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Crane Company

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PETER B. LOGAN (State Bar No. 083652) WRIGHT, ROBINSON, OSTHIMER& TATUM 44 Montgomery Street, 18th Floor San Francisco, California 94104-4705 Telephone: (415) 391-7111 Telefax: (415) 391-8766 Attorneys for Defendant CRANE CO.
CALIFORNIA SUPERIOR COURT CITY AND COUNTY OF SAN FRANCISCO
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INRE: COMPLEX ASBESTOS LITIGATION
~ No. 828684
) CRANE CO.'S RESPONSES ) TO PLAINTIFFS'
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PROPOUNDING PARTIES: RESPONDING PARTY: SET NUMBER: Plaintiffs
)
STANDARD INTERROGATORIES
Defendant CRANE CO. General Order No. 129 Interrogatories (Exhibit I)
Pursuant to General Order No. 129, defendant Crane Co. responds to the Plaintiffs' Standard Interrogatories as follows:
GENERAL OBJECTIONS A. Crane Co. objects to any Standard Interrogatory that purports to impose upon
Crane Co. any obligations not expressly set forth in the California Code of Civil Procedure and San Francisco Superior Court General Order No. 129. B. Crane Co. objects to Plaintiffs' Standard Interrogatories to the extent that they
request information and/or documents that are protected by any privilege or protection, including
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but not limited to the attorney-client privilege, the joint-defense privilege and the work product doctrine. Crane Co. and its counsel hereby assert all applicable privileges and protections with respect to such information and/or documents .. C. Crane Co. objects to Plaintiffs' Standard Interrogatories, because they have been
propounded indiscriminately upon every defendant without any attempt to tailor them to any individual defendant. As such, said Interrogatories are vague, ambiguous, overbroad and unduly burdensome. D. Crane Co. objects to Plaintiffs' Standard Interrogatories, because they seek
information that is irrelevant and/or immaterial and which is not reasonably calculated to lead to the discovery of admissible evidence in this action. E. Crane Co. objects to Plaintiffs' Standard Interrogatories, because plaintiffs have
failed to identify any Crane Co. products to which plaintiffs were exposed. Without any identification by plaintiffs of specific products, Crane Co. cannot adequately determine which Interrogatories are proper and relevant to these action:;. F. Crane Co. objects to Plaintiffs' Standard Interrogatories, because plaintiffs have
failed to identify any work locations or job sites where plaintiffs allege exposure to any Crane Co. products. Without any identification by plaintiffs of specific work locations or job sites at which Crane Co. products were utilized, Crane Co. cannot adequately determine which Interrogatories are proper and relevant to these actions. G. Crane Co. objects to Plaintiffs' Standard Interrogatories, because they are overly
broad and irrelevant. The information sought is not adequately limited temporally or geographically, nor is it confined to plaintiffs' alleged exposure(s) to Crane Co. products. Accordingly, Plaintiffs' Standard Interrogatories are unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. H. Crane Co. objects to each Standard Interrogatory to the extent that the form of
such interrogatory is compound, misleading, broad, vague, ambiguous or uncertain to the extent that Crane Co. cannot determine the precise nature of the information sought. Crane Co. cannot
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respond to such interrogatories without creating an unreasonable risk of inadvertently providing a misleading, confusing, inaccurate or incomplete response. I.. Crane Co. objects to responding to these Standard Interrogatories on the ground
that many of the interrogatories are redundant or overlapping as to subject matter. The repeated interrogatories serve no useful purpose and will cause Crane Co. unnecessary burden and expense. 1. Crane Co. objects to these Standard Interrogatories insofar as they seek production
of any information constituting a trade secret, confidential financial data or other confidential research, development Of commercial information. K. Crane Co. objects to the definitions provided in Plaintiffs' Standard Interro~atories
to the extent that such definitions are inconsistent with the commonly understood meanings of the terms defined. L. Crane Co. does not concede that any of its answers to Plaintiffs' Standard
Interrogatories are or will be admissible evidence ata trial of this action. Crane Co. does not waive any objection, on any ground, whether or not asserted herein, to the use of any such answer at trial. M. Crane Co. objects to Plaintiffs' Standard Interrogatories to the extent they seek
medical records or other privileged and confidential personnel information. Crane Co. will not provide such information absent an appropriate waiver of the applicable privilege by the appropriate individual(s). N. Crane Co. believe$ that these responses are accurate as of the date made.
However, many of the matters inquired about in these discovery requests took place decades ago. Due to the passage oftime, information may be incomplete or no longer available. Nevertheless, Crane Co. has endeavored to investigate all relevant facts and circumstances. The following
answers are based upon its investigation. However, Crane Co. cannot exclude the possibility that its continued investigation may reveal more complete information. Crane Co. specifically reserves the right to supplement these answers in the event that it acquires additional information that is responsive to these requests. Further, Crane CO.'s investigation is continuing. These responses
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are based on the most current information. O. The foregoing General Objections are hereby explicitly incorporated into each and all of the responses hereinafter provided.
RESPONSES
TO INTERROGATORIES
1. RESPONSE:
IDENTIFY the person verifying these answers on YOUR behalf These Responses are verified by Augustus I. duPont, Vice President, General
Counsel.and Secretary of Crane Co. from 1996 to present. His business address is 100 Stamford Place, Stamford, Connecticut 06902.
2.
State the date offirst employment with YOU, and the dates and titles of each job
position the person verifying these interrogatories has held while employed by YOU. RESPONSE: See Crane Co.'s Response to Interrogatory No.1.
3.
State whether or not YOU are a corporation, and if so, state: A. B. YOUR correct corporate name; YOUR state of incorporation; The date of YOUR incorporation; The address of YOUR principal place of business; Whether or not YOU have ever held a certificate of authority to do business
c.
D. E.
in the State of California, and ifso, the inclusive dates of any certificate;
F.
If YOU are wholly owned or the majority interest of YOUR company is
owned by another business entity, state the entity's name and principal place of business; G. Whether YOU have any business offices in California, and, if so, YOUR
principal place of business in California. RESPONSE: Subject to and without waiving the foregoing General Objections, Crane Co. is a
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corporation and was originally incorporated in Illinois in or about 1865. In 1985, Crane Co. was reincorporated in Delaware. Crane CO.'g principal place of business is at 100 Stamford Place, Stamford, Connecticut 06902. Crane Co. has held a certificate to do business in California since at least 1985. Crane Co. currently has a facility in Long Beach, California.
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6.
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4.
Have YOU ever been identified, known, or done business under any other name in
the State of California?
RESPONSE: Subject to and without waiving the foregoing General Objections, Crane Co.
objects to InterrogatoryNo. 4 because the terms "identified, known or done business unde," are
undefined, vague and ambiguous. Crane Co. further objects to Interrogatory NO.4 insofar as it seeks information dating back over sixty-five years for which it is impractical, if not impossible, to locate knowledgeable employees or review pertinent documents. Crane Co. further objects to
Interrogatory NO.4 because it has no control over how it may have been identified or known by others during the defined time period. Subject to and\yithout waiving the foregoing objections, Crane Co. to its knowledge has consistently conducted business under the name Crane andlor Crane Co. or through one ofits various divisions during the defined time period.
If your answer to Interrogatory No. 4is in the affirmative, please state such name
or names and the time period during which THIS DEFENDANT was so known or identified.
RESPONSE: Not applicable.
If YOU are not a corporation, what is YOUR business structure (partnership, joint
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venture, sole proprietorship, etc.).
RESPONSE: Not applicable.
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7.
If YOU are not a corporation, please IDENTIFY all persons or other entities with
an ownership interest in YOU.
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RESPONSE: Not applicable.
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8.
If you are not a corporation, please state the following: A. The address where the IDSTORICAL RECORDS ofTIDS DEFENDANT
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are currently located; and
B.
DEFENDANT'S
The name, job title and current address of the Custodian for TIDS mSTORICAL RECORDS.
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As use herein, 'IDSTORICAL RECORDS" shall include all DOCUMENTS relating to the formation ofTIDS DEFENDANT, all minutes of partners', general partners', or other' owners' meetings, and all DOCUMENTS relating to TIllS DEFENDANT's acquisition of or purchase, or sale of or by any other COMPANY. merger with,
RESPONSE: Not applicable.
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RESPONSE: Subject to and without waiving the foregoing General Objections, Crane Co.
objects to Interrogatory No.9 because the term "custodian of Business Records" is undefined, vague and ambiguous. Subject to and without waiving the foregoing objections and to the extent Crane Co. understands the terms "custodian of Business Records", there is no custodian of company records for the defined time period.
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10.
IDENTIFY the person or persons most knowledge about: A. YOUR acquisition of RAW ASBESTOS and/or ASBESTOS
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CONTAINING PRODUCTS; B. PRODUCTS; C. YOUR contracting with others to do work involving use or handling of YOUR use of RAW ASBESTOS and/or ASBESTOS CONTAINING
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RAW ASBESTOS or ASBESTOS CONTAINING PRODUCTS.
