Document Z4ov4yj2KmE90rxDX10KoB6zJ

PLAINTIFFS | EXHIBIT [j i^mi.o __ State the name, present business address, and capacity or title of the' individual signing these Interrogatories on behalf of the answerng defendant. RESPONSE TO INTERROGATORY NO. 1: tion. Jack Palmer, Vice President, Wagner Electric Corpora INTERROGATORY NO. 2: Please state the address of your principal place of business and whether you have assumed the assets and/or liabil ities of any predecessor corporation or entity. Answer these Interrogatories for each such acquired company which manufac tured products containing asbestos. RESPONSE TO INTERROGATORY NO. 2: Wagner Electric Corporation, 100 Misty Lane, Parsip- pany. New Jersey. INTERROGATORY NO. 3: Has defendant, at any time from 1930 to the present, engaged in the manufacture of products containing asbestos fi bers? RESPONSE TO INTERROGATORY NO. 3: No. INTERROGATORY NO. 4: state: If the answer to Interrogatory No. 3 is yes, please (a) Where the asbestos-containing product were manu factured; (b) How long the defendant has manufactured and/or distributed asbestos-containing materials; (c) Whether defendant has supplied manufactured as bestos materials to any other defendant herein since 1930; (d) The dates of the transactions referred to in subsection (c); ABEX 207.850 SCF-ABEX-2845 (e) The compensation paid for the manufactured asbes tos materials; (f) Whether any warnings, cautions, caveats or direc tions accompanied the materials referred to in (c); and (g) The date the warnings, cautions, caveats or di rections referred to in (f) first appeared. RESPONSE TO INTERROGATORY NO. 4: See Wagner's response to Interrogatory No. 3. INTERROGATORY NO. 5: state: If the answer to Interrogatory No. 3 is no, please (a) From what sources has defendant obtained asbes tos-containing products since 1930? (b) Whether any warnings, cautions, caveats or direc tions accompanied the material referred to m 9{a); (c) The nature and extent of said warnings, cautions, aveats or directions accompanying* said asbestos materials. (d) Approximately what date said warnings, cautions, caveats or directions first appears on the manufactured asbestos materials. RESPONSE TO INTERROGATORY NO. 5: See Wagner's response to In terrogatory Nos. 10 and 18. INTERROGATORY NO. 6: Has defendant, at any time from 1930 to the present, engaged in the mining and/or milling of material containing asbestos fibers? RESPONSE TO INTERROGATORY NO. 6: No. INTERROGATORY NO. 7: state: If the answer to Interrogatory No. 6 is yes, please (a) Where the asbestos was mined and milled; bestos; (b) How long the defendant has mined and milled as 3 (c) Whether the defendant has supplied this mined and/or milled asbestos to any defendant herein since 1930; (d) The date of each transactions; (e) The dollar and tonnage amount of each sale; (f) Whether any warnings, cautions, caveats or direc tions accompanied the materials referred to in (c); and (g) The dates any warnings, cautions, caveats or directions referred to in subsection (f) first accompanied de fendant's asbestos-containing products. RESPONSE TO INTERROGATORY NO. 7: See Wagner's response to Interrogatory No. 6. INTERROGATORY NO. 8: state: If your answer to Interrogatory No. 6 is no, please (a) From what sources has defendant obtained mined asbestos since 1930: * (b) Have any warnings, cautions, caveats or direc tions accompanied the material referred to in (a); (c) The nature and extent of the warnings, cautions, caveats or directions referred to in (b); (d) Approximately what date said warnings, cautions, caveats or directions first appeared on the mined asbestos. RESPONSE TO INTERROGATORY NO. 8: See Wagner's reesponse to Interrogatory No. 6. INTERROGATORY NO. 9: Has defendant, at any time from 1930 to the present, engaged in the processing, marketing and/or sale of products containing asbestos fibers? RESPONSE TO INTERROGATORY NO. 9: During Plaintiff's alleged exposure period to brake products, Wagner purchased friction material containing, among other components, asbestos modified by a bonding agent, coating or binder or other materials and assembled this material with 4 1 other, non-asbestos-containing components, into brake shoes. 2 These brake shoes have been distributed and sold nationwide. 3 INTERROGATORY NO. 10: 4 If the answer to Interrogatory No. 3, No. 6 or No. 9 is affirmative, please state as to each affirmative answer: 5 (a) The trade or brand name of each product mined, 6 manufactured, and/or marketed; 7 (b) the dates each product was placed on the market; 8 (c) The dates each product was withdrawn from the market; 9 (d) A description of the chemical composition of each 10 product, including the type of asbestos contained in each such product (i.e., amosite, chrysotile, crocidolite) and the quanti 11 tative percentage of asbestos in each product; 12 (e) A description of the physical appearance of each product; 13 (f) A detailed description of the intended uses of 14 each product; 15 (g) The name of the manufacturers of each product; 16 (h) The mining or milling concern from which the raw asbestos was obtained. 17 RESPONSE TO INTERROGATORY NO. 10: 18 (a) - (b) Wagner friction products have been distrib 19 uted and sold under the following brand names during Plaintiff's 20 alleged exposure period to brake products: 21 Wagner/Wagner Lockheed 1967-1976 22 Wagner - 1976-1983 23 Chatham 1976-1983 24 (c) Wagner has not discontinued assembling, selling 25 or distributing its brake products. 26 (d) Wagner does not know the contents by weight of 27 the friction materials it purchases containing, among other 28 5 1 components, asbestos modified by a bonding agent, coating or 2 binder, or other materials, which are either distributed as 3 lining or assembled with other components, which contain no 4 asbestos, into brake shoes, or disc pad assemblies which are 5 then distributed for use. The percentage composition of these 6 friction materials is information proprietary to Wagner's sup 7 pliers. Wagner has always obtained friction material from manu 8 facturers, who manufacture it according to performance standards 9 specified by Wagner. Wagner's specifications relate only to the 10 performance characteristics and not the composition of the fric 11 tion materials. Wagner further states that, to the best of its 12 knowledge and belief, the only asbestos contained in brake prod 13 ucts is chrysotile. 14 (e) Wagner brakes made for original equipment manu 15 factures consist of the brake shoes, backing plate and other 16 connected apparatus. Wagner brake shoes, lining and disc pads 17 sold as replacement equipment consist of a brake lining or a 18 brake lining attached to a brake shoe or disc pad. 19 (f) As a friction material to slow down and stop 20 moving vehicles. 21 (g) - (h) Wagner does not use raw asbestos in the 22 assembly of its brake shoes or disc pad assemblies, during the 23 period pertinent to this action, Wagner had obtained asbestos- 24 containing friction material from one or more of the following 25 suppliers or their predecessors, among others: 6 27 28 6 1 Abex Corporation 2 Bendix Corporation 3 Brake Rebuilder Corporation 4 Carlisle Corporation 5 Certified, a division of Lear Siegler, Inc. 6 E.P.E. 7. 8 Gnnnell Stamping Co. H.K. Porter Company, Inc. .9 10 11 Johns-Manville Sales Corporation Krasne Corporation Maremont corporation 12 Nuturn Corporation 13 Raybestos-Manhattan, Inc. 14 Reddaway Manufacturing Co., Inc. 15 RoyaL Industries, Inc. 16 Safeguard Automotive Corp. 17 Thiokol Corporation 18 INTERROGATORY NO. 11: 19 Does defendant hold the rights to any patent pertain ing to the products listed m the preceding Interrogatory? 20 RESPONSE TO INTERROGATORY NO. 11: 21 No. 22 INTERROGATORY NO. 12: - 23 If the answer to the preceding interrogatory is affir 24 mative, please state: 25 (a) The number of each patent; <o -CM (b) The date each patent was issued; 27 (c) The number of each patent application that is pending. 28 7 1 RESPONSE TO INTERROGATORY NO. 12: 2 See Wagner's response to Interrogatory No. 11. 3 INTERROGATORY NO. 13; 4 Have any of the products listed in Interrogatory No. 10 above been altered in chemical composition, asbestos type or 5 content since first being marketed. 6 RESPONSE TO INTERROGATORY NO. 13: 7 Wagner has from time to time changed the performance 8 specifications it furnishes its suppliers. Wagner does not know 9 if they have changed the composition of their bonded asbestos- 10 containing materials which they supply to Wagner. 11 INTERROGATORY NO. 14. 12 If the answer to Interrogatory No. 13 is affirmative, please state: 13 (a) The trade name of each product; 14 (b) The date each product was altered; 15 (c) The nature of the alteration; 16 (d) The reason for the alteration. 17 RESPONSE TO INTERROGATORY NO. 14: 18 See Wagner's responses to Interrogatory No. 13. 19 INTERROGATORY NO. 15: 20 Do any written material of any kind or character exist 21 relating to the testing of said products? 22 RESPONSE TO INTERROGATORY NO. 15: 23 Memoranda exist relating to the testing of Wagner 24 brake products to meet performance specifications and to estab 25 lish quality control in the assembly process. 26 INTERROGATORY NO. 16: 27 Did defendant make any design changes as a result of the tests referred to in Interrogatory No. 15? 28 8 1 RESPONSE TO INTERROGATORY NO. 16: 2 Wagner objects to this Interrogatory on the grounds 3 that it is not confined to any relevant time frame, is vague in 4 that it does not define "design changes" and is not confined to 5 the issue in this case or calculated to lead to the discovery of 6 admissible evidence and is therefore overly broad and unduly 7 burdensome. Subject to that objection, Wagner states that there 8 have been changes m its products. 9 INTERROGATORY NO. 17: 10 If the answer to Interrogatory No. 16 is affirmative, please state: 11 (a) The nature of the change made; 12 (b) The name, address, and job classification of each 13 person ordering the change m design. 14 RESPONSE TO INTERROGATORY NO. 17T 15 See Wagner's response to Interrogatory No. 16. 