as to the phrase Retired Employees Association Directory 10 REQUEST FOR PRODUCTION NO 3 11 DOCUMENT CONCERNING the Retired Employees Association Directory for the 12 asbestos cement pipe division of Kubota 13 RESPONSE TO REQUEST FOR PRODUCTION NO 3 14 15 KUBOTA objects that the request is vague ambiguous unintelligible and undefining as 16 to the phrase Retired Employees Association Directory KUBOTA also objects to this request 17 as it invades the right to privacy of third parties and their families who are not parties to the 18 action who are protected by the California Constitution Japanese law and common law The 19 request is also overly broad in scope unduly burdensome oppressive harassing irrelevant and 20 not reasonably calculated to lead to the discovery of admissible evidence 21 REQUEST FOR PRODUCTION NO 4 22 23 DOCUMENT RELATING to any and all asbestos deaths of former Kubota 24 employees 25 RESPONSE TO REQUEST FOR PRODUCTION NO 4 26 KUBOTA objects to this request as it invades the right to privacy of third parties and 27 their families who are not parties to the action who are protected by the California Constitution 28 Japanese law and common law The request is overly broad in scope unduly burdensome DEFENDANT KUBOTA CORPORATION'S RESPONSES TO PLAINTIFFS REQUESTS FOR PRODUCTION OF DOCUMENTS SET
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Should KUBOTA be 18 ordered to produce such documentation said order will force KUBOTA to breach its confidential 19 contract with third parties This demand also requests documents that may be protected by the 20 attorney and attorney work product privileges Without waiving these objections 21 KUBOTA responds as follows 22 KUBOTA has conducted a diligent search and reasonable inquiry and is not in 23 possession custody or control of the requested documents that were created prior to December 24 31 1975 and are related to asbestos pressure pipe nor are they known to exist 25 REQUEST FOR PRODUCTION NO 2 26 DOCUMENT CONCERNING YOUR Retired Employees Association Directory 27 28 4 DEFENDANT KUBOTA CORPORATION'S RESPONSES TO PLAINTIFFS REQUESTS FOR PRODUCTION OF DOCUMENTS SET 03/15/2010 03/15/2010 17:18 FAX 084/137 084/137 RESPONSE TO REQUEST FOR PRODUCTION NO 2 KUBOTA objects to this request as it invades the right to privacy of third parties and 3 their families is overly broad in scope unduly burdensome oppressive harassing irrelevant and 4 not reasonably calculated to lead to the discovery of admissible evidence as to any KUBOTA business documents created after December 31 1975 and as to information related to other containing products besides asbestos pressure pipe The request is also vague ambiguous unintelligible and undefining as to the phrase Retired Employees Association Directory REQUEST FOR PRODUCTION NO 3 DOCUMENT CONCERNING the Retired Employees Association Directory for the asbestos cement pipe division of Kubota RESPONSE TO REQUEST FOR PRODUCTION NO 3 KUBOTA objects that the request is vague ambiguous unintelligible and undefining as to the phrase Retired Employees Association Directory KUBOTA also objects to this request as it invades the right to privacy of third parties and their families who are not parties to the action who are protected by the California Constitution Japanese law and common law The request is also overly broad in scope unduly burdensome oppressive harassing irrelevant and not reasonably calculated to lead to the discovery of admissible evidence REQUEST FOR PRODUCTION NO 4 22 23 DOCUMENT RELATING to any and all asbestos deaths of former Kubota 24 employees 25 RESPONSE TO REQUEST FOR PRODUCTION NO 4 26 KUBOTA objects to this request as it invades the right to privacy of third parties and 27 their families who are not parties to the action who are protected by the California Constitution 28 Japanese law a
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Lead Paint $1.3M Jury Award Upheld in Baltimore Lead Paint Case A Maryland landlord will remain on the hook for a $1.3 million jury award to a man exposed to lead paint in a Baltimore rental property as a child, a Maryland appeals court ruled.
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Again, the State Mitigation Leads are also being provided with an opportunity for review and input.