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If
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RESPONSE: Subject to and without waiving the foregoing General Objections, Crane Co.
objects to Interrogatory No. 10 because it is unduly burdensome, oppressive and overly broad insofar as it seeks information dating back over sixty-five years for which it is impractical, if not impossible, to locate knowledgeable employees or review pertinent documents. Subject to and
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without waiving the foregoing objections, Crane Co. to its knowledge neither acquired nor used raw asbestos. Crane f::o. is not aware of any individual who was primarily responsible for the acquisition of or use of products that may have contained asbestos. By way of further answer, to Crane Co.'s knowledge, William N. McLean, a Crane Co. engineer from approximately 1955 to 1986 when he retired from Crane Co., is the person most knowledgeable regarding Crane Co.' s acquisition and use of asbestos-containing products. Mr. McLean may be contacted through Crane Co.' s counsel. Crane Co.' s investigation in regard to its possible use or acquisition of asbestos-containing products is continuing.
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11.
For DEFENDANTS involved in the MARKETING of ASBESTOS-
CONT AINING PRODUCTS, state the IDENTITY or physicians, medical directors and/or industrial hygienists employed by YOU during the time frame or prior to the time YOU discontinued the marketing of such products. All other DEFENDANTS need only respond as to medical directors and/or industrial hygienists or physicians employed in the area of employee health and safety. PREl\1ISES owners and domestic corporations need only respond as to the . United States.
RESPONSE: Subject to and without waiving the foregoing General Objections, Crane Co. to its
knowledge did not employ a corporate-wide physician, medical director or industrial hygienist during the defined time period.
12.
Has any employee of THIS DEFENDANT testified by deposition or at trial on
behalf of THIS DEFENDANT in a third-party case, in which THIS DEFENDANT was a party, wherein the plaintiff has alleged an asbestos-related injury? If so, for each such third-party case
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(except that Premises Defendants and Contractor Defendants need answer only with respect to cases relating to sites within.the GEOGRAPIDC AREA) please state: . A.
B.
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The caption .and case number; The court filing including state and county; The date of deposition or trial testimony; The name and address of plaintiff's counsel of record; The name and address of the court reporter.
c.
D.
E.
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Subject to and without waiving the foregoing General Objections, Crane Co.
responds that William N. McLean, a fonner Crane Co. employee, has been deposed two times on behalf of Crane Co. in asbestos litigation: Norman v. A-C Product Liability Trust. et aI., No. 94421061 NP (Wayne County, Mich.) and In re: Burleigh and Cass Counties, Set NO.4 (Burleigh County, NO). In Norman, the deposition was conducted in December, 1995 and the court reporter was Diane Hromek's Court Reporters, Inc., 732 Berkshire Court, Downers Grove, Illinois 60516. In In re: Burleigh County, the deposition was conducted in February, 1995 and the court reporter was Norman E. Mark-Court Reporter Service, 312 Black Building, 118 Broadway in Fargo, North Dakota.
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13.
For each of the following, please state whether, at any time within the time frame
or until such time as any defendant which had been engaged in MARKETING RAW ASBESTOS or ASBESTOS-CONTAINING PRODUCTS discontinued the MARKETING of such products,
TIDS DEFENDANT was a member or paid dues for any representative ofTIDS DEFENDANT (excluding faculty members of educational institutions) to bea member of the following:
A.
B.
American Conference of Governmental Industrial Hygienists; American Industrial Hygiene Association; American Petroleum Institute; American Railroad Association; Asbestos Cement Producers Association;
C.
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D.
E.
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2 your answers);
F.
Asbestos Information Association (AIA)(please answer through date of
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G.
Asbestos Information AssociationINorth America (AIAlNA)(pleaseanswer
through date of your answers);
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H.
I.
Asbestos Textile Institute (ATI); Industrial Hygiene Foundation andlor Industrial Health Foundation (lliF); Industrial Mineral Insulation Manufacturers Institute; Magnesia Insulation Manufacturers' Association; Magnesia Silica Insulation Manufacturers Association; Mineral Wool Institute; National Insulation Manufacturers Association (NIMA); National Safety Counsel; New York Academy of Sciences; Quebec Asbestos Mining Asspc!ation (QAMA); Refractories Institute; Safe Building Alliance (please answer through date of your answers); Thermal Insulation Manufacturers Association (TIMA); U.S. Maritime Commission; IDENTIFY any other organizations, associations or groups of
J.
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K.
L.
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N.
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Q.
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T. U. V.
manufacturers, miners, distributors, importers, labelers, supplies, andlor sellers of ASBESTOSCONTAINING PRODUCTS of which TIDS DEFENDANT was a member.
w.
RESPONSE:
IDENTIFY any such representative ofTIDS DEFENDANT.
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Subject to and without waiving the foregoing General Objections, Crane Co.
objects to Interrogatory No. 13, because it is overly broad, oppressive and unduly burdensome insofar as (i) it seeks information dating back to a period of time at which it is impractical, if not impossible, to locate knowledgeable employees or review pertinent documents, (ii) it seeks information relating to individual organizations that have no relation to Crane Co.'s business
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activities, and (Hi) it seeks information on any other "organizations, associations or groups" irrespective of whether they are in any way related to these actions. Finally, Crane Co. objects to Interrogatory No. 13 to the extent it requires Crane Co. to speculate as to whether other members of an organization manufactured or sold asbestos-containing products and accordingly, Crane Co. has only investigated its participation in the above organizations. Subject to and without waiving
the foregoing objections, Crane Co. is without present knowledge of its membership in any organization identified in Interrogatory No. 13, other than the following: the National Safety Council, of which Crane Co. until recently was a member, and the Valve Manufacturers
Association of which Crane Co. is currently a member. In addition, Crane Co. did have a former employee who was a member of the American Petroleum Institute.
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14.
For each organization, association or other entity identified in YOUR Response to
Interrogatory No. 13, please state:
A.
B.
The dates during which THIS !,EFENDANT was a member; The name(s) of any publication(s) received by THIS DEFENDANT from
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such association or organization;
c.
RESPONSE:
The name of any committee or subcommittee of which THIS
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DEFENDANT was a member, and the dates of such committee or subcommittee membership. Subject to and without waiving the foregoing General Objections, Crane Co.
objects to Interrogatory No. 14 because it is overly broad, oppressive and unduly burdensome insofar as it seeks information dating back to a period of time at which it is impractical, if not impossible, to locate knowledgeable employees or review pertinent documents. Subject to and
without waiving the foregoing objections, Crane Co. responds to the best of its knowledge as follows: National Safety Council (approximately 1975 to 1996); and Valve Manufacturers Association (approximately 1938 to present). In addition, Mr. William N. McLean belonged to the American Petroleum Institute's Refinery Subcommittee on Piping from approximately 1967 to 1995.
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15.
Had TIllS DEFENDANT prior to 1973 received any DOCUMENTS containing
results or conclusions of any studies and/or tests conducted by Bonsib for Standard Oil of New Jersey relating to asbestos exposure in the workplace or the human health consequences of exposure to asbestos? If so:
A.
Either (1) attach all DOCUMENTS evidencing the information sought in
this Interrogatory and its subparts to your answers to these Interrogatories, or (2) attach disks containing such data, or (3) describe such DOCUMENTS with sufficient particularity that they may be made the subject of a request for production of documents. B. DOCillAENTS; C. D. State the IDENTIFY of the custodian of such DOCUMENTS. This interrogatory does not apply to pOCUMENTS contained in a library State the date upon which THIS DEFENDANT first received such
maintained by a DEFENDANT hospital or a DEFENDANT'S general public. RESPONSE:
library providing access to the
Subject to and without waiving any of the foregoing General Objections,
Crane Co. objects to Interrogatory No. 15 because it is unduly burdensome and oppressive insofar as it asks Crane Co. to investigate whether over twenty-five years ago someone employed by it received and then reviewed a study and/or test results, the origins of which are not defined by plaintiffs. Subject to and without waiving the foregoing objections, Crane Co. to its knowledge did not receive said studies and/or tests and is not otherwise aware of any documents responsive to this Interrogatory.
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16. Had TillS DEFENDANT prior to 1973 received a copy of any portion of any studies
and/or tests conducted by an insurance company, including but not limited to Metropolitan Life Insurance Company and Aetna Insurance relating to asbestos exposure in the workplace or the human health consequences of exposure to asbestos? Ifso:
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A.
Either (1) attach all DOCUMENTS evidencing the information sought in
this Interrogatory and its subparts to your answers to these Interrogatories, or (2) attach disks containing such data1 or (3) describe such DOCUMENTS with sufficient particularity that they may be made the subject of a request for production of documents.
B.
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State the date upon which TInS DEFENDANT first received such
c.
D.
State the IDENTITY of the custodian of such DOCUMENTS .. This interrogatory does not apply to DOCUMENTS contained in a !ibrary library providing access to the
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maintained by a DEFENDANT hospital or a DEFENDANT'S general public. RESPONSE:
Subject to and without waiving any of the foregoing General Objections,
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Crane Co. objects to Interrogatory No. 16 because it is unduly burdensome and oppressive insofar as it asks Crane Co. to investigate whether over twenty-five years ago someone employed by it received and then reviewed a study and/or test results, the origins of which are not defined by plaintiffs. Subject to and without waiving the foregoing objections, Crane Co. to its knowledge did not receive said studies and/or tests and is not otherwise aware of any documents responsive to this Interrogatory.
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17.
Had THIS DEFENDANT prior to 1973 received any DOCUMENTS containing
results or conclusions of any studies and/or tests conducted by any laboratory, including but not limited to, the Saranac Laboratory relating to asbestos exposure in the workplace or the human health consequences of exposure to asbestos? If so: A. Either (1) attach all DOCUMENTS evidencing the information sought in this Interrogatory and its subparts to your answers tp these Interrogatories, or (2) attach disks containing such data, or (3) describe such DOCUMENTS with sufficient particularity that they may be made the subject of a request for production of documents.