16 INTERROGATORY NO. 18: 17 Has defendant, at any time since 1930, published and /or distributed any brochures, sales literature, pamphlets, or 18 other written materials of any kind that contain any warnings, cautions, caveats or direction concerning the possibility of 19 injury resulting from the use of the products listed in Inter rogatory No. 10 above? If so, identify each brochure sales 20 literature, pamphlet or other written material and the date of publication and distribution. 21 RESPONSE TO INTERROGATORY NO. 18: 22 Wagner has supplied its distributors, mechanics and 23 their employers, and purchasers with the following warnings: 24 1976-present: "CAUTION: CONTAINS ASBESTOS FIBERS. AVOID 25 CREATING DUST. BREATHING ASBESTOS DUST MAY 26 CAUSE SERIOUS BODILY HARM." 27 28 9 1 1977-present: 2 (Wagner Step-by "CAUTION - Brake lining materials contain asbestos fibers. Avoid creating dust when 3 Step Installation removing pads or cleaning caliper and rotor 4 Guide for Brake 5 Disc Pads): areas. The use of a damp rag for cleaning operations will help aviod dust. Breathing 6 asbestos dust may be a potential health 7 hazard." 8 "Clean road dirt from areas over which brake 9 parts must move. Use a damp cloth for 10 cleaning to avoid raising asbestos dust. 11 Dispose of cleaning rags after use." 12 1977-present "CAUTION - Brake lining materials contain 13 (Wagner Step-by 14 Step Installation asbestos fibers. Avoid creating dust when * removing drums and cleaning parts. Breath 15 Guide for Drum ing asbestos dust may be a 16 Brake Shoe and potential health hazard. 17 Lining Sets): "With all the brake parts off the backing 18 plate, clean off the backing place with a 19 damp cloth to avoid raising any asbestos 20 dust." 21 1978-1981 (Wagner 22 Diagnostic Anal "Since the lining materials contain asbestos fibers, avoid creating dust when 23 ysis and Recon removing the drums and cleaning the parts. 24 ditioning Manual).- Breathing asbestos dust may be a potential 25 health hazard. 26 "Clean the backing place and the parts 27 to be reused; wipe with a damp rag to avoid 28 10 ! 1 raising asbestos dust. Breathing asbestos 2 dust may be a potential health hazard." 3 . "CAUTION: Brake lining materials con- 4 tain asbestos fibers. Avoid circulating 5 dust when servicing the brakes. Breathing 6 asbestos dust may be a potential health 7 hazard. 8 INTERROGATORY NO. 19: 9 Has defendant received notice (excluding Workers' Compensation claims) of any person claiming injuries sustained 10 as a result of exposure to abestos-containing products manufac- trued, sold or distributed by it? 11 RESPONSE TO INTERROGATORY NO. 19: 12 Wagner objects to this Interrogatory on the grounds 13 that it seeks information which is not relevant to the subject 14 matter of this action and is not calculated to lead to the dis15 covery of admissible evidence. 16 INTERROGATORY NO. 20: 17 If answer to Interrogatory No. 19 is affirmative. 18 please state: 19 (a) The names of all parties involved in the claim(s); 20 (b) The date defendant received notice of each 21 claim(s); 22 (c) The injuries allegedly sustained by each claim- ant; 23 (d) The court in which each claim was made. 24 RESPONSE TO INTERROGATORY NO. 20: 25 Wagner objects to this Interrogatory on the grounds 26 that it seeks information which is not relevant to the subject 27 28 11 matter of this action and is not calculated to lead to the dis covery of admissible evidence. INTERROGATORY NO. 21: Does defendant have any records indicating that any of its asbestos-contaning products were sold or distributed to any of the defendants named herein? RESPONSE TO INTERROGATORY NO. 21: Wagner objects to this Interrogatory on the grounds that it is overly broad and unduly burdensome m that it does not identify for which Wagner products it seeks information and, is not relevant to the subject matter of this action and is not calculated to lead to the discovery of admissible evidence in that it is not limited to Wagner products to which Plaintiff alleges exposure. INTERROGATORY NO. 22: If answer to Interrogatory No. 21 is affirmative, please state: (a) the name, address, and 30b classification of each individual who currently has possession of such records; (b) The names of each defendant named herein to whom your products have been sold or disributed; (c) The dates of each such sale; uted; (d) the amount and type of materials sold or distrib (e) Whether defendant manufactured asbestoscontaining products for any other business entity but placed labels or logos not belonging to this defendant on said subsec tion. RESPONSE TO INTERROGATORY NO. 22: See Wagner's response to Interrogatory No. 21. INTERROGATORY NO. 23: Does defendant have policies of insurance that cover the claims that have been made by plaintiff herein? 12 RESPONSE TO INTERROGATORY NO. 23: Wagner has product liability insurance coverage which would be applicable were plaintiffs to recover on their claim. Wagner objects to the remainder of this Interrogatory on the grounds that it is not relevant and not calculated to lead to the discovery of admissible evidence pursuant to California Evidence Code, 1155. INTERROGATORY NO. 24: If response to Interrogatory No. 23 is affirmative, please list the name of each insurance carrier referred to in the preceding interrogatory, the amount of such coverage, and the effective dates of each policy? RESPONSE TO INTERROGATORY NO. 24: Wagner objects to this interrogatory on the grounds that it is overly broad, unduly .burdensome and not calculated to lead to the discovery of admissible evidence. INTERROGATORY NO. 25: Is there any dispute as to insurance coverage with respect to claims made by plaintiff? RESPONSE TO INTERROGATORY NO. 25; See Wagner's response to Interrogatory No. 23. INTERROGATORY NO. 26: Does defendant possess knowledge which would enable asbestos-containing products to be manufactured or treated so to eliminate potential health hazards to workers using said products? as RESPONSE TO INTERROGATORY NO. 26: No product can be manufactured or treated as to elimi nate all potential hazards, health or otherwise, associated with its use, since any product can be hazardous if used in an im- 13 1 proper and unforeseeable way. Wagner does not admit that there 2 is any health hazard associated with the use of its products. 3 INTERROGATORY NO. 27; 4 Please describe m detail the type of packages m which defendant has' sold or distributed asbestos-containing 5 material, listing the dates each type of package was used, and a description of any printed material or trademarks that appeared 6 thereon. 7 RESPONSE TO INTERROGATORY NO. 27: 8 Wagner has distributed and sold its aftermarket brake 9 shoes and disc pads in containers and packages of various 10 shapes, sizes, types, and colors, primarily rectangular boxes 11 with red and/or blue lettering against a white background. 12 INTERROGATORY NO. 28: 13 Did defendant receive any reports or communications from any insurance carrier with regard to the hazards incident 14 to the use of asbestos-containing products? If so, please state the name of the person(s) who has possession of said reports, 15 the location of the reports and a summary of the contents of the reports, including the name of each insurance company, its ad 16 dress, and the agent delivering such information. 17 RESPONSE TO INTERROGATORY NO. 28: 18 Wagner objects to this Interrogatory on the grounds 19 that it is irrelevant and is not calculated to lead to the dis- 20 covey of admissible evidence. Subject to that objection, Wagner 21 states that it received no such reports. 22 INTERROGATORY NO. 29; 23 Has any other defendant named herein ever furnished the answering defendant with information as to the state of 24 medical knowledge regarding the connection between asbestos exposure and the development of pulmonary diseases, including 25 cancer and asbestos? 26 RESPONSE TO INTERROGATORY NO. 29: 27 No, to the best of Wagner's knowledge. 28 14 1 INTERROGATORY NO. 30: 2 If the answer to the preceding interrogatory is m the affirmative, please state: q w (a) The nature and content of the information ref4 fered to in the preceding interrogatory; 5 (b) When the defendant was furnished the information; 6 (c) From whom the defendant received the information. 7 RESPONSE TO INTERROGATORY NO. 30: 8 See Wagner's response to Interrogatory No. 29. 9 INTERROGATORY NO. 31: 10 Has any other defendant herein furnished the answered defendant with the results of any research, tests, medical stud- 11 les or experiments regarding any connection between asbestos exposure and the development of pulmonary disease, including 12 lung cancer and asbestosis, since 1930? 13 RESPONSE TO INTERROGATORY NO. 31: * 14 No, to the best of Wagner's knowledge. 15 INTERROGATORY NO. 32: 16 If the answer to the preceding interrogatory is in the affirmative, please state: 17 (a) When the defendant received the above-described 18 information; 19 (b) From whom the defendant received the information; 20 (c) Describe the nature and content of each document or communication. 21 RESPONSE TO INTERROGATORY NO. 32: 22 See Wagner's response to Interrogatory No. 31. 23 INTERROGATORY NO. 33: 24 Please state if the defendant ever conducted, spon25 sored or contributed financially to any research or studies to determine if the inhalation of asbestos fibers may be harmful. 26 If so, please state: 27 (a) By whom the research was conducted; 28 (b) The dates the research or study was conducted; 15 1 (c) The results of the research or study. 2 RESPONSE TO INTERROGATORY NO. 33: 3 Wagner objects to this Interrogatory on the grounds 4 that it is irrelevant and is not calculated to lead to the dis 5 covery of admissible evidence. Subject to that objection, Wag 6 ner states that it conducted no such studies. 7 INTERROGATORY NO. 34; 8 Please state the names, addresses, dates of employment and official title of the defendant's chief medical officers 9 from 1930 until the present. 10 RESPONSE TO INTERROGATORY NO. 34: 11 Wagner has not employed anyone in the position of 12 chief medical officer. 13 INTERROGATORY NO. 35: 14 Please state the name, address, title and dates of employment of the immediate superior(s) of the individual iden 15 tified in the preceding interrogatory. 16 RESPONSE TO INTERROGATORY NO. 35: 17 See Wagner's response to Interrogatory No. 34. 18 INTERROGATORY NO. 36: 19 Please describe m detail the duties and responsibil ities of the defendant's chief medical officer. 