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Should KUBOTA be 18 ordered to produce such documentation said order will force KUBOTA to breach its confidential 19 contract with third parties This demand also requests documents that may be protected by the 20 attorney and attorney work product privileges Without waiving these objections 21 KUBOTA responds as follows 22 KUBOTA has a conducted diligent search and reasonable inquiry and is not in 23 possession custody or control of the requested documents that were created prior to December 24 31 1975 and are related to asbestos pressure pipe nor are they known to exist 25 REQUEST FOR PRODUCTION NO 2 26 DOCUMENT CONCERNING YOUR Retired Employees Association Directory 27 28 4 DEFENDANT KUBOTA CORPORATION'S RESPONSES TO PLAINTIFFS REQUESTS FOR PRODUCTION OF DOCUMENTS SET RESPONSE TO REQUEST FOR PRODUCTION NO 2 KUBOTA objects to this request as it invades the right to privacy of third parties and their families is overly broad in scope unduly burdensome oppressive harassing irrelevant and not reasonably calculated to lead to the discovery of admissible evidence as to any KUBOTA business documents created after December 31 1975 and as to information related to other containing products besides asbestos pressure pipe The request is also vague ambiguous unintelligible and undefining as to the phrase Retired Employees Association Directory 10 REQUEST FOR PRODUCTION NO 3 11 DOCUMENT CONCERNING the Retired Employees Association Directory for the 12 asbestos cement pipe division of Kubota 13 RESPONSE TO REQUEST FOR PRODUCTION NO 3 14 15 KUBOTA objects that the request is vague ambiguous unintelligible and undefining as 16 to the phrase Retired Employees Association Directory KUBOTA also objects to this request 17 as it invades the right to privacy of third parties and their families who are not parties to the 18 action who are protected by the California Constitution Japanese law and common law The 19 request is also overly broad in scope unduly burdensome oppressive harassing irrelevant and 20 not reasonably calculated to lead to the discovery of admissible evidence 21 REQUEST FOR PRODUCTION NO 4 22 23 DOCUMENT RELATING to any and all asbestos deaths of former Kubota 24 employees 25 RESPONSE TO REQUEST FOR PRODUCTION NO 4 26 KUBOTA objects to this request as it invades the right to privacy of third parties and 27 their families who are not parties to the action who are protected by the California Constitution 28 Japanese law and common law The request is overly broad in scope unduly burdensome DEFENDANT KUBOTA CORPORATION'S RESPONSES TO PLAINTIFFS REQUESTS FOR PRODUCTION OF DOCUMENTS SET
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Rick Snyder's administration to be caught in the criminal probe of the impoverished city's lead contamination crisis.
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I'm emailing to follow up on our meeting from a few months ago on EPA's Endangerment Finding for Lead Emissions from Piston-Engine Aircraft Using Leaded Aviation Gasoline (Docket No.: EPA-HQ-QAR-2007-0294).
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To: From: Sent: Subject: Jackson, Ryan[jackson.ryan@epa.gov] POLITICO Pro Energy Whiteboard Wed 11/8/2017 3:54:59 PM Senate to vote on Wehrum nomination to lead EPA air office By Anthony Adragna 11/08/2017 10:53 AM EDT Senate Majority Leader Mitch McConnell said today the chamber would vote to move forward on William Wehrum's nomination to lead EPA's air office.
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Most recently, the authority announced it was suspending a lead service line replacement program after a handful o f tests showed elevated levels o f lead after partial replacement.
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Lucent objects to each of th Discovery Requests to the extent that they seek information neither relevant to the subject matter of the pending litigation nor reasonably calculated to lead to the discovery of admissible evidence.
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There are two lead directors: Jeffrey Fettig, who previously served as the lead independent director for Dow; and Alexander Cutler, who previously served as the lead independent director for DuPont.
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There are two lead directors: Jeffrey Fettig, who previously served as the lead independent director for Dow; and Alexander Cutler, who previously served as the lead independent director for DuPont.