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2 DOCUMENTS.
B.
State the date upon which TillS DEFENDANT first received such
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C.
D.
State the IDENTITY of the custodian of such DOCUMENTS. This interrogatory does not apply to DOCUMENTS contained in a library library providing access to the
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maintained by a DEFENDANT hospital or a DEFENDANT'S general public.
RESPONSE: Subject to and without waiving any of the foregoing General Objections,
Crane Co. objects to Interrogatory No. 17 because it is unduly burdensome and oppressive insofar as it .asks Crane Co. to investigate whether over twenty-five years ago someone e~ployed by it received .and then reviewed a study and/or test results, the origins of which are not defined by plaintiffs. Subject to and without waiving the foregoing .objections, Crane Co. to its knowledge did not receive said studies and/or tests and is not otherwise aware of any documents responsive to this Interrogatory.
18.
Had TillS DEFENDANT (except for a defendant that is an educational institution)
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prior to 1973 ever maintained a library (or libraries) which contained books, articles, periodicals, journals, and/or reference materials that related to the subjects of asbestos, industrial hygiene, medicine, safety and/or occupational disease. If so, state:
A.
The date each such library was established; The location of each such library; The IDENTIFY of each librarian or other person in charge of such library.
B.
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c.
RESPONSE: Subject to and without waiving the foregoing General Objections, Crane Co.
objects to Interrogatory No. 18 because it is overly broad, oppressive and unduly burdensome insofar as it seeks information dating back toa period of time at which it is impractical, if not impossible, to locate knowledgeable employees or review pertinent documents. Subject to and without waiving the foregoing objections, Crane Co. is not aware of the existence of any suchlibrary.
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19.
With the exception of OSHA compliance, had TIDS DEFENDANT (except for a
defendant that is an educational institution) prior to 1980 exchanged DOCUMENTS or communicated with any person or other C01'v1P ANY expressly regarding the results of tests and/or studies relating to asbestos exposure in the workplace or the human health consequences of exposure to asbestos? If so, state:
A.
Each person or COMPANY with whom the information was exchanged or
to whom it was communicated.
B.
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The date(s) of any such exchanges or communications; The IDENTITY of the custodian or such DOCUMENTS.
c.
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RESPONSE: Subject to and without waiving the foregoing General Objections, Crane Co.
objects to Interrogatory No. 19 because it is overly broad, oppressive and unduly burdensome insofar as it seeks information dating back to a period of time at which it is impractical, ifnot impossible, to locate knowledgeable employees or review pertinent documents. Subject to and
without waiving the foregoing objections, Crane Co. to its knowledge did not prior to 1980 exchange any documents or communicate with any person or company expressly regarding the results of any studies and/or tests relating to asbestos exposure in the workplace and is not otherwise aware of any documents responsive to this Interrogatory.
20.
Has any employee or designee ofTIDS DEFENDANT testified as a representative
ofTIDS DEFENDANT before the Occupational Safety and Health Administration, the National Institute of Occupational Safety and Health, or any committee of subcommittee of the United States Congress relating to asbestos exposure in the workplace or the human health consequences of exposure to asbestos? If so, please state:
A.
B.
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The entity before whom such testimony was given; The date(s) and location( s) of such testimony;
C. The IDENTITY of the individual( s) who so testified;
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D.
testimony was given;
E.
Whether any DOCUMENTS were presented to the entity before which
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21.
Whether copies of DOCUMENTS presented were retained by THIS
DEFENDANT and, if so, state the IDENTITY of the custodian of such DOCUMENTS.
RESPONSE: Subject to and without waiving the foregoing General Objections, Crane Co.
objects to Interrogatory No. 20 because it is overly broad, oppressive and unduly burdensome insofar as it seeks information dating back to a period of time at which it is impractical, ifnot impossible, to locate knowledgeable employees or review pertinent documents. Subject to ,and
without waiving the foregoing objections, Crane Co. is not aware orany such testimony.
Has THIS DEFENDANT (except for a defendant that is an educational institution)
conducted, or caused to be conducted, tests, and/or studies ()f ambient asbestos dust created during the manufacture, processing and/or assembling for sale of ASBESTOS-CONTAINING PRODUCTS? If so, state:
A.
Each manufacturing facility, including location and address, at which any
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such test and/or study was conducted;
B. C.
The date of each such test and/or study; The individual(s) or entity conducting each such test and/or study; Whether THIS DEFENDANT has any DOCUMENTS containing the
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D.
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results and/or conclusions of each such study;
E.
The IDENTITY of the custodian of such DOCUMENTS.
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RESPONSE: Subject to and without waiving the foregoing General Objections, Crane Co.
objects to Interrogatory No. 21 because it is overly broad, oppressive and unduly burdensome insofar as it seeks information dating back to a period of time at which it is impractical, if not impossible, to locate knowledgeable employees or review pertinent documents. Subject to and
without waiving the foregoing objections, Crane Co. to its knowledge does not believe it conducted any tests or studies of ambient asbestos dust levels during the defined time period.
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22.
Has TInS DEFENDANT (except for a defendant that is an educational institution)
conducted, or caused to be conducted, any tests and/or studies on ambient asbestos dust levels at any location or job site where ASBESTOS-CONTAINING or removed? If so, for the first 5 tests and/or studies, state:
A.
PRODUCTS were installed, utilized
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The location, including name and address, at which each such test and/or
study was conducted;
B. C.
Theindividual(s) or entity conducting each such test and/or study; The date of each such test and/or study; Whether TInS DEFENDANT has any DOCUMENTS containing the
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D.
results and/or conclusions of each such test and/or study;
E.
The IDENTITY of the custodian of such DOCm.1ENTS.
RESPONSE:
Subject to and without waiving the foregoing General Objections, Crane Co.
objects to Interrogatory No. 22 because it is overly broad, oppressive and unduly burdensome insofar as it seeks information dating back to a period 'Oftime at which it is impractical, if not impossible, to locate knowledgeable employees or review pertinent documents. Subject to and
without waiving the foregoing objections, Crane Co. does not believe it conducted any tests or studies of ambient asbestos dust levels at any location or job site during the defined time period.
23.
Did TInS DEFENDANT (except for a defendant that is.an educational institution)
have any laboratory or other similar type offacility anywhere in the United States at which it conducted, or caused to be conducted, any tests and/or studies of ASBESTOS-CONTAINING PRODUCTS or RAW ASBESTOS relating to the health consequences of asbestos or the dust generated by any use of asbestos or ASBESTOS-CONTAINING
A.
PRODUCTS.
Ifso, state:
The location, including name and address, at which each such test and/or
study was conducted;
B.
The individual(s) or entity conducting each such test and/or study; The date of each such test and/or study;
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C.
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D.
Whether THIS DEFENDANT has any DOCUMENTS containing the
results and/or conclusions of each such test and/or study;
E.
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Y
The IDENTITY of the custodian of such DOCUMENTS.
RESPONSE: Subject to and without waiving the foregoing General Objections, Crane Co.
objects to Interrogatory No. 23 because it is overly broad, oppressive and unduly burdensome insofar as it seeks information dating back to a period of time at which it is impractical, if not impossible, to locate knowledgeable employees or review pertinent documents. Subject to and
8
9
without waiving the foregoing objections, Crane Co. does not believe it had any such laboratory.
10
24.
Has THIS DEFENDANT made available to its employees a medical examination
11 12 13 14 15
program to determine the absence of asbestos-related disease? If so, state:
A.
Whether chest x-rays or pulmonary function tests were part of such
program(s);
B.
Whether participation in any such program was a mandatory condition of
employment or was voluntary;
16
17 18 19 20 21 22
23 24
c.
D.
Whether THIS DEFENDANT has DOCUMENTS of such program(s); The IDENTITY of the custodian of such DOCUMENTS.
RESPONSE: Subject to and without waiving the foregoing General Objections, to its
knowledge, Crane Co. did not have a need for or have such a medical examination to test its employees for the absence of asbestos-related disease, because employees of Crane Co. would not have been exposed to respirable or mabIe asbestos or, if there was any exposure, it would have been deminimus and within all applicable regulations.
25.
Prior to 1973, did any person file a Workers' Comp.ensation claim for asbestos-
25 26 27
28
related injury against THIS DEFENDANT or against any Workers' Compensation insurance carrier which provided coverage for THIS DEFENDANT? claims and, for the first 20 such claims state: If so, state the total number of such
-17-
~
:
)
1
2
A.
B.
The date of such claim; The name of the claimant; The case number; The court in which the claim was filed: The IDENTITY of TIDS DEFENDANT' Scustodian of DOCUMENTS
3
4
C.
D.
E.
5 6 7 8 9 10 11 12 13 14
evidencing such claims. RESPONSE: Subject to and without waiving the foregoing General Objections, Crane Co.
objects to Interrogatory No. 25 because it is oppressive and unduly burdensome insofar as it asks Crane Co. to investigate claims that may have arisen over twenty-five years ago. Crane Co. further objects to Interrogatory No. 25 because it is not reasonably calculated to lead to the discovery of admissible .evidence. Therefore, plaintiffs' exposures, if any, would have differed in quality, type, duration and degree from the exposures relevant to Interrogatory No. 25. Subject to and without waiving the foregoing objections, Crane Co. is not aware of any workers' compensation claims alleging asbestos-related injury ~ring the defined time period.