20 RESPONSE TO INTERROGATORY NO. 36: 21 See Wagner's response to interrogatory No. 34. 22 INTERROGATORY NO. 37: 23 Please state the names and addresses of all physicians 24 employed, retained or otherwise engaged by the defendant at any of its facilities from the years of 1930 until the present time. 25 26 27 28 16 1 RESPONSE TO INTERROGATORY NO. 37: 2 Wagner objects to this Interrogatory on the grounds 3 that it is overly broad and seeks information outside the plain 4 tiff's alleged period of exposure to asbestos-containing prod 5 ucts. Subject to this objection, Wagner states that during the 6 plaintiff's alleged exposure to asbestos-containing products, 7 Wagner retained physicians for the purpose of examining Wagner's 8 employees. These physicians are: 9 Douglas A. Ries, M.D. (deceased) 10 Curtis A. Meyer, M.D. (deceased) 11 John J. Keenoy, M.D. (deceased) 12 Lance D. Gerowin, M.D. 13 INTERROGATORY NO. 38: 14 Please list the names and addresses of all persons employed by defendant from 1930 until the present time who func 15 tioned as industrial hygienists. (As contemplated by these Interrogatories, an industrial hygienist is one that performs 16 engineering or health studies to identify and evaluate potential occupational health hazards and suggests methods of dealing with 17 same.) Include in your answer to the foregoing: 18 (a) The facility or office to which the individuals were assigned; 19 (b) A detailed description of their duties and re 20 sponsibilities . 21 RESPONSE TO INTERROGATORY NO. 38: 22 Wagner objects to this Interrogatory on the grounds 23 stated in its response to Interrogatory No. 37. Subject to this 24 objection, Wagner states that from 1975 through the end of 25 Plaintiff's alleged exposure period, it has used the consulting 26 industrial hygiene services of John A. Jurgiel, Certified Indus 27 trial hygienist, 2092 Concourse Drive, St. Louis, Missouri for 28 17 its assembling facility and bonding shops. Wagner has never had an industrial hygienist as an employee. INTERROGATORY NO. 39: Please state if the defendant's medical officers or industrial hygienists ever made any recommendations and/or sug gestions to the defendant pertaining to the risks or hazards to persons involved m the manufacturing or use of products con taining asbestos? If so, please state: * (a) Where were such recommendations and/or sugges tions made? (b) To whom were such recommendations and/or sugges tions made? (c) By whom were these recommendations and/or sugges tions made? (d) The substance of the recommendations and/or sug gestions made? RESPONSE TO INTERROGATORY NO. 39: See Wagner's response to interrogatory No. 36. INTERROGATORY NO. 40: Please state the names of trade association periodicals to which defendant subscribed from 1930 to 1972. RESPONSE TO INTERROGATORY NO. 40: Wagner objects to this Interrogatory to the extent it seeks information outside the Plaintiff's alleged exposure peri od. Subject to that objection, Wagner states that it has sub scribed to the perodicals issued by the American Trucking Asso ciation, American Association of Motor Vehicle Administrators, Automotive Warehouse Distributors Association, Motor equipment Manufacturers' Association, Automotive Service Industry Associa tion, Automotive Parts and Accessories Association, and the distributors Institute, among others. 1 INTERROGATORY NO. 41: 2 Please state the names of all organizations, groups, inter-company or industrial organizations that defendant has 3 been a member of which conducted studies or research on the relationship between exposure to asbestos or asbestos-containing 4 products and asbest-osis and lung cancer from 1930 to 1972. 5 RESPONSE TO INTERROGATORY NO. 41: 6 Wagner currently lacks knowledge of whether any orgai- 7 zation to which it belongs conducted such studies. Wagner's 8 investigation continues. 9 INTERROGATORY NO. 42: 10 Please state the name, address and amount spent or contributed by the defendant annually from 1930 until 1972 for 11 research specifically directed to the relationship between expo sure to asbestos-containing products and asbestosis, lung cancer 12 or any other pulmonary disease. 13 RESPONSE TO INTERROGATORY NO. 42: 14 Wagner currently lacks knowledge of whether any orga 15 nization to which it belongs conducted such studies. Wagner's 16 investigation continues. 17 INTERROGATORY NO. 43: 18 Please state the name, address and amount annually cotnbuted by the defendant from 1930 to 1972 to any independent 19 medical research group or groups studying the relationship be tween exposure to asbestos and pulmonary disease. 20 RESPONSE TO INTERROGATORY NO. 43: 21 Wagner currently lacks knowledge of whether any organization to 22 which it belongs conducted such studies. Wagner's investigation 23 continues. 24 INTERROGATORY NO. 44: 25 Please state whether the defendant had a department, 26 division or section devoted to scientific and/or medical re search during the period from 1930 until the present time. 27 28 19 1 RESPONSE TO INTERROGATORY NO. 44: 2 Wagner objects to this Interrogatory to the extent it 3 seeks information outside the plaintiff's alleged exposure peri 4 ods. Subject to that objection, Wagner states that it has per 5 formed scientific research and testing of its brake products 6 specifically directed to improving those products' performance, 7 safety and compliance with performance-related safety regula 8 tions. Wagner has had no department, division or section devoted 9 to medical research during the period stated. 10 INTERROGATORY NO. 45: 11 Please state the scientific or medical periodicals to which the defendant, its medical department or industrial hy 12 giene division subscribed during the period between 1930 and 1972 specifying the date said subscriptions were begun. 13 RESPONSE TO INTERROGATORY NO. 45 < 14 Wagner objects to this Interrogatory to the extent it 15 seeks information outside the Plaintiff's alleged exposure peri 16 od. Subject to that objection, Wagner states that it knows of 17 no such periodicals to which it may have subscribed. Wagner's 18 investigation continues. 19 INTERROGATORY NO. 46: 20 Please state whether any of the distributors of defen 21 dant's asbestos-containing products were provided with any spe cial instructions, oral or written, in regard to utilizing said 22 products in a manner so as to avoid exposing workers to dust. If so, please state: ' 23 (a) When these instructions were given; 24 (b) By whom these instructions were given; 25 (c) Whether the instructions oral or written; 26 (d) The precise content of the instructions; 27 (e) If the instructions were written, please attach a 28 copy of the instructions. 20 1 RESPONSE TO INTERROGATORY NO. 46: 2 (a) - (e) Wagner states that it informs mechanics and 3 their employers that Wagner cam-ground brake shoes were shaped 4 to exact tolerances and should not be ground before application. 5 This procedure eliminated the generation of any airborne asbes 6 tos fiber or other dust which might otherwise result from those 7 grinding operations. Wagner also began m 1976 to teach dis 8 tributors, mechanics and their employers, and others who attend 9 ed Wagner training schools a method of changing and handling 10 brakes which minimizes the level of dust created to minimize the 11 possibility of exposure to free asbestos fiber. Wagner also 12 supplied its distributors, mechanics and their employers, and 13 purchasers with the following warnings: * 14 1976-present: "CAUTION: CONTAINS ASBESTOS FIBERS. AVOID 15 CREATING DUST. BREATHING ASBESTOS DUST MAY 16 CAUSE SERIOUS BODILY HARM." 17 1977-present "CAUTION - Brake lining materials contain 18 (Wagner Step-by 19 Step Installation asbestos fibers. Avoid creating dust when removing pads or cleaning caliper and rotor 20 Guide for Brake 21 Disc Pads): 22 areas. The use of a damp rag for cleaning operations will help avoid dust. Breathing asbestos dust may be a potential health 23 hazard." 24 "Clean road dirt from areas over which brake 25 parts must move. Use a damp cloth for 26 cleaning to avoid raising asbestos dust. 27 Dispose of cleaning rags after use." 28 21 1 1977-present "CAUTION - Brake lining materials contain 2 (Wagner Step-by asbestos fibers. Avoid creating dust when 3 Step Installation removing drums and cleaning parts. Breath 4 Guide for Drum 5 Brake Shoe and ing asbestos dust may be a potential health hazard." 6 Lining Sets): "With all the brake parts off the backing 7 plate, clean off the backing plate with a 8 damp cloth to avoid raising any asbestos 9 dust." 10 1978-1981 (Wagner "Since the lining materials contain 11 Diagnostic Anal asbestos fibers, avoid creating dust when 12 ysis and Recon removing the drums and cleaning the parts. 13 ditioning Manual): Breathing asbestos dust may be a potential 14 health hazard." 15 "Clean the backing plate and the parts 16 to be reused; wipe with a damp rag to aviod 17 raising asbestos dust. Breathing asbestos 18 dust may be a potential health hazard" 19 "CAUTION: Brake lining materials con 20 tain asbestos fibers. Avoid creating dust 21 when servicing the brakes. Breathing asbes 22 tos dust may be a potential health hazard." 23 INTERROGATORY NO. 47: 24 Please state whether any employee of the defendant has ever made a claim for asbestosis under the Occupational disease 25 or Workers' Compensation Statute of any state. If so, include in your answer: 26 (a) The date that the defendant first received notice 27 of any claim for asbestosis under the occupational Disease or Workers' Compensation Statute of any state and state; and 28 22 1 (b) The total number of claims filed for the years 1930 to 1972. RESPONSE TO INTERROGATORY NO. 47: 3 Wagner objects to this Interrogatory on the grounds 4 that it is not relevant and not calculated to lead to the dis 5 covery of admissible evidence. Subject to that objection, Wag 6 ner states that no employee of Wagner has ever been awarded 7 workman's compensation based on an asbestos-related claim. 8 INTERROGATORY NO. 48: 9 Has the defendant ever been a member of the Asbestos 10 Textile Institute ("ATI")? If so, please list the year of mem bership. 