Request,Application: JOYCE JUELCH, ET AL VS. ASBESTOS DEFENDANTS (B/P)AS REFLECTED ON EXHIBITS et al

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GEORGE D, YARON, ESQ, (State Bar #96246)
KEITH E, PATTERSON, ESQ. (State Bar #225753)
MICHAEL J. PENG, ESQ. EY Bar #260852)
YARON & ASSOCIATES

601 California Street, 21° Floor

San Francisco, California 94108
Telephone: (415) 658-2929

Facsimile: (415) 658-2930

ELECTRONICALL
FILED

Superior Court of Californie
County of San Francisce

FEB 26 2010

Clerk of the Court
BY: CHRISTLE ARRIOLA
Deputy Glerk

&

Attorneys for Defendant
84 LUMBER COMPANY

SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN FRANCISCO

CASE NO, CGC-09-275212

REQUEST FOR JUDICIAL NOTICE IN
SUPPORT OF 84 LUMBER COMPANY’S|
MOTION FOR SUMMARY JUDGMENT,
OR, IN THE ALTERNATIVE

SUMMARY ADJUDICATION OF ISSUES

JOYCE JUELCH and NORMAN JUELCH, SR.,
Plaintiffs,
v.

)
)
)
)
ASBESTOS DEFENDANTS (B¢P) As)
Reflected on Exhibits B, B-1, C; and DOES 1
)
)
)
)
?

8500; and SEE ATTACHED LIST, Hearing Date: March 18, 2010
Hearing Time: 9:30 a.m.
Depart. No.: 220
Defendants. Hearing Judge: Hon. Harold E. Kahn
Date Action Filed: | May 20, 2009
) Date Set For Trial: April 5, 2010

Defendant 84 LUMBER COMPANY (“84 Lumber”), through its attorney of record,
requests that the Court take Judicial Notice, pursuant to California Evidence Code Sections
452(g)(h) and 453, of the following records in support of 84 Lumber’s Motion for Summary
Judgment, or, in the alternative, Summary Adjudication of Issues.

1. 84 Lumber requests that this Court take judicial notice of the County of San Joaquin
Building Inspection Department public records pertaining to Plaintiff Joyce Juelch’s home at 251
South Adelbert Avenue, Stockton, CA. These documents may be judicially noticed under
California Evidence Code §452, subdivision (h), as facts and propositions that are not reasonably
subject to dispute and are capable of immediate and accurate determination by resort to sources of
reasonable and indisputable accuracy. Attached hereto as Exhibit “1” is a true and correct copy of
-1-

|Request for Judicial Notice GA3265\MS.Mud.Notice. wpdCo PW NY A HW BF ww =

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the County of San Joaquin Building Inspection Department public records.

2. 84 Lumber requests that this Court take judicial notice of the U.S. Consumer
Product Safety Commission announcement of the ban on certain asbestos-containing products,
dated December 2, 1977. These documents may be judicially noticed under California Evidence
Code $452, subdivision (h), as facts and propositions that are not reasonably subject to dispute and

are capable of immediate and accurate determination by resort to sources of reasonable and

indisputable accuracy, Attached hereto as Exhibit “2” are true and correct copies of the documents.

3, 84 Lumber requests that this Court take judicial notice of the Declaration of George

B. Kirk, filed in support of Kaiser Gypsum Company, Inc.’s Notice of Motion and Motion for
Summary Judgment in the case Joseph B. Cavesina and Thomas D. Small v. Owens-Illinois, Inc.
et al., Case No. BBC-329514 in the Los Angeles County Superior Court. This document may be
judicially noticed under California Evidence Code §452, subdivision (d), as records of a Court of
the State of California, Attached hereto as Exhibit “3” is a true and correct copy of this document.

4. 84 Lumber requests that this Court take judicial notice of Defendant Hamilton
Materials, Inc.’s Responses to Plaintiffs’ Standard Interrogatories to All Defendants, verified on
June 8, 1998. This document may be judicially noticed under California Evidence Code §452,

subdivision (d), as records of a Court of the State of California. Attached hereto as Exhibit “4” is

a true and correct copy of this document.

5. 84 Lumber requests that this Court take judicial notice of Defendant Kaiser Gypsum.
Company’s 2007 Supplemental Responses to Plaintiffs’ Standard Interrogatories to All Defendants,
verified on August 8, 2007. This document may be judicially noticed under California Evidence
Code §452, subdivision (d), as records of a Court of the State of California. Attached hereto as

Exhibit “5” is a true and correct copy of this document.