15 16
17 18 19
20
26.
Does TInS DEFENDANT have insurance available to cover judgment(s) entered
against it in asbestos-related personal injury lawsuits? If so, state: . A. The name and principal place of business of any insurance carrier who has
issued such policy of insurance;
B. C. D.
RESPONSE:
The number and effective date of each policy; The amount( s) of coverage of each policy; The applicable dates of coverage.
21
22
23 24 25 26 27
28
Subject to and without waiving the foregoing General Objections, Crane Co.
objects to Interrogatory No. 26 because it is irrelevant and not reasonably calculated to lead to the discovery of admissible evidence. In particular, the nature .and extent of the insurance carriers' duty to defend and indemnify Crane Co. for plaintiffs' asbestos-related claims is not relevant to whether Crane Co. in the first instance possesses .asbestos-related liability for plaintiffs' claims.
-18-
~l
.;,;... :.. ,.:./
1 2
Crane Co. further objects to this Interrogatory based upon the attorney work product and joint defense doctrines.
3
4
27.
State whether YOU have controlled, purchased, or in any way acquired any
5 6 7 8 9 10 11 12 13 14 15 16 17 18 19
20
21
controlling interest in any corporation or business entity which has mined, manufactured, produced, processed, compounded, sold, supplied, distributed and/or otherwise placed RAW ASBESTOS or ASBESTOS-CONTAINING state:
A. B.
PRODUCTS in the stream of commerce. If so,
The name and address of said corporation or business entity: The dates YOU controlled, purchased or acquired any interest; and The nature of the business as it pertains to asbestos.
C.
RESPONSE:
Subject to and without waiving the foregoing General Objections, see Crane Co.'s
Response to Interrogatory No. 30.
28.
State whether TillS DEFENDANT, between 1930 and 1985, has ever engaged in
the following activities with regard to RAW ASBESTOS, and if so, state the inclusive dates of such activity:
A.
Mining; Milling; Supply; Importing; Processing; Distribution; Marketing; Sale; Brokering.
B.
C. D.
E.
F.
22
23
24
25 26
G.
H.
I.
27
28
-19-
1
2
RESPONSE: Subject to and without waiving the foregoing General Objections, Crane Co. to its
knowledge never engaged in any activity with respect to raw asbestos.
3
4 5 6 7 8 9 10 11 12
29.
If YOUR answer to any of subparts oflnterrogatory 28 regarding RAW
ASBESTOS is in the affirmative,state:
A.
The trade, brand name, and/or generic name of such RAW ASBE~TOS
milled or MARKETED in any form of quantity between 1930 and 1985; B. The date(s) such RAW ASBESTOS was first placed on the market,
including the date(s) such RAW ASBESTOS was first marketed; 1. 2. 3. On an experimental basis; On a test basis; For sale.
13
14 15 16 17 18 19 20 21 22
23
C.
The date(s) such RAW ASBESTOS: 1. 2. Ceased to be produced;-or Was recalled from the market, if ever.
D.
A description of the chemical composition of such RAW ASBESTOS,
including the type and/or grade of asbestos; E. A description of the physical appearance and nature of such RAW
ASBESTOS, including an}'color coding, distinctive marking and/or logo on the packaging or container; F. A detailed description of the intended use of such RAW ASBESTOS,
including any temperature limitsfor each such use; G. Whether such RAW ASBESTOS was on the U.S. Government's "Qualified
24 25 26
27
28
Products List," and if so, the inclusivedates it was on such list; H. As to each such, state; IDENTIFY to whom such RAW ASBESTOS has, at any time, been sold.
-20-
1
2 3 4 5 6 7
I.
Whether any of THIS DEFENDANT's
RAW ASBESTOS has, at any time,
been sold, shipped, or otherwise distributed, used or installed to or at any COMPANY (including power company or utility), governmental agency or entity, shipyard, distributor, refinery, contractor, supplier, PRE:MISE owner or occupant, ship owner, or other PREMISE or site in the GEOGRAPHIC AREA and whether any of THIS DEFENDANT's RAW ASBESTOS has at any
time, been sold to any manufacturer, or manufacturing facility, of ASBESTOS-CONTAINING PRODUCTS. If so, state:
1.
8
9 10 11 12
The names of each such COMPANY, governmental agency or
entity, shipyard, distributor, supplier, manufacturer or refinery; 2. The inclusive dates of each such sale, and the amount (quantity) and
the trade brand name of such RAW ASBESTOS sold; 3. 4. The manner of shipment (e.g. ~oat, rail, etc.) Whether you have any records indicating any such sale or shipment
.:t'>
13
14 15 16 17 18 19 20 21
22
and, if so, the name, address and job classification of each person who currently has possession of such records. 5. Either (1) attach all DOCUMENTS evidencing the information
sought in this Interrogatory and its subparts to your answers to these Interrogatories, or (2) attach disks containing such data, or (3) describe such DOCUMENTS with sufficient particularity that they may be made the subject of a request for production of documents.
RESPONSE: Not applicable.
30.
Between 1930 and 1985, did YOU ever engage in any of the activities listed below PRODUCTS? If so, state the inclusive dates of such
23 24
25 26
with regard to ASBESTOS-CONTAINING activity:
A. B.
Supply; Importing; Distribution;
27
28
c.
-21-
.~
'<' .... ::)
1
2
D.
E. F.
Marketing; Sale; Labeling; Manufacturing; Brokering;
3
4
G. H.
RESPONSE:
5
6 7 8 9 10 11 12 13 14 15 16 17 18
Subject to and without waiving the foregoing General Objections, Crane Co.
objects to Interrogatory No. 30, because it assumes facts in dispute - namely that Crane Co. supplied, imported, aistributed, marketed, sold, labeled, manufactured and/or brokered in the GEOGRAPffiCAL AREA and during the pertinent time frame any asbestos-containing products
that are relevant to these lawsuits. Crane Co. further objects to Interrogatory No. 30 because it is unduly burdensome, oppressive and overly broad insofar as it seeks information dating back over sixty-five years for which it is impractical, if not impossible, to locate knowledgeable employees or review pertinent documents. Crane Co. further objects to Interrogatory No. 30 because plaintiffs
have failed to identify (i) any specific Crane Co. products from which plaintiffs allege exposure to asbestos, or (ii) any specific job or work .sites at which plaintiffs allege exposure to Crane Co. products. Finally, Crane Co. objects to Interrogatory No. 30 as being overly broad, oppressive, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence because it is not limited to the alleged asbestos exposures of any plaintiffs in these lawsuits.
19
20 21 22 23 24 25 26 27
28
-22-
Subject to and without waiving the foregoing objections, Crane Co. was not a manufacturer of any asbestos-containing product as that term is defined and as it is commonly used in asbestos litigation. Crane Co. is and has been a manufacturer of certain types ofindustrial equipment. Crane Co. ' s principal line of industrial equipment throughout the time period requested in this interrogatory was industrial valves. Industrial valves manufacture~ by Crane Co. were made of steel, bronze and other metals; the valves were not composed of asbestos. Certain of the valves had enclosed within their metal structure asbestos-containing gaskets. packing or discs. Crane Co. did not manufacture the asbestos containing components that may have been encapsulated within
1 2 3 4 5 6
7
the valves but purchased them from other companies. Any components that may have been enclosed within the metal structure of Crane Co. valves did not emit friable or respirable asbestos fibers. Any asbestos-containing components were completely encapsulated within the metal structure of the valves and/or valve fittings. Furthermore, any asbestos contained in the components was chemically and physically sealed within the component itself by a rubber-like compound.
8 9 10 11 12 13 14 15 16 17 18
Crane Co. acquired around and subsequent to 1961 the assets of several industrial pump companies that manufactured pumps, which then became divisions of Crane Co. Subsequent to those acquisitions Crane Co. manufactured industrial pumps that may have incorporated within their metal structure an encapsulated asbestos-containing gasket or packing. However, Crane Co. did not manufacture the asbestos-containing components, such as gaskets or packing, contained in the industrial pumps and instead purchased these components from other companies. Any components that may have been enclosed within the metal structure of Crane Co. industrial pumps did not emit mabie or respirable asbestos fibers. Any asbestos-containing components were completely encapsulated within the metal structure of the industrial pumps. Furthermore, any asbestos contained in the components was chemically and physically sealed within the component itself by a rubber-like compound.
19
20 21 22 23 24
25
Crane Co. manufactured boilers until 1946 that may have contained encapsulated asbestoscontaining gaskets or packing within the boilers. Crane Co. also purchased the assets of two boiler companies in the 1960' s and resold them several years later; however, to the best of Crane Co.'s knowledge, information and belief, the boilers that Crane Co. manufactured in the 1960's utilized fiberglas, not asbestos insulation.
26 27
28
Crane Co. also offered for sale certain products manufactured by other companies. A small quantity of these products may have contained asbestos. Crane Co. offered for sale gaskets and
-23-
1 2
packing manufactured by other companies that may have contained asbestos. One such product, called Cranite, was manufactured exclusively for resale by Crane Co. during the defined time period and through the 1970's or early 1980's. Any asbestos contained in such products, however, was chemically and physically sealed within a rubber-like compound that prevented the release of any friable asbestos fibers.