11 RESPONSE TO INTERROGATORY NO. 48: 12 No. 13 INTERROGATORY NO. 49: 14 * Please state whether any representative, agent or 15 employee of the defendant corporation was a member of the Air Hygiene Committee of the ATI. If so, please include m your 16 answer a list of the years of membership. 17 RESPONSE TO INTERROGATORY NO. 49: 18 None. 19 INTERROGATORY NO. 50: 20 Please state whether any representative, agent or employee ever attended any meetings of the Air Hygiene Committee 21 of the ATI. 22 RESPONSE TO INTERROGATORY NO. 50: 23 None. 24 INTERROGATORY NO. 51: 25 Please state whether the defendant received copies of transcribed minutes of any committee meetings, general meetings 26 or Board of Director meetings of the ATI and the date said tran scripts were received. 27 28 23 1 RESPONSE TO INTERROGATORY NO. 51: 2 It did not. 3 INTERROGATORY NO. 52: 4 Has the defendant ever been a member of the Industrial Hygiene Foundation ("IHF") or the Industrial Health Foundation. 5 If so, please state the years of membership. 6 RESPONSE TO INTERROGATORY NO. 52: 7 No. 8 INTERROGATORY NO. 53: 9 Please state the name, address and telephone number of any representative, agent or employee of the defendant who was 10 in attendance at the twentieth annual meeting of the IHF in November, 1955, in Pittsburgh, Pennsylvania. 11 RESPONSE TO INTERROGATORY NO. S3: 12 None, to the best of Wagner's knowledge. 13 INTERROGATORY NO. 54: 14 * Please state whether defendant ever received the In 15 dustrial Hygiene Digest published monthly by the HIF. If so, please list the dates of receipt of said publication. 16 RESPONSE TO INTERROGATORY NO. 54: 17 No. 18 INTERROGATORY NO. 55: 19 \ Please state whether defendant ever requested offi 20 cials at the IHF to: 21 (a) Perform a search of the medical literature to determine whether there existed any reported cases of workers 22 with asbestosis and/or lung cancer discussing the potential hazards incident to use of asbestos-containing-products; 23 (b) Perform any studies or research into potential 24 health hazards incident to the use of asbestos-containing prod ucts; 25 (c) Review governmental publications of Great Britain 26 to determine whether any research was conducted by the British Government into potential health hazards associated with the use 27 of products containing asbestos; 28 24 1 (d) Review governmental publications of Great Britain to determine whether the Chief Inspector of Factories or any 2 other British Government agency had issued any regulations or published any findings relative to potential health hazards 3 incident to the use of products containing asbestos. 4 RESPONSE TO INTERROGATORY NO. 55: 5 No, to the best of Wagner's knowledge. 6 INTERROGATORY NO. 56: 7. Has the defendant sponsored, since 1930, any meetings, seminars, conferences, or conventions where the subject of occu 8 pational health and/or exposure to asbestos was discussed? 9 RESPONSE TO INTERROGATORY NO. 56: 10 In its training meetings prior to 1976, instructions 11 on using Wagner products m a manner to avoid exposure to dust 12 were discussed as an incident to stressing the desirability of a 13 clean working environment. In the schools held m 1976 through * 14 the present, minimization of dust creation was discussed in 15 regard to minimizing the workers' potential exposure to free 16 asbestos fiber. 17 INTERROGATORY NO. 57: 18 If the answer to Interrogatory No. 56 is in the affir mative, please state: 19 (a) The date and place of such meeting, seminar, 20 conference or convention; 21 (b) The name and address of the speakers. 22 RESPONSE TO INTERROGATORY NO. 57: 23 Wagner objects to this Interrogatory on the grounds 24 that it is overly broad, unduly burdensome and not calculated to 25 lead to the discovery of admissible evidence. 26 INTERROGATORY NO. 58: 27 Has the defendant ever warned any labor union or its representative of the potential health hazards associated with 28 the use of products containing asbestos? 25 1 RESPONSE TO INTERROGATORY NO. 58: 2 Wagner objects to this Interrogatory on the grounds 3 that it assumes conclusions not established. 4 INTERROGATORY NO. 59: 5 If the answer to the preceding Interrogatory is m the affirmative, state: 6 (a) The name of the union and/or its representative; 7 (b) The date and place of said warning; 8 (c) The content and nature of said warning; 9 (d) The individual giving said warning. 10 RESPONSE TO INTERROGATORY NO. 59: 11 See Wagner's response to Interrogatory No. 58. 12 INTERROGATORY NO. 60: 13 Has the defendant at any time given any advice, publi 14 cation, warning, order, directive, requirement or recommenda tion, written or oral, including by U.S. mail, which purported 15 to advise the users of its asbestos-containing products of the potential health hazards associated with exposure to the asbes 16 tos contents of said products? 17 RESPONSE TO INTERROGATORY NO. 60: 18 Wagner advised Plaintiff and all other potential pur 19 chasers through statements in its service manuals and servicing 20 guides and on its packaging of the possibility of harmful ef 21 fects from exposure to asbestos-containing products during the 22 periods stated in Wagner's response to Interrogatory No. 46. 23 INTERROGATORY NO. 61: 24 State whether defendant has subscribed to or received copies of the Asbestos Worker magazine. If so, please state the 25 dates of subscription or receipt of this magazine. 26 RESPONSE TO INTERROGATORY NO. 61: 27 No. 28 INTERROGATORY NO. 62: 26 1 Please state whether defendant ever subscribed to the Asbestos magazine and list the dates of subscription. 2 RESPONSE TO INTERROGATORY NO. 62; 3 No. 4 INTERROGATORY NO. 63. 5 Please identify all booklets, manuals, journals and 6 publications provided to the recipients of any asbestos- containing products manufactured, sold or distributed by defen 7 dant regarding the proper use and application of products. In clude in your answer the dates said information was provided. 8 RESPONSE TO INTERROGATORY NO. 63: 9 See Wagner's response to Interrogatory No. 46. 10 INTERROGATORY NO. 64: 11 Please identify and describe in detail all tests and 12 experiments conducted by defendant to determine whether or not asbestos contained within its asbestos-containing products would 13 become airborne with normal use Include in your answer the dates, results and conclusions of each test and/or experiment. 14 RESPONSE TO INTERROGATORY NO. 64; 15 Wagner considers its brake products to be inherently 16 safe when properly used. Therefore, Wagner would have no busi 17 ness reason to engage in any study such as suggested by this 18 Interrogatory and has never done so. 19 INTERROGATORY NO. 65: 20 At any time prior to 1972 were any tests or studies 21 conducted or sponsored by defendant to determine: 22 (a) The level of airborne dust or fiber concentration incident to: 23 (i) Arching, sanding, clipping, grind 24 ing or beveling defendant's asbestos-containing prod ucts; 25 (li) Placing the products on/in motor 26 vehicles and other machinery requiring such products; 27 (iii) Tearing down the product during repair and maintenance functions; 28 27 1 (b) Whether long-term (5 years or more) exposure to products containing asbestos below 5 million particles per cubic 2 foot (mppcf) might cause asbestosis or expose the user of said product to an increased statistical risk of developing: 3 (i) Bronchogenic cancer; 4 5 neal); (li) Mesothelioma (pleural or pento- 6 (lii) Gastrointestinal cancer; 7 (iv) Asbestosis. 8 RESPONSE TO INTERROGATORY NO. 65: 9 Wagner considers its brake products to be inherently 10 safe when properly used. Therefore, Wagner would have no busi 11 ness reason to engage in any study such as suggested by this 12 interrogatory and has never done so. 13 INTERROGATORY NO. 66: 14 Was the concentration of the airborne asbestos fibers prior to 1972 at job sites at which defendant's asbestos- 15 containing products were used within the prescribed threshold limit values? If so, state the source of the information and 16 the date said information was obtained. 17 RESPONSE TO INTERROGATORY NO. 66: , 18 Wagner is unable to respond to this Interrogatory due 19 to the lack of a definition of the phrase "threshold limit val 20 ue" and the lack of a description of the application of the 21 threshold limit, value to users of Wagner products. 22 INTERROGATORY NO. 67: 23 Please state the date and source from which defendant received its first notice of threshold limit values ("TLV") 24 pertaining to the concentration of airborne asbestos fibers. 25 26 27 28 28 1 RESPONSE TO INTERROGATORY NO. 67: 2 Wagner is unable to respond to this Interrogatory due 3 to the lack of a definition of the phrase ''threshold limit val 4 ue" and the lack of'a description of the application of the 5 threshold limit value to users of Wagner products. 6 INTERPOGATORY NO. 68; 7 Describe what action was taken by defendant prior to 1972, to determine whether the concentration of airborne asbes 8 tos fibers during normal use, application or repair of its as bestos-containing products was below the TLV. Include in your 9 answer the date the above-described actions were taken by defen dant. 10 RESPONSE TO INTERROGATORY NO. 68; 11 Wagner is unable to respond to this Interrogatory due 12 to the lack of a definition of the phrase "threshold limit 13 value" and the lack of a description of the application of the 14 threshold limit value to users of Wagner products. 15 INTERROGATORY NO. 69: 16 Describe the manner m which defendant recommended 17 that its asbestos-containing products be cut, ground, sawed, beveled, fabricated, mixed and/or prepared for use since 1930 by 18 its users. 19 RESPONSE TO INTERROGATORY NO. 69: 20 Wagner objects to this Interrogatory to the extent 21 that it seeks information outside the plaintiff's alleged expo 22 sure period. Subject to that objection, Wagner states that they 23 began informing mechanics and their employees that Wagner cam- 24 ground brake shoes were shaped to exact tolerances and should 25 not be ground before application. See Wagner's response to 26 Interrogatory No. 46. 27 28 29 1 INTERROGATORY NO. 70: 2 Please state the manner m which the asbestos- containing products manufactured by defendant were arced since 3 1930. . 4 RESPONSE TO INTERROGATORY NO. 70: 5 See Wagner's response to Interrogatory No. 69. 