DATED: February 24, 2010

Request for Judicial Notice -2- GN3265\MS ud Notice. wpdEXHIBIT 1Give this Number When
Calling for inspection

SAN JOAQUIN COUNTY BUILDING: INSPECTION DEPT.

1UIO £ HAZELTON AVE, STOCKTON, CALIFORNIA 96201

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pines. NEWS from CPSC

U.S. Consumer Product Safety Commission

Office of Information and Public Affairs Washington, DC 20207

FOR IMMEDIATE RELEASE
December 2, 1977
Release # 77-118

Asbestos Ban Announced

WASHINGTON, DC (Dec. 2) -- The U.S. Consumer Product Safety Commission {CPSC) today approved a ban
of two consumer products containing inhalable asbestos -- consumer patching compounds containing asbestos
and artificial fireplace ash containing asbestos. The Commission believes that certain types of cancer may result
from inhaling free-form asbestos fibers released into the air during the use of these products.

The asbestos content of a given product is not necessarily the sole criterion for that product's relative health
tisk. A health risk occurs when asbestos fibers become airborne and can then be inhaled, Free-form asbestos is
that which is not bound or otherwise "locked-in" to a product and, therefore, can readily become airborne.

Consumer patching compounds are available in dry form (to be mixed with water by the user) or in a ready-mix
paste form and are used to cover, seal or mask cracks, joints, holes and similar openings in the trim, walls and
ceilings of building interiors, Asbestos fibers are released into the air after application, when the patching
compound is sanded or scraped in the process of finishing or smoothing the surface. Asbestos may also be
released into the air when the dry form of patching compound is mixed with water prior to use.

Approximately haif of all patching compounds sold contain asbestos. These products generally do not have
ingredients listed on the label.

Artificial fireplace emberizing materials (ash and embers) are used in gas- burning or artificial fireplace systems
for decorative purposes; when subjected to high temperatures, the asbestos in these products produces a glow
similar to real embers and ash. Asbestos fibers are released into the air when the emberizing material is
sprinkled on the fireplace floor, when glue used by the consumer to attach the material to an artificial
gas-burning log melts at high temperatures, and when household air currents disturb the ash.

The ban of artificial fireplace ash containing asbestos takes effect as soon as notice of the ban is published in
the Federal Register. The ban on asbestos- containing patching compounds is staggered; thirty days after
publication in the Federal Register manufacturers of patching compounds containing asbestos may no longer
produce or distrioute into commerce these products, and 180 days after publication, all other distribution and
retail sales of asbestos-containing patching compounds must halt. Publication of the ban in the Federal Register
is expected before the end of the year.

Consumer Alert

Proposed Instructions for Removing Non-Burning Artificial Fireplace Logs, Gas-Burning Fireplace Logs
and Ashes Containing Asbestos

(Emberizing Materials)

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The U.S, Consumer Product Safety Commission (CPSC) estimates that in the past 10 years about 300,000 to
500,000 consumers have purchased artificial fireplace ash. Artificial fireplace ash is a material containing
asbestos, placed under logs in gas- burning fireplace systems or in artificial fireplaces for decorative purposes.
The asbestos material also may be glued to artificial logs. When heated, the material glows like real embers and
ash.

Asbestos can cause cancer. Therefore, the Commission is going to ban artificial fireplace ashes (asbestos
emberizing materials) and consumers should remove the ashes from their homes using the following procedures.
Read all of the instructions and make sure you understand them BEFORE you start to remove the ash.

Equipment
You will Need:

~-Two heavy-duty plastic bags;

--Two pieces of string or "ties" for fastening the bags;

--One flat-bottomed scoop (sugar scoop, dust pan or small, plastic toy shovel);

--A covering for the nose and mouth. (This could be a dust face mask, available at most drugstores, or a
single-use respirator. Respirators may be purchased at most hardware stores.);

~-One pump spray-type bottle (window cleaner bottie, plant mister, etc.);

-- Agenerous supply of paper towels or pieces of cloth (for wiping up) ;

-- A supply of newspaper;

--Washable clothing.

Preparations
Proper removal and disposal of the ash also requires that you:

~-Be careful not fo create dust from the ash and embers in the fireplace.