3
4 5 6 7
Crane Co.'s investigation of its activities regarding asbestos-containing products is continuing.
8
9
31.
If your answer to any subpart ofInterrogatory
No. 31 regarding "ASBESTOS-
10
CONTAINING PRODUCTS" is in the affirmative, state:
A.
11
12
The trade, brand name, and/or generic name of each such ASBESTOS-
CONTAINING PRODUCT MARKETED in any form or quantity between 1930 and 1985;
B.
13
14 15 16
The date(s) each such ASBESTOS-CONTAINING
PRODUCT was first PRODUCT
placed on the market, including the date(s) each such ASBESTOS-CONTAINING was first MARKETED;
1.
On an experimental basis; On a test basis; or For sale.
17
18
19
2. 3.
c.
The date(s) each such ASBESTOS-CONT AININGPRODUCT:
1.
20
Ceased to be produced; or Was recalled from the market, if ever.
21
22
23
2.
D.
A detailed description of the chemical composition of each such PRODUCT, including the type and/or grade of asbestos and/or
ASBESTOS-CONTAINING
24 25 26 27
28
asbestos fiber contained in each such product and the quantitative percentage of asbestos or asbestos fiber in each such product, andall non-asbestos components of the ASBESTOSCONTAINING PRODUCT, and if the chemical composition changed over time, the inclusive dates of each formulation;
-24-
1
2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27
28
E.
A description of the physical appearance and nature of each such PRODUCT, including any color coding, distinctive marking and/or
ASBESTOS-CONTAINING
logo, either on the product or on the packaging;
F.
A detailed description of the intended use of each such ASBESTOS-
CONTAINING PROOUCT, including any temperature limits for each such use;
G.
Whether any such ASBESTOS-CONTAINING
PRODUCT was on the
U.S. Government's "Qualified Products List," and if so, the inclusive dates it was on such list;
H.
The name and address of the supplier of the RAW ASBESTOS use~ in
each such product and the time period of such supply;
I.
Whether any ofTIDS DEFENDANT's
RAW ASBESTOS OR
ASBESTOS-CONT AINING PRODUCTS have, at any time, been sold, shipped, or otherwise distributed to any COMPANY (including power company orutility), governmental agency or entity, shipyard distributor, refinery, contractor, supplier, manufacturer, PREMISE owner or occupant, ship owner, or other PREMISE or site in the GEOGRAPIDC AREA. Ifso, state:
1.
The names of each such COMPANY, governmental agency or
entity, shipyard, distributor, supplier, manufacturer, refinery, contractor, PREMISE owner or occupant, ship owner, PREMISE or site: 2. The inclusive dates of each such sale, shipment, distribution, use or
installation .and the amount (volume) and the trade or brand name of each such ASBESTOSCONTAINING PRODUCT sold; 3. Whether you have any records indicating any such sale, shipment,
distribution, use or installation and, if so, the name, address and job classification of each person who currently has possession of such records.
J.
Either (1) attach all DOCUMENTS evidencing the information sought in
this Interrogatory and its subparts to your answers to these Interrogatories, or (2) attach disks containing such data, or (3) describe such DOCUMENTS with sufficient particularity that they may be made the subject of a request for production of documents.
-25-
1
2 3 4 5 6 7 8 9 10
RESPONSE: Subject to and without waiving the foregoing General Objections, Crane Co.
objects to Interrogatory No. 31, because it assumes facts in dispute - namely that Crane Co. supplied, imported, distributed, marketed, sold, labeled, manufactured and/or brokered in the GEOGRAPIDCAL AREA and during the pertinent time frame any asbestos-containing products that are relevant to these lawsuits. Crane Co. further objects to Interrogatory No. 31 because it is unduly burdensome, oppressive and overly broad insofar as it seeks information dating back over sixty-five years for which it is impractical, ifnot impossible, to locate knowledgeable employees or review pertinent documents. Crane Co. further objects to Interrogatory No. 31 because pl~intiffs have failed to identify (i) any specific Crane Co. products from which plaintiffs allege exposure to asbestos, or (ii) any specific job or work sites at which plaintiffs allege exposure to Crane Co. products. Finally, Crane Co. objects to Interrogatory No. 31 as being overly broad, oppressive, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence because it is not limited to the alleged asbestos exposures of any plaintiffs in these lawsuits.
11
12 13 14 15 16 17 18 19 20
21
Subject to and without waiving the foregoing objections, Crane Co. responds that in an effort to locate documents relating to the sale, manufacture or use of asbestos-containing products, Crane Co. has collected and organized from various of its document repositories a number of documents, some of which are potentially responsive to Interrogatory No. 31. Upon request, Crane Co. will
.
.
make all non-privileged relevant documents responsive to this request available for review and copying at the offices of Crane Co. ' s legal counsel.
22 23 24 25 26 27
28
Crane Co. has no specific knowledge of any other documents that are responsive to this request, but Crane Co. does maintain additional documents in document repositories that may possibly contain relevant information. Crane Co. has not reviewed the documents at these locations and, consequently, cannot certify that these documents do not contain information responsive to Interrogatory No. 31. The documents at these repositories are not organized and Crane Co. is not able to ascertain whether any documents are responsive to Interrogatory·No. 31. These
-26-
1 2 3 4 5 6 7 8
9
repositories contain numerous documents that are Dot relevant to this request and which are subject to the attorney-client privilege and/or the work product doctrine. Should plaintiffs wish to review the documents at any of these repositories, Crane Co. will make certain of those documents available to plaintiffs ifplaintiffsagree, in writing, that (i) Crane Co. has not waived
any objections it may have with respect to the discoverability of those documents on any ground and (ii) Crane Co. may conduct a post-designation review to remove privileged and irrelevant documents from any collection of documents that may be copied for production to plaintiffs, even if plaintiffs had specifically designated the privileged or irrelevant documents for copying.
10 11 12 13 14 15 16 17
32.
(PREMISES
DEFENDANTS
only) Did YOU install, remove, or handle or
contract to have others install, remove, or .handle RAW ASBESTOS or ASBESTOSCONT AINING PRODUCTS at any PREMISES in the GEOGRAPIDC AREA which PREMISES is at issue as to YOU in San Francisco Superior Court asbestos litigation as of the date of your answers to these interrogatories? A. IDENTIFY the PREMISES. B. For each of the PREMISES:
1.
If so:
State the nature of your ownership or possessory interest; State the inclusive date of that interest; IDENTIFY the party from whom that interest was acquired; IDENTIFY the party, if any, to whom that interest was transferred.
18
19
20
21
2. 3: 4.
c.
IDENTIFY every contract to which YOU were a party or of which you
22 23 24
25
26
have knowledge wherein the performance of such contract involved the installation, removal, disturbing or handling of any RAW ASBESTOS or ASBESTOS-CONTAINING YOUR PREMISES. For each such contract:
1. 2.
PRODUCTS at
IDENTIFY the parties to the contract; Provide a general description and specific location of the work to be
27
28
performed by each party to the contract;
-27-
F\
.
)
IfIIJt:., , .. :r'i•• •• "':)
,<
1
2 3
4
3.
IDENTIFY and describe the NATURE of the RAW ASBESTOS or
ASBESTOS-~ONT AINING PRODUCTS installed, removed, disturbed or handled in the performance of the contract; 4. D. State the dates of the contract and the dates of performance;
5
6 7 8 9 10 11 12 employees;
Except as provided in response to subpart (c), has any work other than
routine maintenance been done on or to the PREMISES that involved the installation, removal, disturbing or handling of RAW ASBESTOS or ASBESTOS-CONTAINING for each such instance:
1.
PRODUCTS?
If so,
State the inclusive dates of the work; Provide a general description and specific location of the work; State whether the work was done by YOU and/or YOUR
2. 3.
13
14
15
4.
IDENTIFY and describe the NATURE of the RAW ASBESTOS or
ASBESTOS-CONT AINING PRODUCTS installed, removed, handled or disturbed; 5. IDENTIFY from whom the RAW ASBESTOS or ASBESTOS-
16 17 18 19
20
CONT AINING PRODUCTS were acquired.
E.
Has any asbestos abatement effort been made at the PREMISES?
If so, for
each such effort:
1.
IDENTIFY who did the work; State the inclusive dates thereof; State whether samples were taken, and, if the samples still exist,
2. 3.
21 22
23
IDENTIFY the custodian of the samples; 4. results of each test;
5.
State whether any material was tested, and, if so, what were the
24
25
IDENTIFY each test with sufficient particularity for purposes of a
26 27
28
request for production of documents, or, in the alternative, attach a copy to YOUR answers to these interrogatories.
-28-
1
2 3 4 5 6 7
F.
Except for insurance coverage litigation, have you filed suit against, or
otherwise sought to recover from, any person or entity for some or all of the cost of asbestos abatement or for the property damage allegedly caused by the presence of RAW ASBESTOS or ASBESTOS-CONTAINING (A) above? If so:
1.
PRODUCTS on the PREMISES identified in response to subpart
IDENTIFY the person or entity against whom YOU have filed suit
or otherwise sought to recover; 2. If YOU have filed suit, state the court in which the action was filed,
8
9 10
11
on the date on which it was filed, IDENTIFY all Plaintiffs and Defendants and their counsel of record; 3. was the status or disposition. State whether or not the case has been resolved, and, if so, what
12
, 13
14 15 16 17 18 19
20
21
G.