6 INTERROGATORY NO. 71: 7, Is defendant aware of articles authored by W. C. Dres- sen m Public Health Bulletin No. 241 of 1938, establishing 8 threshold limit values for airborne asbestos fibers? If so, when did defendant first learn of the above-mentioned article? 9 RESPONSE TO INTERROGATORY NO. 71: 10 No. 11 INTERROGATORY NO. 72: 12 Please state when defendant obtained any information 13 concerning the likelihood of asbestos being hazardous to one's health. Include m your answer how defendant first obtained 14 this information. 15 RESPONSE TO INTERROGATORY NO. 72: 16 Wagner objects to this Interrogatory on the grounds 17 that it assumes facts not established. Wagner states that it 18 first became aware of the possibility that inhalation of asbes 19 tos fibers may be harmful to the health of brake mechanics in 20 1976. During 1976, Wagner received a letter informing it of 21 this possibility from the United States Government Department of 22 Health, Education and Welfare, from an article in the May 1976 23 issue of Brake & Front End Magazine entitled "Know and under 24 stand the law -- OSHA will soon be around," and from materials 25 received from the National Institute for Automobile Service 26 Excellence, among others. 27 28 30 1 INTERROGATORY NO. 73: 2 Please state whether or not defendant ever maintained a library or collection of medical information pertaining to 3 effects of asbestos upon human health. If so please state: 4 (a) The location of said library or collection, 5 (b) The person(s) who maintained it; 6 (c) The bibliography of medical articles, materials, and ocher reports that are or were a part of said library on 7 said subject, including journals, publications, reports and all memoranda published and received by defendant since 1930. 8 RESPONSE TO INTERROGATORY NO. 73: 9 Wagner has not maintained a library specifically re 10 lating to the effects of asbestos on human health. Articles and 11 other publications on this subject are among the materials main 12 tained by Wagner's labor relations department relating to em 13 ployee health and safety. * 14 INTERROGATORY NO. 74: 15 Please state whether or not any governmental agency 16 has ever written letters of warning to defendant pertaining to the likelihood of injury to persons being exposed to asbestos 17 and asbestos-containing products. 18 RESPONSE TO INTERROGATORY NO. 74: 19 No. 20 INTERROGATORY NO. 75: 21 If the answer to the preceding Interrogatory is affir mative, please state the name and address of the agency, the 22 date of the letters of warning and who possesses a copy of said documents. - 23 RESPONSE TO INTERROGATORY NO. 75: 24 See Wagner's response to Interrogatory No. 74. 25 INTERROGATORY NO. 76: *26 Please state the date defendant received information 27 pertaining to the association between inhalation of asbestos fibers and the development of cancer and asbestosis. Include in 28 your answer to the preceding the source of said information. 31 1 RESPONSE TO INTERROGATORY NO. 76: 2 Wagner objects to this Interrogatory on the grounds 3 that it assumes facts not established. Wagner states that it 4 first became aware of the possibility that inhalation of asbes 5 tos fibers may be harmful to the health of brake mechanics m 6 1976. During 1976, Wagner received a letter informing it of 7 this possibility from the United States Government Department of 8 Health, Education and Welfare, from an article in the May 1976 9 issue of Brake & Front End Magazine entitled "Know and under 10 stand the law -- OSHA will soon be around," and from materials 11 received from the National Institute for Automotive Service 12 Excellence, among others. 13 INTERROGATORY NO. 77: A- 14 Has defendant ever subscribed to or received the Unit ed States Public Health Bulletin service? If your answer is in 15 the affirmative, please state the dates defendant received the Public Health Service Bulletin. 16 RESPONSE TO INTERROGATORY NO. 77: 17 No. 18 INTERROGATORY NO. 78: 19 Please state the date defendant first notified its 20 employees working in manufacturing plants and factories of the need to wear and use respirators. 21 RESPONSE TO INTERROGATORY NO. 78: 22 Wagner employees who assemble brake* shoes or disc pad 23 assemblies at its factory have not worn respirators because the 24 level of airborne asbestos fibers in the factory has been far 25 below the levels at which OSHA requires the use of warnings or 26 respirators. 27 28 32 1 INTERROGATORY NO. 79: 2 Please state the date when defendant first notified users of its asbestos-containing products of the need to wear 3 respirators. 4 RESPONSE TO INTERROGATORY NO. 79: 5 See Wagner's response to Interrogatory No. 46. 6 INTERROGATORY NO. 80: 7 Please state whether or not defendant has ever pub lished any written materials, warning its employees about the 8 potential health hazards of inhaling asbestos by use or exposure to asbestos-containing products of this defendant. If so, 9 please state the date and year that said written materials were distributed to defendant's employees, and the name of the author 10 of the materials. 11 RESPONSE TO INTERROGATORY NO. 80: 12 Wagner objects to this Interrogatory on the grounds 13 that it is not relevant to any i?sue in this lawsuit. 14 INTERROGATORY NO. 81: 15 Does defendant contend plaintiff knew of the dangers of the inhalation of asbestos fibers? If so, please state how 16 plaintiff would have acquired said knowledge. 17 RESPONSE TO INTERROGATORY NO. 81: 18 During the period pertinent to this action, plaintiff 19 knew or should have known not to inhale any dust, fumes, gases 20 or other similar substances which are by-products of the indus 21 trial environment. 22 INTERROGATORY NO. 82: 23 Please state whether any officers, agents, servants or employees of the defendant has ever testified before any govern 24 mental body regarding the potential health hazards of the inha lation of asbestos. If so, please state: 25 (a) When and where such testimony was given; 26 (b) Summary of said testimony; 27 (c) If said testimony was recorded. 28 33 1 RESPONSE TO INTERROGATORY NO. 82: 2 No. 3 INTERROGATORY NO. 83; . 4 Please state the names and addresses of all distribu tors and companies to which the defendant sold or distributed 5 asbestos or asbestos-containing products for the years 1930 to 1972. 6 RESPONSE TO INTERROGATORY NO. 83: 7 Wagner objects to this interrogatory on the grounds 8 that it is overly broad, unduly burdensome, and not calculated 9 to lead to the discovery of admissible evidence and seeks pro 10 prietary business information. 11 INTERROGATORY NO. 84: 12 Please state whether defendant has knowledge of any 13 material which could be or is be^ng used for the same purpose as asbestos. Include in your answer when defendant discovered that 14 said material could be used as a substitute for asbestos. 15 RESPONSE TO INTERROGATORY NO. 84: 16 Metallic and other substances, most combined with 17 asbestos-containing substances, are now being used in brake 18 linings for front disc brake applications on some new vehicles. 19 It was first determined in 1978 that these materials could be 20 used safely for some of the same purposes as asbestos-containing 21 brake lining. However, despite a continuing effort by Wagner, 22 its suppliers, and the friction materials industry to find a 23 substance for asbestos in friction materials, no substance other 24 than asbestos-containing brake lining was available during 25 plaintiff's period of exposure which could produce friction 26 materials that would be safe and conform to applicable safety 27 standards governing brake performance for any drum brake appli- 28 34 1 cation or for disc brake applications predating recent design 2 changes. 3 INTERROGATORY NO. 85: 4 Please state whether this defendant has distributed any catalogs, brochures, pamphlets or other advertising materi 5 als regarding its asbestos-containing products between 1930 and 1972. 6 RESPONSE TO INTERROGATORY NO. 85: 7 Wagner objects to this interrogatory on the grounds 8 that it is overly broad, unduly burdensome and not calculated to 9 lead to the discovery of admissible evidence. 10 INTERROGATORY NO. 86: 11 Does defendant advertise its asbestos-containing prod 12 ucts by any media whatsoever. 13 RESPONSE TO INTERROGATORY NO. 86; 14 Wagner objects to this interrogatory on the grounds 15 that it is overly broad, unduly burdensome and not calculated to 16 lead to the discovery of admissible evidence. 17 INTERROGATORY NO. 87: 18 Please state whether defendant sold any asbestos- containing products to any United States governmental agency 19 between 1930 to 1972. If so: 20 (a) List the name and address of each such agen cy; 21 (b) The dates of each sale; 22 (c) The final government destination of each 23 product sold; 24 (d) The type and serial or model number of prod ucts sold or distributed to said agencies. 25 RESPONSE TO INTERROGATORY NO. 87: 26 Wagner objects to this interrogatory on the grounds 27 that it is irrelevant, is not calculated to lead to the discov- 28 35 1 ery of admissible evidence, and seeks confidential business 2 information which consists of trade secrets. 3 INTERROGATORY NO. 88: 4 Please state whether or not defendant's automotive repair employees, in the course of reparing automobiles, use or 5 have used routers, saws, sanders, grinders, or any type device to shape, form, cut or fabricate asbestos-containing material. 6 RESPONSE TO INTERROGATORY NO. 98: 7 Wagner is not involved in providing automotive repair 8 services. 9 INTERROGATORY NO. 89: 10 If the answer to Interrogatory No. 88 above is affir 11 mative, please state whether any vacuum systems, dust control devices, watering-down systems, or any systems designated to 12 reduce dust m the air were at any time used by defendant's automobile repair employees. 13 R1 ESPON SE-- TO . IN- TERROG ATORY -NO. - 89: 4 14 See Wagner's response to interrogatory No. 88. 15 INTERROGATORY NO. 90: 16 If the answer to Interrogatory No. 89 above is affir 17 mative, please state: 18 (a) The date that such a device was first list ed; 19 (b) The type of system or device used; 20 (c) Whether such a system is presently used by 21 defendants' automobile repair employees. 22 RESPONSE TO INTERROGATORY NO. 90: 23 See Wagner's response to Interrogatory No. 89. 