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CHESTERTON INC et al ) \ Defendant ) ECEIVE ECEIVE ECEIVE 2012 , PACCAR INC'S ANSWER TO PLAINTIFFS MANUFACTURER INTERROGATORIES DIRECTED TO DEFENDANT Defendant PACCAR Inc hereinafter PACCAR by and through its attorneys Segal McCambridge Signer & Mahoney Ltd. and for its Answers to Plaintiffs Manufacturer Interrogatories Directed to Defendant states as follows PRELIMINARY STATEMENT These responses are provided only for those products to which Plaintiff has alleged exposure These 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 Therefore PACCAR reserves the right to amend these responses if more information becomes available PACCAR prepared these 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 requirements 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 responses below DEFINITIONS Plaintiff's Definitions are not repeated herein for the sake of brevity PACCAR objects to those Definitions as overly broad vague and confusing as drafted PACCAR further objects to Plaintiff's Definitions in that they include meanings and characterizations inconsistent with PACCAR's interpretation of the defined terms and phrases GENERAL OBJECTIONS PACCAR objects to Plaintiff's Interrogatories to the extent that they seek corporate knowledge as it is impossible 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 responses to provide information discovered subsequent to the answers contained herein PACCAR asserts the following objections and incorporates each by reference into each and every response to Plaintiff's Interrogatories set forth herein a PACCAR asserts the right tto o object on the grounds of competency privilege relevancy materiality or any other proper ground to the use of any said responses for any purpose in whole or in part in any subsequent step or proceeding in this litigation b 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 c PACCAR asserts the right to revise correct supplement or clarify any of the responses or objections set forth herein at any time and PACCAR reserves the right to object to the use of these responses at trial or any other proceeding as deemed necessary and appropriate by PACCAR d PACCAR objects to the Plaintiff's Interrogatories to the extent that they involve matters outside of the geographical area at issue in this litigation and limits its responses to said area e 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 which Plaintiff alleges exposure to in this litigation and information which is also unrelated to the locations at which any PACCAR product was allegedly used the conditions under which the products were allegedly used the time period during which any PACCAR product was allegedly in use at any alleged work sites or the time periods during which exposure to a PACCAR product allegedly occurred Thus these Interrogatories seek information which is neither material nor relevant to the issues in this litigation are overly broad in time scope and location and are otherwise not reasonably calculated to lead to the discovery of admissible evidence f These Interrogatories are oppressive and 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 g PACCAR objects to these 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 manufactured h 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 ) PACCAR objects to these Interrogatories as overly broad 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 these Interrogatories to YOU YOUR COMPANY and THIS DEFENDANT are assumed to refer only to PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company ( 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 k PACCAR objects on the basis that these Interrogatories are argumentative because they assume that a health hazard is created by the PACCAR products that may have incorporated containing component parts which PACCAR denies 1 PACCAR objects to these Interrogatories on the basis that they are vague and ambiguous The 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 m PACCAR objects to these Interrogatories in that they tend to group together all of the defendants in this litigation and are therefore overly broad unduly burdensome harassing and not calculated to lead to the discovery of relevant and material evidence n PACCAR objects to each and every Interrogatory that calls for either pure speculation or legal conclusions on the part of PACCAR for its answers o PACCAR objects to these Interrogatories to the extent that they call for a medical conclusion beyond the scope of PACCAR's knowledge and capability p PACCAR objects to each and every Interrogatory that purports to impose any obligations on it that are not set forth in the Missouri Rules of Civil Procedure q PACCAR objects to these Interrogatories to the extent that they seek information protected by the attorney client privilege or attorney work product doctrine \ r PACCAR objects to these Interrogatories to the extent that they seek 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 s PACCAR objects to these Interrogatories to the extent that they seek information for any period subsequent to Bert Dobson's alleged exposure t PACCAR objects to these Interrogatories to the extent that they seek information that is not under PACCAR's custody or control or which is within the public domain or otherwise equally available to Plaintiff as it is to PACCAR Without waiving any of the foregoing objections PACCAR states as follows PACCAR'S ANSWERS TO INTERROGATORIES INTERROGATORY NO 1 Describe the manner in which the information used to answer these interrogatories was collected by identifying any and all such sources of information relied upon including records or documents reviewed records or documents determined to have been destroyed document retention policies persons providing information and overseeing the process and the person verifying the answers ANSWER PACCAR objects this Interrogatory is overly broad not limited in scope vague and confusing as drafted PACCAR further objects to the extent that this Interrogatory seeks information protected by the attorney privilege the attorney work product doctrine and the consulting expert privilege Subject to and without waiving objection Rod Curbo Product Safety and Compliance Manager for Peterbilt Motors Company has verified these answers and has supplied responsive information Mr.
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