Either (1) attach all DOCUMENTS evidencing the information sought in
this Interrogatory and its subparts to your answers to these Interrogatories, or (2) attach disks containing such data, or (3) describe such DOCUMENTS with sufficient particularity that they may be made the subject of a request for production of documents.
H.
IDENTIFY the person(s) presently most knowledgeable about the
information sought in this interrogatory or its subparts. RESPONSE: Not applicable.
33.
(CONTRACTOR
DEFENDANTS
only) At any time between 1930 and 1985,
22
23
did YOU hold a contractor's license in the State of California? lfso:
A.
B.
IDENTIFY each license by type, date and number. If on the date of your answers YOU are a defendant in four or more
24 25 26 27
28
asbestos actions in San Francisco Superior Court, IDENTIFY each job or contract that YOU performed (directly or through one or more subcontractors) during this time period for work in any PREMISES which is at issue as to YOU on such date, and in any PREMISES of 50,000
-29-
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23
24
square feet or more in the GEOGRAPHIC AREA which job or contract involved installation, removal, disturbing or handling RAW ASBESTOS or ASBESTOS-CONTAINING PRODUCTS.
(Alternatively, at your option, you may IDENTIFY each job or contract YOU performed (directly or through one or more subcontractors) during this time frame for all work, or for all work on PREMISES of50,000 square feet or more, in the GEOGRAPHIC A AREA.) As to each such job or contract:
1.
IDENTIFY the location (including name of ship, if applicable)
where the job or work was performed. 2. 3. 4. State the date of the contract or the inclusive dates of the work; IDENTIFY the person or entity with whom you contracted; State your job or contract number.
C.
If on the date of your answers you are not a defendant in four or more
asbestos actions in San Francisco Superior Court, IDENTIFY each job or contract that YOU performed (directly or through one or more subcontractors) during this time period for work in any PREMISES which is at issue as to YOU on such date. As to each such job or contract: 1. where the job or work
WaS
IDENTIFY the location (including name of ship, if applicable) performed; State the date of the contract or the inclusive dates of the work; IDENTIFY the person or entity with whom you contracted; State your job or contract number.
2. 3. 4. RESPONSE:
Subject to and without waiving the foregoing General Objections, Crane Co. to its
knowledge did not hold a contractor's license in California, but its investigation is continuing in this regard.
25 26 27
28
34.
Did any of the distributors identified In your Answer to Interrogatory Nos. 29 and If so, state the relevant time period.
31 above have an exclusive distributorship? RESPONSE: Not applicable.
-30-
1 2 3 4 5 6 7 8 9
10
35.
IfTIDS DEFENDANT entered into any agreements for the rebranding of any
ASBESTOS-CONTAINING PRODUCTS by TIDS DEFENDANT for resale or distribution by another person or entity, describe each agreement's terms and the parties to said agreement, the duration of the agreement, .andname of each product(s) and/or material(s) covered by each such agreement. RESPONSE: Subject to and without waiving the foregoing General Objections, Crane Co. objects to Interrogatory No.3 5 because the term "rebranding" is undefined, vague and ambiguous. Subject to and without waiving the foregoing objections, Crane Co. to its knowledge did not enter into any rebranding agreement as it understands that term.
11 12 13 14 15 16 17 18 19
20
36.
IfTIUS DEFENDANT entered into any agreements for the rebranding of
ASBESTOS-CONTAINING PRODUCTS manufactured, sold, supplied or distributed by another person or entity for resale or distribution by YOU, describe each of the agreements and the parties to said agreement, the terms, the duration, and the names of each product(s) andlor material(s) covered by each such agreement. RESPONSE: Subject to and without waiving the foregoing General Objections, Crane Co. objects to Interrogatory No. 36 because the term "rebranding" is undefined, vague and ambiguous. Subject to and without waiving the foregoing objections, see Crane Co.'s Response to Interrogatory No. 35.
21 22 23 24 25 26 27
28
37.
As to RAW ASBESTOS and to each such ASBESTOS-CONTAINING
PRODUCT listed in YOUR responses to Interrogatories No. 29 and 31 did DEFENDANT warn of the healthhuards of asbestos? If so, state for each such warning: A. The content, size, color, and location; whether the warning appeared on the
material and/or on the container, andlor was placed on a tag; whether the warning was included in contracts; whether the warning was included in advertising or other promotional materials. B. State whether you have any photographs thereof;
-31-
I
2
c.
D.
changes; and
E.
The inclusive dates on which you used each such warning; State all changes you made in such warnings and the dates of such
3 4 5 6 7 8 9 10 II 12 13 14
Identify the person most knowledgeable about your warnings and warning
policy.
RESPONSE: Subject to and without waiving the foregoing General Objections, as to raw
asbestos see Crane Co.'s Response to Interrogatory No. 29, and as to asbestos-containing products see Crane CO.'s Response to Interrogatory No. 31. By way offurther answer, in or about 1985 a silver mylar warning tag or strip with black lettering was affixed to one of the bolts on steel valves. It read "Caution: Packing or gasket contains asbestos." At the time Crane Co. added the warning tag or strip to its steel valves in 1985, similar designations were not applied to its bronze and iron valves because Crane Co. had previously discontinued the use of asbestoscontaining components in them.
15
16 17 18 19 20 21 22
23
38.
With respect to each of YOUR ASBESTOS-CONTAINING
PRODUCTS, state
whether TillS DEFENDANT's
name, a trademark, logos, color coding, or other identifying
markings ever appeared on the actual product itself If so, IDENTIFY each such product, state when the practice to place such identifying markings upon the product was begun and when it ended, if applicable, and describe in detail the pertinent marking(s) and the purpose, if any, of such markings.
RESPONSE: Subject to and without waiving the foregoing General Objections, see Crane Co.'s
Response to Interrogatory No. 31.
24 25 26 27
28
39.
Between the years 1930 to 1985, did TillS DEFE~ANT
purchase or otherwise
acquire any ASBESTOS-CONTAINING state for each such purchase:
A.
PRODUCT lines from another person or entity? If so,
Date of purchase or acquisition;
-32-
<f'.:-:'~
~,
:/
1
2
B.
Terms of purchase or acquisition agreement; Either (1) attach all DOCU1vfENTS evidencing said acquisition, or
C.
3 4 5
6
(2) attach diSKScontaining such data, or (3) describe such DOCU1vfENTS with sufficient particularity that they may be made the subject of a request for production of documents.
D.
E.
Trade, brand, and/or generic name of each such product line so acquired; Name of the person or entity from whom YOU purchased or acquired each
7
such ASBESTOS-CONT AlNING PRODUCT line; and
F.
8
9 10 11 12 13 14 15 16 17 18 19
20
Location of any manufacturing facilities so acquired, and the type of
ASBESTOS-CONT AINING PRODUCTS manufactured therein. RESPONSE: Subject to and without waiving the foregoing General Objections, Crane Co.
objects to Interrogatory No. 39 because the term "ASBESTOS CONTAINING PRODUCT lines" is undefined, vague and ambiguous. Crane Co. further objects to Interrogatory No. 39 because it is unduly burdensome, oppressive and overly broad insofar as it seeks information dating back over sixty-five years for which it is impractical, if not impossible, to locate knowledgeable employees or review pertinent documents. Subject to and without waiving the foregoing objections, see Crane CO.'s Response to Interrogatory No. 30.
40.
Between the years 1930 to 1985, did THIS DEFENDANT sell any ASBESTOS-
CONTAINING PRODUCT line to another person or entity? If so, state for each such sale;
A.
B. C.
Date of sale; Terms of sales agreement; Either (I) attach all DOCU1vfENTS evidencing said acquisition, or
21
22
23 24
25 26
(2) attach disks containing such data, or (3) describe such DOCUMENTS with sufficient particularity that they may be made the subject of a request for production of docu~ents.
D.
E.
Trade, brand, and/or generic name of each such product line so sold; Name of the person or entity to whom you sold each such ASBESTOS-
27
28
CONTAINING PRODUCT line; and
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1
2 3 4 5 6 7 8 9 10
F.
Location of any manufacturing facilities so sold, and the type of PRODUCTS manufactured therein.
ASBESTOS-CONTAINING RESPONSE:
Subject to and without waiving the foregoing General Objections, Crane Co.
objects to Interrogatory No. 40 because the term "ASBESTOS CONTAINING PRODUCT lines" is undefined, vague and ambiguous. Crane Co. further objects to Interrogatory No. 40 because it is unduly burdensome, oppressive and overly broad insofar .as it seeks information dating back over sixty-five years for which it is impractical, if not impossible, to locate knowledgeable employees or review pertinent documents. Subject to and without waiving the foregoing
objections, see Crane Co.'s Response to Interrogatory No. 30.
11
12 13 14
41.
IDENTIFY all brochures, pamphlets, catalogs or other advertising relating to PRODUCTS and/or RAW ASBESTOS which THIS DEFENDANT
ASBESTOS-CONTAINING
manufactured, sold, distributed or supplied from the year 1930 to 1985. For each such document, state:
A.
15 16
17
18
A description .of the document; The year it was printed; The period of time in which it was used; The purpose of such document; Whether the documents or copies of said 'documents presently exist; If said documents or copies stilI exist, where they are located; and The IDENTITY of the custodian of such documents.
B.
C.
D.
E. F.
19
20
21
G.