24 INTERROGATORY NO. 91: 25 Please state the name and address of any brake and/or clutch repair facility owned and operated by defendant between 26 the years 1930 and 1983. 27 RESPONSE TO INTERROGATORY NO. 91: 28 None. 36 t 1 INTERROGATORY NO. 92: 2 Please list the automobile repair facilities owned/or operated by defendant that are open to the public. 3 RESPONSE TO INTERROGATORY NO. 92: 4 None. 5 INTERROGATORY NO. 93: 6 Please list the automobile repair facilities owned 7 and/or operated by defendant for the repair of defendant's cor porate vehicles only. 8 RESPONSE TO INTERROGATORY NO. 93: 9 None. 10 INTERROGATORY NO. 94: 11 Please state whether or not on any occasion defendant 12 provided respirators to its automobile repair employees. 13 RESPONSE TO INTERROGATORY NO. 94: 14 See Wagner's response to Interrogatory No. 88. 15 INTERROGATORY NO. 95: 16 If your answer to Interrogatory No. 94 above is affir mative, please state which automobile repair employees were 17 provided with respirators. 18 RESPONSE TO INTERROGATORY NO. 95: 19 See Wagner's response to Interrogatory No. 94. 20 INTERROGATORY NO. 96: 21 Please describe in detail the respirators provided. Include m your answer the dates each type of respirator was 22 used. 23 RESPONSE TO INTERROGATORY NO. 96: 24 See Wagner's response to Interrogatory No. 88. 25 INTERROGATORY NO. 97: 26 Please state whether defendant has ever required its automobile repair employees to have physical examinations at any 27 time during their employment. 28 37 1 RESPONSE TO INTERROGATORY NO. 97: 2 See Wagner's response to Interrogatory No. 88. 3 INTERROGATORY NO. 98: 4 If the answer to the preceding interrogatory is affir mative, please state if the results of any such examination 5 revealed that any employee of defendant developed evidence of asbestosis or other pulmonary disease, including cancer. 6 RESPONSE TO INTERROGATORY NO. 98: 7 - See Wagner's response to Interrogatory No. 97. 8 INTERROGATORY NO. 99: 9 Please state whether defendant has ever been a member 10 of or associated with the Asbestos Research Council of England. 11 RESPONSE TO INTERROGATORY NO. 99: 12 No. 13 INTERROGATORY NO. 100: 14 Please state whether defendant has sold or distributed any asbestos-containing products to English firms or corpora 15 tions for any year between 1930 and 1972. 16 RESPONSE TO INTERROGATORY NO. 100: 17 None. 18 INTERROGATORY NO. 101: 19 Please state whether defendant possessed any ownership interest in any firm or corporation involved in the mining, 20 processing or sale of raw asbestos, any asbestos-containing products which were domiciled, headquartered or doing business 21 in the British Isles for any year from 1930 to 1972. 22 RESPONSE TO INTERROGATORY NO. 101: 23 No. 24 INTERROGATORY NO. 102: 25 Please state whether any business or corporation de scribed above possessed any ownership interest in defendant from 26 1930 to 1972. 27 28 1 RESPONSE TO INTERROGATORY NO. 102: 2 None. 3 INTERROGATORY NO. 103: 4 Please state when the first claim for Workers' Compen sation was filed by any of defendant's automobile repair employ 5 ees or factory workers in which it was alleged that said claim ant had developed: 6 (a) Asbestosis; 7 (b) Lung cancer; 8 (c) Mesothelioma 9 For each such claimant, list the date the claim was filed, the 10 claimant's name and the state m which the claim was filed. 11 RESPONSE TO INTERROGATORY NO. 103: 12 See Wagner's response to Interrogatory No. 47. 13 INTERROGATORY NO. 104: 14 Please state whether the defendant entered into any agreements with any British or German concerns which manufac- 15 tured asbestos-containing products from 1930 to 1972. 16 RESPONSE TO INTERROGATORY NO. 104: 17 No. 18 INTERROGATORY NO. 105: 19 If the answer to the above interrogatory is affirma tive, please list: 20 (a) The name, address and phone number of each 21 such British or German concern; 22 (b) The year the agreement was entered into and the date said agreement terminated; 23 (c) The products exchanged or involved in said 24 agreement, including: 25 (i) The percent composition of asbestos; 26 (n) The intended use of the products; 27 (iii) Whether the products were marketed in the United States 28 39 1 RESPONSE TO INTERROGATORY NO. 105: 2 See Wagner's response to Interrogatory No. 104. 3 INTERROGATORY NO. 106: 4 Please state whether the defendant at any time between 1930 and 1972 had an International Division. 5 RESPONSE TO INTERROGATORY NO. 106: 6 Wagner objects to this Interrogatory on the grounds 7 that it is overly broad, unduly burdensome and not calculated to 8 lead to the discovery of admissible evidence. 9 INTERROGATORY NO. 107: 10 If the answer to the preceding interrogatory is affir 11 mative, please state when the International Division was created and where it has been headquartered from its inception. 12 RESPONSE TO INTERROGATORY NO. 107: 13 Wagner objects to this .Interrogatory on the grounds 14 that it is overly broad, unduly burdensome and not calculated to 15 lead to the discovery of admissible evidence. 16 INTERROGATORY NO. 108: 17 Please state whether the defendant has ever had a 18 division which exported raw asbestos or asbestos-containing products. If so, please state whether said division supplied 19 any British manufacturer of motor vehicles or machinery products with any component parts which contained asbestos between the 20 years 1930 and 1972. 21 RESPONSE TO INTERROGATORY NO. 108: 22 See Wagner's response to Interrogatory No. 3. 23 INTERROGATORY NO. 109: 24 Please stae whether defendant sold or distributed any asbestos-containing products to any British repair business or 25 entity engaged in mechanical repair, or distribution of this defendant's asbestos-containing mechanical parts for the years 26 1930 to 1972. 27 RESPONSE TO INTERROGATORY NO. 109: 28 No, to the best of Wagner's knowledge. 40 1 INTERROGATORY NO. 110: 2 Please list the names and addresses of all insurance carriers which provided Worker's Compensation coverage for occu 3 pational diseases for defendant's employees, including automo bile repair employees, between the years 1930 and 1972. 4 RESPONSE TO INTERROGATORY NO. 110; 5 Wagner objects to this Interrogatory on the grounds 6 that it is overly broad, unduly burdensome and not calculated to 7 lead to the discovery of admissible evidence. 8 INTERROGATORY NO. Ill: 9 At any time during the period 1948 to 1978, has defen 10 dant manufactured automobile undercoat sealer' If so, please state: 11 (a) the trade or brand name(s) under which the undercoat sealer was marketed, 12 (b) the years during which the undercoat sealer, 13 under each trade or brand name, was manufactured; 14 (c) the dates each product listed in (a) was Withdrawn from the market; 15 (d) the quantitative percentative of each chemi 16 cal component of the undercoat sealer under each trade or brand name; 17 (e) if asbestos was included in the composition 18 of the undercoat sealer which you manufactured under any trade or brand name, please state: 19 (i) The type of asbestos fiber 20 (i.e., amosite, chrysotile, crocidolite) used in the undercoat sealer under each 21 trade or brand name; 22 (li) The quantitative percentage of asbestos fiber used in the undercoat sealer 23 under each trade or brand name; 24 (iii) The years during which asbestos fiber was included in the composition of the 25 undercoat sealer under each trade or brand name; 26 (f) the location of the facility (facilities) 27 where the undercoat sealer was manufactured. 28 41 1 RESPONSE TO INTERROGATORY NO. Ill: 2 Wagner has never manufactured automobile undercoat 3 sealer. 4 INTERROGATORY NO. 112: 5 At any time during the period 1948 to 1978, has defen dant distributed automobile undercoat sealer? If so, please 6 state: (a) the trade or brand name(s) under which the 7 undercoat sealer was marketed; 8 (b) the years during which the undercoat sealer, under each trade or brand name, was distributed; 9 (c) the dates each product was withdrawn from 10 the market, if such is the case; 11 (d) the quantitative percentage of each chemical component of the undercoat sealer under each trade or 12 brand name; 13 (e) if asbestos was included m the composition of the undercoat sealer which you distributed under 14 any trade or brand name, please state; 15 (l) The type of asbestos fiber (i.e., amosite, chrysotile, crocidolite) 16 used m the undercoat sealer under each trade or brand name; 17 (n) The quantitative percentage of 18 asbestos fiber used m the undercoat sealer under each trade or brand name; 19 (iii) The years during which asbestos 20 fiber was included in the composition of the undercoat sealer under each trade or brand 21 name; 22 RESPONSE TO INTERROGATORY NO. 112; 23 Wagner has never manufactured automobile undercoat 24 sealer. 25 INTERROGATORY NO. 113: 26 Identify all distributors of defendant's automobile undercoat sealer m and for the State of California, and for 27 each distributor, state: 28 42 1 (a) the date(s) defendant's automobile undercoat sealer was sold or delivered to said distributor; 2 (b) the quantity and type, including trade or 3 brand name'(s) of defendant's automobile undercoat sealer sold or delivered to said distributor. 4 RESPONSE TO INTERROGATORY NO. 113: 5 See Wagner's response to Interrogatory No. 111. 6 INTERROGATORY NO. 114: 7 Has defendant directly or indirectly sold or distrib 8 uted its automobile undercoat sealer to any of the following: 9 (a) Chrysler-Plymouth Corp.; (b) Ford Motor Company; 10 (c) General Motors; (d) American Motors; 11 (e) Nissan Motors; (f) Mitsubishi Motor Car Division; 12 (g) Volkswagon; (h) British Leyland; 13 (i) Sears & Roebuck. 14 RESPONSE TO INTERROGATORY NO. 114: 15 See Wagner's response to Interrogatory No. 111. 16 INTERROGATORY NO. 115: 17 If your answer to any part of Interrogatory No. 114 is affirmative, include as a part of your answer: 18 (a) the date(s) during which defendant's automo 19 bile undercoat sealer was sole or distributed to each entity; 20 (b) the quantity and type, including trade or 21 brand name, of defendant's automobile undercoat sealer sold or distributed to each entity; 22 (c) the identity of each employee or ex-employee 23 having knowledge of the sales and distributions to each entity. 24 RESPONSE TO INTERROGATORY NO. 115: 25 See Wagner's response to Interrogatory No. 114. 26 INTERROGATORY NO. 116: 27 Does defendant have or posses any data or information 28 regarding any shipments, sales or distributions of automobile 43 1 undercoat sealer by a manufacturer or distributor other than itself, to any of the following entities: 2 (a) Chrysler-Plymouth Corp.; 3 (b) Ford Motor Company; (c) General Motors; 4 (d) American Motors; (e) Nissan Motors; 5 (f) Mitsubishi Motor Car Division; (g) Volkswagon; 6 (h) British Leyland; (i) Sears & Roebuck. 7 RESPONSE TO INTERROGATORY NO. 116: 8 See Wagner's response to Interrogatory No. 111. 9 INTERROGATORY NO. 117: 10 If the answer to any part of Interrogatory No. 116 is 11 affirmative, please state: 12 (a) the identities of each manufacturer or dis tributor and the above-named entity which received the 13 automobile undercoat sealer; 14 (b) the date(s) of each shipment, sale or dis tribution of automobile undercoat sealer for which 15 defendant has data or information; 16 (c) the quantity and type, including trade or brand name, of the automobile undercoat sealer 17 shipped, sold or distributed to each of the above- named entities. 18 RESPONSE TO INTERROGATORY NO. 117: 19 See Wagner's response to Interrogatory No. 116. 20 INTERROGATORY NO. 118: 21 At any time during the period 1948 to 1978, has defen 22 dant manufactured automobile brake linings or brake assemblies? If so, please state: 23 (a) the trade or brand name(s) under which the 24 brake linings or brake assemblies were marketed; 25 (b) the years during which the brake linings or brake assemblies, under each trade or brand name, were 26 manufactured; 27 (c) the date each product was withdrawn from the market, if such is the case; 28 44 1 (d) the quantitative percentage of each chemical component of the brake linings under each trade or 2 brand name; 3 (e) if asbestos was included m the composition of the brake linings which defendant manufactured 4 under any trade or brand name, please state: 5 (l) The type of asbestos fiber (i.e., amosite, chrysotile, crocidolite) used m the brake lin 6 ings under each trade or brand name; 7 (ii) The quantitative percentage of asbestos fiber used in the brake linings under each trade 8 or brand name; 9 (m) The years during which asbestos fiber was included m the composition of the brake linings 10 under each trade or brand name; 11 RESPONSE TO INTERROGATORY NO. 118: 12 See Wagner's response to Interrogatory No. 9. 13 INTERROGATORY NO. 119: 14 At any time during the period 1948 to 1978, did defen dant distribute automobile brake linings or brake assemblies? 15 If so, please state: 16 (a) the trade or brand name(s) under which the brake linings or brake assemblies were marketed; 17 (b) the years during which the brake linings or 18 brake assemblies, under each trade or brand name, were manufactured; 19 (c) the date each product was withdrawn from the 20 market, if such is the case; 21 (d) the quantitative percentage of each chemical component of the brake linings under each trade or 22 brand name; 23 (e) if asbestos was included in the composition of the brake linings which defendant manufactured 24 under any trade or brand name, please state: 25 (l) The type of asbestos fiber (i.e., amosite, chrysotile, crocidolite) used in the brake lin 26 ings under each trade or brand name; (n) The quantitative percentage of asbestos fiber used in the brake linings under each trade or brand name; 45 1 (in) The years during which asbestos fiber was included m the composition of the brake linings 2 under each trade or brand name; 3 RESPONSE TO INTERROGATORY NO. 119. 4 (a)-(b) See Wagner's response to Interrogatory No. 5 10(a)-(b). 6 (c) See Wagner's response to Interrogatory No. 10(c). 7 (d) -(e) See Wagner's response to Interrogatory No. 8 10(d)-(e). 9 (f) Wagner brake products have been assembled at 10 various bonding shops throughout the country. 11 INTERROGATORY NO. 120: 12 Identify all distributors of defendant's automobile brake linings or brake assemblies in and for the State of Cali 13 fornia, and for each distributor, state: * 14 (a) the date(s) defendant's automobile brake linings or brake assemblies were sold or delivered to 15 said distributor; 16 (b) the quantity and type, including trade or brand name(s), of defendant's automobile brake linings 17 and brake assemblies sold or delivered to said dis tributor. 18 RESPONSE TO INTERROGATORY NO. 120: 19 Wagner objects to this interrogatory on the grounds 20 that it is overly broad, unduly burdensome and not calculated to 21 lead to the discovery of admissible evidence and seeps propri 22 etary business information. 23 INTERROGATORY NO. 121: 24 Has defendant directly or indirectly sold or distrib 25 uted its automobile brake linings or brake assemblies to any of the following: 26 (a) Chrysler-Plymouth Corp.; 27 (b) Ford Motor Company; (c) General Motors; 28 (d) American Motors; 46 1 (e) Nissan Motors, (f) Mitsubishi Motor Car Division; 2 (g) Volkswagon; (h) British Leyland; 3 (i) Sears & Roebuck. 4 RESPONSE TO INTERROGATORY NO. 121: 5 Wagner objects to this interrogatory on the grounds 6 that it is overly broad, unduly burdensome and not calculated to 7 lead to the discovery of admissible evidence and seeks propri 8 etary business information. 9 INTERROGATORY NO. 122: 10 If the answer to any part of Interrogatory No. 123 is affirmative, please: 11 (a) state the date(s) during which defendant's 12 automobile brake linings or brake assemblies were sold or distributed to each entity; 13 (b) state the quantity and type, including trade 14 or brand name, of defendant's automobile brake linings or brake assemblies sold or distributed to each enti 15 ty; 16 (c) identify and produce all documents relating to the sale of defendant's automobile brake linings or 17 brake assemblies to each entity; 18 (d) identify each person within defendant's company having knowledge of sales and distributions to 19 each entity. 20 RESPONSE TO INTERROGATORY NO. 122: 21 See Wagner's response to Interrogatory No. 123. 22 INTERROGATORY NO. 123: 23 Does defendant have or possess any data or information regarding any shipments, sales or distributions of automobile 24 brake linings or brake assemblies by a manufacturer or distribu tor, other than itself, to any of the following entities: 25 (a) Chrysler-Plymouth Corp.; 26 (b) Ford Motor Company; (c) General Motors; 27 (d) American Motors; (e) Nissan Motors; 28 (f) Mitsubishi Motor Car Division; 47 1 (g) Volkswagon; (h) British Leyland; 2 (i) Sears & Roebuck. 3 RESPONSE TO INTERROGATORY NO. 123: 4 No. 5 INTERROGATORY NO. 124: 6 If the answer to any part of Interrogatory No. 123 is affirmative, please state: 7 (a) the identities of each manufacturer or dis 8 tributor and the above-named entity which received the automobile brake linings or brake assemblies; 9 (b) the date(s) of each shipment, sale or dis 10 tribution of automobile brake linings or brake assem blies for which defendant has data or information; 11 <c) the quantity and type, including trade or 12 brand name, of the automobile brake linings or brake assemblies shipped, sold or distributed to each of the 13 above-named entities; 14 (d) identify each person within defendant's company having knowledge of sales and distributions to 15 each entity. 16 RESPONSE TO INTERROGATORY NO. 124: 17 See Wagner's response to Interrogatory No. 123. 18 INTERROGATORY NO. 125: 19 At any time during the period 1948 to 1978, did defen dant manufacture automobile body filler. If so, please state: 20 (a) the trade or brand name(s) under which the 2i automobile body filler were marketed; 22 (b) the years during which the automobile body filler, under each trade or brand name, was manufac 23 tured; 24 (c) the date each product was withdrawn from the market, if such is the case; 25 (d) the quantitative percentage of each chemical 26 component of the automobile body filler manufactured under each trade or brand name; 27 28 48 (e) if asbestos was included m the composition of the automobile body filler which defendant manufac tured under any trade or brand name, please state: (1) The type of asbestos fiber (i.e., amosite, chrysotile, crocidolite) used in the automobile body filler under each trade or brand name; (li) The quantitative percentage of asbestos fiber used m the automobile body filler under each trade or brand name; ' (m) The years during which asbestos fiber was included in the composition of the automobile body filler under each trade or brand name; RESPONSE TO INTERROGATORY NO. 125: Wagner does not manufacture or distribute automobile body filler. INTERROGATORY NO. 126: At any time during the period 1948 to 1978, did defen dant distribute automobile body filler? If so, please state: (a) the trade or brand name(s) under which the automobile body filler were marketed; (b) the years during which the automobile body filler, under each trade or brand name, was distribut ed; (c) the date each product was withdrawn from the market, if such is the case; (d) the quantitative percentage of each chemical component of the automobile body filler manufactured under each trade or brand name; (e) if asbestos was included in the composition of the automobile body filler which defendant distrib uted under any trade or brand name, please state: (i) The type of asbestos fiber (i.e., amosite, chrysotile, crocidolite) used in the automobile body filler under each trade or brand name; (ii) The quantitative percentage of asbestos fiber used in the automobile body filler under each trade or brand name; (ni) The years during which asbestos fiber was included m the composition of the automobile body filler under each trade or brand name; RESPONSE TO INTERROGATORY NO. 126: See Wagner's response to Interrogatory No. 125. INTERROGATORY NO 127: Identify all distributors of defendant's automobile body filler in and for the State of California, and for each distributor, state: (a) the date(s) defendant's automobile body filler was sold or delivered to said distributor; (b) the quantity and type, including trade or brand name(s), of defendant's automobile body filler sold or delivered to said distributor. RESPONSE TO INTERROGATORY NO. 127: See Wagner's response to Interrogatory No. 125. INTERROGATORY NO. 128: ` Has defendant directly or indirectly sold or distrib uted its automobile body filler to any of the following: (a) Chrysler-Plymouth Corp.; (b) Ford Motor Company; (c) General Motors; (d) American Motors; (e) Nissan Motors; (f) Mitsubishi Motor Car Division; (g) Volkswagon; (h) British Leyland; (i) Sears & Roebuck. RESPONSE TO INTERROGATORY NO. 128: See Wagner's response to Interrogatory No. 125. INTERROGATORY NO. 129: If defendant's answer to any part of Interrogatory No. 128 is affirmative, please: (a) state the date(s) during which defendant's automobile body filler was sold or distributed to each entity; 1 (b) state the quantity and type, including trade or brand name, of defendant's automobile body filler sold or distributed to each entity; 3 (c) identify and produce all documents relating to the sale of defendant's automobile body filler to 4 each entity; 5 (d) identify each person within defendant's company having knowledge of sales and distributions to 6 each entity. 