RESPONSE:
22 23 24 25 26 27
28
Subject to and without waiving the foregoing General Objections, Crane Co.
objects to Interrogatory No. 41 because it assumes facts in dispute - namely that Crane Co. manufactured, sold, distributed and/or supplied in the GEOGRAPHICAL AREA and during the pertinent time frame any raw asbestos or asbestos-containing products that are relevant to these lawsuits. Crane Co. further objects to InterrogaioryNo. 41 because it is unduly burdensome,
oppressive and overly broad, insofar as it seeks information dating back over sixty-five years.
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·
"
1
2 3
4
Finally, Crane Co. objects to Interrogatory No. 41 because plaintiffs have failed to identify any specific Crane Co. products from which plaintiffs allege exposure to asbestos. Subject to and without waiving the foregoing objections, see Crane Co.' s Response to Interrogatory No. 31.
5
6 7 8 9 10
11
42.
State if YOU have or had within YOUR corporate or other business structure any
CONTRACT UNITS. RESPONSE: Subject to and without waiving the foregoing General Objections, Crane Co.
objects to Interrogatory No. 42 because it is unduly burdensome, oppressive and overly broad, insofar as it seeks information dating back over sixty-five years. Finally, Crane Co. objects to Interrogatory No. 42 because plaintiffs have failed to identify any specific job or work sites at which plaintiffs allege a contract unit of Crane Co. may have been engaged. Subject to and without waiving the foregoing objections, to Crane Co.' s knowledge neither Crane Co. nor any so-called CONTRACT UNIT was engaged in the installation, removal, etc. of raw asbestos or asbestos-containing products, but its investigation isccintinuing in this regard. By way of further answer, see Crane Co. 's Response to Interrogatory No. 30.
12
13
14
15
16 17 18 19 20 21 22
23
43.
State whether or not any of YOUR CONTRACT UNITS installed and/or removed PRODUCTS in the GEOGRAPIDC
RAW ASBESTOS and/or ASBESTOS-CONTAINING AREA at any time between 1930.and 1985. Ifso:
A.
State the business addresses and name of the CONTRACT UNIT; State the inclusive periods of time the CONTRACT UNITS were working
B.
in the GEOGRAPIDC AREA;
c.
State the name and address of each job site within the GEOGRAPIDC
24 25 26
27
28
AREA and the dates the CONTRACT UNIT worked at those job sites, and, IDENTIFY the RAW ASBESTOS and/or ASBESTOS-CONTAINING occasIOn; PRODUCTS installed or removed on each
D.
Either (1) attach all DOCUMENTS evidencing the information sought in
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.
'
Q
r1
1 2
this Interrogatory and its subparts to your .answers to these Interrogatories, or (2) attach disks containing such data, or (3) describe such DOCUMENTS with sufficient particularity that they may be made the subject of a request for production of documents. RESPONSE: Subject to and without waiving the foregoing General Objections, Crane Co.
3
4 5 6 7 8 9 10
objects to Interrogatory No. 43 because it is unduly burdensome, oppressive and overly broad, insofar as it seeks information dating back over sixty-five years. Finally, Crane Co. objects to Interrogatory No. 43 because plaintiffs have failed to identify any specific job or work sites at which plaintiffs allege a contract unit of Crane Co. may have been engaged. Subject to and without waiving the foregoing objections; see Crane Co.' s Response to Interrogatory No. 42.
11
12 13 14 15 16 17 18 19
20
44.
When do YOU contend that TIllS DEFENDANT first became aware that there is
an association between asbestos exposure and disease in human beings? RESPONSE: Subject to and without waiving the foregoing General Objections, Crane Co.
objects to Interrogatory No. 44 as being vague and speculative because it requires information regarding a supposed causal link between various medical conditions and exposure to asbestos, without regard for the fiber types or the concentration, duration, frequency or nature of the exposures. Subject to and without waiving the foregoing objections, Crane Co. first became aware of the purported association between asbestos exposure and disease in human beings in the late 1970's or early 1980's.
21
22 23 24 25
26
45.
How do YOU contend that TIllS DEFENDANT first became aware that there is
an association between asbestos exposure and disease in human beings? RESPONSE: Subject to and without waiving the foregoing General Objections, Crane Co.
objects to Interrogatory No. 45 as being vague and speculative because it requires information regarding a supposed causal link between various medical conditions and exposure to asbestos,
/1/
/11
27
28
-36-
,
,
!•
1 2 3
4
without regard for the fiber types or the concentration, duration, frequency or nature of the exposures. Subject to and without waiving the foregoing objections, Crane Co. became aware of
said purported association through a variety of sources.
5 6 7 8 9 10 11
12
46.
Either (1) attach all DOCUMENTS evidencing the information upon which YOUR
contentions in YOUR answers to Interrogatories No. 44 and No. 45 are based, or (2) attach disks containing such data, or (3) describe such DOCUMENTS with sufficient particularity that they may be made the subject of a request for production of documents. RESPONSE: Subject to and without waiving the foregoing General Objections, upon request
Crane Co. will make documents potentially responsive to Interrogatory No. 46 available for review and copying at the offices of Crane Co.'s legal counsel.
13 14 15 16 17 18 19 20 21 22 23 24 25 26 27
28
47.
When did TillS DEFENDANT first warn its employees that exposure to asbestos
could be hazardous to human health? State: A. B. C. D. RESPONSE: Whether the first such warning was written or oral; Whether copies of DOCUMENTS containing such warning exists; The IDENTITY of the custodian of such DOCUMENTS; The content of the warning.
Subject to and without waiving the foregoing General Objections, Crane Co.
objects to Interrogatory No. 47 as being irrelevant and not reasonably calculated to lead to the discovery of admissible evidence because to its knowledge employees of Crane Co. would not have been exposed to respirable or friable asbestos or, if there was any exposure, it would have been deminimus and within all applicable regulations and this interrogatory assumes a duty to warn without any evidence of employee exposure to asbestos at hazardous levels in any Crane Co. facility. Subject to and without waiving the foregoing objections, Crane Co. responds: unknown, although its investigation in this regard is continuing.
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t
~
f'
1
2
48.
Did TInS DEFENDANT ever issue a written COMPANY policy discontinuing
warning its employees that exposure to asbestos could be hazardous to human health? If so,
A.
B.
3
4
5
Provide the date; Describe the circumstances; and Either (1) attach all DOCUMENTS evidencing the information sought in
C.
6 7 8 9 10
this Interrogatory and its subparts to your answers to these Interrogatories, or (2) attach disks containing such data, or (3) describe such DOCUMENTS with sufficient particularity that they may be made the subject of a request for production of documents.
RESPONSE: Subject to and without waiving the foregoing General Objections, ~rane Co.
objects to Interrogatory No. 48 as being irrelevant and not reasonably calculated to lead to the discovery of admissible evidence because no present or former employees of Crane Co. are known to have made asbestos exposure claims against Crane Co. and the interrogatory assumes a duty to warn without any evidence of employee exposure to asbestos at hazardous levels in any Crane Co. facility. Subject to and without waiving the foregoin~jobjections, Crane Co. responds: no.
11
12
13
14
15
16 49. Did TInS DEFENDANT provide any Independent Contractor or Subcontractor AREA with a written warning that exposure to asbestos could be
17 18
within the GEOGRAPmC hazardous to human health.
19
20 21 22
23
RESPONSE: Subject to and without waiving the foregoing General Objections, Crane Co.
objects to Interrogatory No. 49 because the terms "Independent Contractor or Subcontractor" are undefined, vague and ambiguous. Subject to and without waiving the foregoing objections, see Crane CO.'s Response to Interrogatory No. 37.
24
50.
Has THIS DEFENDANT been cited for or otherwise charged by a public agency
25 26 27
28
with a violation in the GEOGRAPHIC AREA of any statute, ordinance, safety order, regulation, or law pertaining to asbestos exposure? For each occasion, IDENTIFY:
-38-
;":
..
::"'~
:/
A.
The code section, safety order, statute, or regulation for which TillS
DEFENDANT had been cited .or otherwise charged; B. The date(s) thereof The agency or other governmental unit which issued the citation or
c.
D.
E. RESPONSE:
otherwise charged YOU. All persons known to YOU with information relevant to the incident. What was the ultimate resolution.
Subject to and without waiving the foregoing General Objections, Crane Co.
objects to Interrogatory No. 50 because it assumes facts in dispute - namely that Crane Co. sold in the GEOGRAPffiC AREA and during the pertinent time frame any asbestos-containing products that are relevant to these lawsuits. Crane Co. further objects to Interrogatory No. 50 because any citation against Crane Co. is neither relevant to nor reasonably calculated to lead to the discovery of admissible evidence as to plaintiffs' asbestos claims. Subject to and without waiving the foregoing objections, Crane Co. has no knowledge of any such citations or charges.
51.
If TillS DEFENDANT has ever owned or operated a railroad, state: A. The IDENTITY of each such railroad, including the name(s) of such
railroad during the time period of YOUR ownership and/or operation, the principal place of business of such railroad and the dates of YOUR ownership and/or operation; B. C. D. The geographic area of operation of such railroad; The name(s) of such railroad prior to YOUR ownership and/or operation; The IDENTITY of the person or entity from whom YOU purchased your
ownership or operating interest, and the date of such purchase; E. The IDENTITY of the person or entity to whom YOU sold your ownership
or operating interest, and the date of such sale; F. and/or sale exist; Whether copies of DOCUMENTS evidencing your ownership/operation
-39-
•
~I
1
2 3 4 5 6 7
G. H.
The IDENTITY of the Custodian of such DOCUMENTS. To the extent that information has not been given in answers to
Interrogatory Nos. 32 and 33, the information required in Interrogatory Nos. 32 and 33, for each railroad owned or operated by RESPONSE:
you.