7 RESPONSE TO INTERROGATORY NO. 129: See Wagner's response to Interrogatory No. 129. 9 INTERROGATORY NO. 130: 10 Does defendant have or possess any data or information regarding any shipments, sales or distributions of automobile 11 body filler by a manufacturer or distributor, other than itself, to any of the following entities.- 12 (a) Chrysler-Plymouth Corp.; 13 (b) Ford Motor Company; (c) General Motors; * 14 (d) American Motors; (e) Nissan Motors; 15 (f) Mitsubishi Motor Car Division; (g) Volkswagon; 16 (h) British Leyland; (i) Sears & Roebuck. 17 RESPONSE TO INTERROGATORY NO. 130: 18 No. 19 INTERROGATORY NO. 131: 20 If the answer to any part of Interrogatory No. 130 is 21 affirmative, please state: 22 (a) the identities of each manufacturer or dis tributor and the above-named entity which received the 23 automobile body filler; 24 (b) the date(s) of each shipment, sale or dis tribution of automobile body filler for which defen 25 dant has data or information; 26 (c) the quantity and type, including trade or brand name, of the automobile body biller shipped, 27 sold or distributed to each of the above-named enti ties; 28 51 RESPONSE TO INTERROGATORY NO 131: See Wagner's response to Interrogatory No. 131. 4DATED: fy* , 1984 SKADDEN, ARPS, SLATE, MEAGHER & FLOM ERIC S. WAXMAN By: Attorneys for Defendant Wagner Electric Corporation 52 VERIFICATION STATE OF CALIFORNIA, COUNTY OF l have read the foregoing-------------------- and know its contents. 03 CHECK APPLICABLE PARAGRAPH I am a party to this action. The matters stated in it are true of my own knowledge except as to those matters which are stated on information and belief, and as to those matters I believe them to be true. I am G an Officer a partw-r G ______________ of---------------------------------------------- a party to this action, and am authorized to make this verification for and on its behalf, and I make this venflcauon for that reason. I have read the foregoing document and know its contents. The matters stated in it are true of my own knowledge except as to those matters which are stated on information and belief, and as to those matters I believe them to be true. I am one of the attorneysfnr -- -- -- -- a party to this action. Sucn party is absent from the county of aforesaid where such attorneys have their offices, and I make this verification for and on behalf of that party for that reason. 1 have read the foregoing document and know its contents. I am informed and believe and on that ground allege that the matters stated in it are true. Executed nn 19___ , at... ..... - .Califomia- I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. ACKNOWLEDGMENT OF RECEIPT OF DOCUMENT (other than summons and complaint) Signature Received copy of document described as. oiu---------------------------------------------------------------------- 19-------- PROOF OF SERVICE Signature STATE OF CALIFORNIA. COUNTY OF LOS ANGELES t am employed in the county of_______ Los Angeles State of California. t am over the age of 18 and not a party to the within action; my business address ik-- 515 South Figueroa Street, Los Angeles, California 90071 On. September 4 J9J, I served the foregoing document described at WAGNER ELECTRIC CORPORATION'S ANSWERS TO INTERROGATORIES PROPOUNDED BY THE PLAINTIFF _cn_ all Interested parties in this action by placing a true copy thereof enclosed in a sealed envelope with postage thereon fully prepaid in the United States mail 515 South Fiaueroa Street, Los Angeles, Claiforma 90071 addressed as follows: See Attached List e (BY MAIL) I caused such envelope with postage thereon fully prepaid to be ptaced in the United States mail al_ , --Log Angolas......... . California. (BY PERSONAL SERVICE) 1 -caused such envelope to be delivered by hand to the ofTices of the addressee. Executed an Popt-Pmhor & _. . at____Lns Angplps . California. Q (State) I declare under penalty of perjury under the taws of the State of California that the above is true and correct, g (Federal) I declare that I am employed in the office of a member of the bar of this court at whose direction the service was made. Qu. EASS, 5ERRY 4 SIMS 1st American Center Nashville, TN 37238 BOOTH, MITCHELL, STRANGS & SMITH Thirtieth Floor Equitable Plaza ' * 3435 Wilshire Boulevard - Los Angeles, California 90010 \ BRONSON, BRONSON i McKINNON J?_ 0_ Box 7358 ' . San Francisco, CA 94120 `^CLINNIN, SIRACUSE & BELCHER Suite 910 700 South Flower Street .Los Angeles, CA 90017 COTSIN, COLLINS, KOLTS & FRANSCELL Suite 1300 550 South Hill Street . Los Angeles, CA '90013 ' .GIBSON, DONN & CRUTCHER Attentionr Don Howarth, 333 South Grand Avenue Los Angeles, CA 90071 Esq. * GRACE, NEUMEYER & OTTO, INC. Wilshire Center Law Building S25 South New Hampshire Avenue Los Angeles, CA 90005 HARRINGTON, FOXX, DUBROW & CANTER ' Suite 703 '' ' One Wilshire Building Los Angeles, CA 90017 EARRIS & MACAOLEY Harbor Bouse 4500 Via Marina . Marina Del Rey, CA 90291 . HILL,* GENSON, EVEN, CRANDALL & WADE . 505 Shatto Place . ' Los Angeles, CA 90020 ILLSINGER &' COSTANZO Seventh Floor 3055 Wilshire Boulevard Angeles, CA 90010 IRSFEL^, IRSFE1D & YCCNGSR Suite 1011 7060 Hollywood Boulevard Los Angeles, CA 90028 KINKLE, RODIGER & SPRIGGS 621 Sunset Boulevard Los Angeles, CA 90017 KINSSLLA, BOSSCH, FUJIKAWA & TOWLE Suite 1690 1875 Century Park East Los- Angeles, CA 90067 KNAPP, PETERSEN' & CLARKE ' 70 Universal City Plaza Universal City, CA 91608 LTLLICZ, McHOSS & CHARLES 707 Wilshire Boulevard Los Angeles, CA 90017 - McCUTCHZN, BLACK, VERLEGER SHEA ' 600 Wilshire Boulevard Los Angeles, CA 90017 - MEYERS, 3IANC3I, McCONNSLL & MALLON Suite 206 12301 Wilshire Boulevard Los Angeles, CA 90025 ~ MILLARD, STACK & STEVENS Suite 300 707 Wilshire Boulevard Los Angeles, CA 90017 SPRAY, GOULD & BOWERS Attention: Thomas E. Ott, Esq. Suite 1100 3550 Wilshire Boulevard Los Angeles, CA 90G10 PATRICIA A. BEAMAN, ESQ. SKADDEN, ARPS, SLATE, MEAGHER &. FLGM 515 South Figueroa Street Los Angeles, California 90071 1 LA FOLLETTE, JOHNSON, SCHROETER 2 &'DEHAAS Attn: Brian W. Aherne, Esq. 320 North Vermont Ave. 3 Los Angeles, CA 90004 4 MARTIN 4 STAMP Attn: Lloyd V. Stamp, Esq. 5 110 Pine Avenue, Suite 820 6 Long Beach, CA 90802 McHALE & CONNOR 7 Attention: J. A. Connor, Esq. 626 Wilshire Blvd., Suite S00 8 Los Angeles, CA 90017 9 MCKAY & BYRNE Attention: J. P. McKay, Esq. 10 3250 Wilshire Blvd., Suite 603 n Los Angeles, CA 90010 MORGAN, WENZEL & MeNICHOLAS 12 Attn: D. J. Sinclitico, Esq. 1545 Wilshire Blvd., Suite 800 13 Los Angeles, CA 90017 14 NORBY & BRODEUR Attention: J. W. Norby, Esq. 15 21535 Hawthorne Boulevard Torrance, CA 90503 16 OVERTON, LYMAN & PRINCE 17 550 South Flower Street Los Angeles, CA 90071 18 PAUL, HASTINGS, JANOFSKY 19 & WALKER Attention: D. C. Conroy, Esq. 20 555 South Flower Street Los Angeles, CA 90025 21 SCHELL & DELAMER - 22 Attn: F. B. Belanger, Esq. 3333 Wilshire Blvd., Suite 500 23 Los Angeles, CA 90010 24 i SHIELD & SMITH . I 'Attention: J. L. Judy, Esq. 258 1200 Wilshire Blvd., Suite 400 I Los Angeles, CA 90017 261 ' | SKYLIE & SELMAN 27 j Suite 1610 I 1875 Century Park East 28 8 Los Angeles, CA 90067 STEARNS & NELSON Attention: Rolf E. Teuber, 1800 N. Highland Ave., Suite Los Angeles, CA 90028 YUSIM, STEIN & HANGER Attn: Andrew D. Stein, Esq. 8383 Wilshire Blvd., Suite 330 Beverly Hills, CA 90211 in ui I ADAMS, DUQUE & HAZELTINE Attention: Jerald R. Cochran, Esq. 523 West Sixth Street, Suite 1000 Los Angeles, CA 90014 BALL, HUN?, HART, BROWN 6 BAERWITZ Attention: Steven Greenfield, Esq. 450 North Roxbury Drive Beverly Bills, CA 90210 LAW OFFICES OF JOSEPH BOGAN . 230 North Maryland Boulevard, Suite 107 Glendale, CA 91203 CAPLAN & OVERLANDER Attention: T. F. Overlander. Esq. 727 West Seventh Street, Suite 255 Los Angeles, CA 90017 CHASE, ROTCHFORD, DRUKKER & BOGUST Attention:. Vincent Fish, Esq. 700- South Flower Street Suite 500 Los Angeles, California 90017 COYLE, MARRONE & ROBINSON * Attention: Richard B. Coyle, Esq. 3356 Barham Boulevard Los Angeles, CA 90068 JAMES . CUSICK, ESQ. 4201 Wilshire Blvd. Los Angeles, CA 90010 GIBSON, DUNN & CRUTCHER Attention: Charles Ivi&, 333 South Grand Avenue Los Angeles, CA 90071 Esq. GIBSON, DUNN & CRUTCHER Attention: Gary Justice, Esq. 333 South Grand Avenue Los Angeles, CA 90071 HALL, SMALL, BURNS & PALUMBO Attention: Richard Hall, Esq. 5939 Monterey Road Los Angeles, CA 90042 .-Ruston & Nance ..........................- -- . Ill Fashion Lane ________ _____ Tttstin. CA 92660 .. Attn: ~ Joan Spurney,' Esq. .. 1 David A. Gifford, Esq. ERICKSEN. ARBUTHNOT, MCCARTHY, KEARNEY & WALSH, INC. 535 Mira Vista Avenue Oakland, CA 94607 Attorneys for Defendant Ford Motor Company Re a m . Tr a in & Ro sko ph k PASINrmMt* iMriUOtNOPHOrCMKJNAl COAOOMAIlO fM ATTORNEYS at la w 7 9 9 PACE MILL ROAD SUITE B IOO 5 John Krebs, Esq. PARICHAN. RENBERG, CROSSMAN & HARVEY 6 2350 W. Shaw Avenue, Suite 130 Fresno^ CA 93795 7 Attorneys for Defendant General Motors 6 Robert M. Thompson, Esq. THOMPSON & MICHEL 3500 American River Drive 10 Sacramento, CA 95825 Attorneys for Defendant n Lear Siegler * 12 * 13 Is u. 5 14 5? u 15 2s < 0wa< 16 17 Holly Helmuth, Esq. ARMOUR, ST. JOHN, WILCOX ic GOODIN 505 Sansome Street, Suite 900 San Francisco, CA 94111 Attorneys for Defendant Maremont 18 19 20 21 22 23 24 25 26 27 28