Subject to and without waiving the foregoing General Objections, Crane Co. does
not believe it owned or operated a railroad.
8
9 10 11 12
52.
If DEFENDANT has ever owned or operated a shipyard, state:
A.
The IDENTITY of each such shipyard, including the name(s) of such
shipyard during the time period of YOUR ownership and/or operation, the place of business of such shipyard and the dates of YOUR ownership and/or operation.
B.
The name(s) of such shipyard prior to YOUR ownership and/or operation; The IDENTITY of the person or entity to whom YOU sold your ownership
13
14
c.
D.
and/or sale exist;
E.
or operating interest, and the date of such sale; Whether copies of DOCUMENTS evidencing your ownership/operation
15
16
17
Whether any representative of TInS DEFENDANT attended the Maritime
18 19 20
21
Commission Conference in December 1942 in Chicago, Illinois? If so, IDENTIFY any such representative of THIS DEFENDANT;
F.
The IDENTITY of the Custodian of such DOCUMENTS; To the extent that information has not been given in answers to
G.
22 23 24 25
26
27
Interrogatory No. 32, the information requested in Interrogatory No ..32, for each shipyard owned or operate~ by YOU. RESPONSE: Subject to and without waiving the foregoing General Objections, Crane Co. does
not believe it owned or operated a shipyard.
28
-40-
53.
At any time between 1930 and 1985, did you import, export, ship, transship or PRODUCTS into, out of
otherwise transport RAW ASBESTOS or ASBESTOS-CONTAINING
or through any port in the GEOGRAPffiC AREA? If so, for each occasion: A. IDENTIFY and describe the NATURE and amount .ofRAW ASBESTOS
and/or ASBESTOS-CONT AINING PRODUCTS~
B.
IDENTIFY the ship or ships (including the owners and operators thereof) PRODUCTS
onto or from which the RAW ASBESTOS and/or ASBESTOS-CONTAINING were loaded, unloaded or transshipped;
c.
D.
State the dates, port and pier involved for each occasion; Either (1) attach all DOCUMENTS evidencing the information sought in
this Interrogatory and its subparts to your answers to these Interrogatories, or (2) attach disks containing such data, or (3) describe such DOCUMENTS with sufficient particularity that they may be made the subject of a request for production of documents. RESPONSE: Subject to and without waiving the foregoing General Objections, Crane Co.
objects to Interrogatory No. 53 because the term "port" is undefined, vague and ambiguous. Crane Co. further objects to Interrogatory No. 53 because it is unduly burdensome, oppressive and overly broad insofar as it seeks information dating back over sixty-five years. Crane Co. further objects to Interrogatory No. 53 because plaintiffs have failed to identify (i) any specific Crane Co. products from which plaintiffs allege exposure to asbestos, or (ii) any specific job or work sites at which plaintiffs allege exposure to Crane Co. products. Finally, Crane Co. objects to Interrogatory No. 53 as being overly broad, oppressive, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence because it is not limited to the alleged
III III III III III
-41-
•
+•
,
,
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
,,
,
asbestos exposures of any plaintiffs in these lawsuits. Subject to and without waiving the foregoing objections, Crane Co. to its knowledge did not transport raw asbestos via any port. Crane Co. has no knowledge regarding whether or not it transported asbestos-containing products via any port. By way offurther answer, see Crane CO.'s Response to Interrogatory No. 31.
DATED:
July 6, 1998
WRIGHT, ROBINSON, OSTIDMER&
TATUM
By:
~ c~%S.(.
/~
PETERB L GAN
Attorneys for Defendant CAANE O. C
-42-
.,
,
.
<& •
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w
..! I
1
1
3
4
5
6
I, AUgustusl duPont, declarend say~ a
I amtheVicePresident, General Counac1 andSocr.eury dtfeftc1an~Cranc;_C~. of h~y~
reviewed the foregoingCrane CO.'I :Responsesto Plaintiffs' Stwlard Interrogatories (General
J
Order 129). CraneCo. dOI$ not haveanycurrentemployees ithpersonalknowlcclse w olme
7
~nfonnationsought y saidinterrogatories. he informatiourovided. n CraneCo.'sresponses b T i
8
9
has been obtainedthrough a reviewof existingbusiness recorcb .1Z1d interYiIW former of
=ployees otthe company.11M inf'ormed andbelieve,andon that basisassert, that said
information true. is I declar. WIder peDlltyof pajury \I.!1der thelaws()t the State of California that the
10
11 .• 12
toregoirag true and correct. is
13
14
15
DATEJ): 1uly.£.
1998
~
16
17
i;.
IS
. 19
21
12
23
14
25
26
17
28
. ~WSS:O! 866!'Z 'Int
•
,
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.
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.
)
PROOF OF SERVICE
1
2
I declare that:
3
4
I am a citizen of the United States, employed in the County of San Francisco, California,
over the age of eighteen years, and not a party to the within cause. My business address is 44 Montgomery Street, 18th Floor, San Francisco, California, 94104. On July 6, 1998, served the within:
5
6
7
I
CRANE CO.'S RESPONSES TO PLAINTIFFS' STANDARD INTERROGATORIES
8
9
xx BY MAIL on the parties in said cause, by placing a true and correct copy thereof enclosed in a sealed envelope with postage ther~on fully prepaid, in the United States mail at San Francisco, California, addressed as follows:
SEE ATTACHED LIST
10
11
12
13
14
certify and declare under penalty of peIjury that the foregoing is true and correct and that this declaration was executed on July 6, 1998, at San Franci California.
I
15
16
17
18
19
20
21
22 23
24
25
26 27
28
k
,
1
2
Mr. Zafferono
Bruce L. Ahnfeldt, Esq.
P. O. Box 6078 Napa, CA 94581
AARONSON, DICKERSON, COHN & LANGONE
P.O. Box 1065 San Carlos, CA 94070
3
4
5
6
Bryce Anderson, Esq.
P.O. Box 756 Clayton, CA 94517-0756
Marc C. Bandich, Esq.
LAW OFFICES OF MARC C. BARULICH
1721 Court Street Redding, CA 96001
7
8
9
Louis M. Bernstein, Esq.
Attorney at Law One Kaiser Plaza, Suite 601 Oakland, CA 94612 Michael A. Pollack, Esq.
BRAYTON HARLEY CURTIS
P. O. Box 2109 Novato, CA 94948
10
11
CASCINO VAUGHAN LAW OFFICES
633 W. Wisconsin Avenue, Suite 330 Milwaukee, WI 53202
Frederick Schenk, Esq.
12
13 14
CASEY, GERRY, CASEY, WESTBROOK, REED & SCHENK
110 Laurel Street San Diego; CA 92101
LAW OFFICES OF JACK K.CLAPPER
15
16
T~otftasD. Thomas, Esq.
Marina Office Plaza 2330 Marinship Way, Suite 140 Sausalito, CA 94965
DAVIS & mOMAS
1999 Avenue of the Stars, Suite 2310 Los Angeles, CA 90067
17 18
19
LAW OFFICES OF FRANK H. FINNEY
3200 a. DanvilleBlvd., Ste. 101 Alamo, CA 94507
LAW OFFICES OF CHRISTOPHER E. GRELL
685 Market Street, Suite 540 San Francisco,.CA 94105
20
21
22 23
HARRISON & DeGARMO
One Daniel Burnham Court, Suite 220-C San Francisco, CA 94109
LAW OFFICES OF GLORIA J. BUSICK
351 St. Mary Street Pleasanton, CA 94566
KAZAN, McCLAIN, EDISES, SIMON ABRAHAMS
171 Twelfth Street, Suite 300 Oakland, CA 94607
&
GEORGE W. KILBOURNE, ESQ.
661 Augusta Drive Moraga, CA 94556
24
25 26
27
28
'<
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~
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•
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.
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1 2 3 4 5 6 7 8 9
LAW OFFICES OF J. KENNETH LYNCH
One Sansome Street, Suite 2100 San Francisco, CA 94104
McCARTHY, JOHNSON & MILLER
595 Market Street, Suite 2200 San Francisco, CA 94105
Jerry N. Paul, Esq.
Attorney at Law 16830 Ventura Blvd., Ste. 500 Encino, CA 91436
LAW OFFICES OF JOHN C. ROBINSON
855 Channing Circle Benicia, CA 94510
JOHN C. SMITH, JR., ESQ.
Fox Plaza 1390 Market Street, Suite 702 San Francisco, CA 94102
STEVEN B. STEIN, ESQ.
One Embarcadero Center, Ste. 2112 San Francisco, CA 94111
STERNS, WALKER & LODS
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
F:\PBL\791030\0004\00129pos.doc
280 Utah Street San Francisco, CA 94103
VISSE & YANEZ
One Daniel Burnham Court, Ste. 220-C San Francisco, CA 94109
WARTNlCK, CHABER, HAROWITZ, SMITH & TIGERMAN 101 California Street, 22M Floor
San Francisco, California 94111
BERRY
& BERRY
StationD. P.O. Box 70250 Oakland, CA 94612
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