--Clear the room of all other people and pets.

--Close all windows and doors which might cause a draft.

--Close the fireplace flue damper.

--Fill the pump spray bottle with water and 2 or 3 drops of liquid detergent. Do not make a lot of suds in the
bottle.

--put one plastic bag inside the other.

--Cover your nose and mouth with a respirator or face mask.

--Do not try to disconnect the gas line as this should only be done by licensed plumbers or gas company
personnel. Be sure gas valve is turned off.

Removal Procedures
--Do not try to vacuum this material.

--Lightly spray the ash and embers with the water and detergent mixture until the ash is thoroughly dampened,
Do Not POUR Water on the Ash and Embers. Be careful not to stir up the ash and embers while spraying.

--Using the scoop or smail shovel, put the ash and embers into the double plastic bag. (If the ash and embers
are in a pan located under the grate, put the entire pan into the bag).

--Put the scoop or shovel into the plastic bag.

--With wet paper towels or pieces of cloth, wipe the remaining ash and embers from the fireplace floor and
surrounding area two times. Also, wipe all fireplace tools and the artificial logs with damp paper towels or cloths
to remove any possible ash and embers. Put the cloth and towels into the plastic bag.

--Put the face mask or respirator into the plastic bag.

2/22/2010 3:41 PMAsbestos Ban Announced hittp://Aw ww .cpse.gow/CPSCPUB/PREREL/prhtnl77/771 1 8.html

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--Use one piece of string or a “tie” to close the inside plastic bag tightly. Do not try to get the air out of the bag.
Use one piece of string or a tie to close the outside plastic bag.

--All clothing worn while cleaning up should be washed immediately after use. This clothing should be washed
separately from other clothing or household articles. Do not shake clothing before washing. Take a bath or
shower immediately following clean up.

Disposal Of The Plastic Bags
Attach the following label to the bag. Print in large letters:

CAUTION: CONTAINS ASBESTOS. AVOID BREAKING OR PUNCTURING THE BAG.
DO NOT burn the bag in a trash barrel.

DO NOT take the bag to an incinerator.

DO NOT put the bag in a trash compactor,

Call your local environmental services agency, sanitation or health department for instructions on disposal. These
agencies are listed in the white pages of your local telephone directory.

Exemptions
Fake fireplace logs, usually made of pressed wood which can burn, are not included in the CPSC ban.

The U.S, Consumer Product Safety Commission is charged with protecting the public from unreasonable risks of
serious injury or death from thousands of types of consumer products under the agency's jurisdiction. The CPSC
is committed to protecting consumers and families from products that pose a fire, electrical, chemical, or
mechanical hazard. The CPSC's work to ensure the safety of consumer products - such as toys, cribs, power
tools, cigarette lighters, and household chemicals - contributed significantly to the decline in the rate of deaths
and injuries associated with consumer products over the past 30 years.

To report a dangerous product or a product-related injury, call CPSC's Hotline at (800) 638-2772 or CPSC's
teletypewriter at (301) 595-7054. To join a CPSC e-mail subscription list, please go to htlps://www.cpsc.gov
/epsclist.aspx. Consumers can obtain recail and general safety information by logging on to CPSC's Web site at

WWW. CpSC. gov.

Onrcem tere ar ipec ty

Bolu ular)

2/22/2010 3:41 PMEXHIBIT 328

ACKSON CR WALLACE LP
SISPRAA OAKS.

MARK D. SAYRE, ESQ,, State Bar No. 111168
JESSICA A. STEPP, ESQ,, State Bar No. 225830
JACKSON e WALLACE LLP

14724 Ventura Blvd, Suite 1210

Sherman Oaks, CA 91403

Tel: 818.379.4700

Fax: 818.379.4702

Attorneys for Defendant
KAISER GYPSUM COMPANY, INC.

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND POR THE COUNTY OF LOS ANGELES

JOSEPH B. CAVESINA and THOMAS D. Case No. BBC 329514

SMALL,
DECLARATION OF GEORGE B. 1ORK IN

Plaintiffs, SUPPORT OF DEFENDANT KAISER
GYPSUM COMPANY, INC.’S NOTICE OF
we MOTION AND MOTION FOR SUMMARY
JUDGMENT, OR IN THE ALTERNATIVE,
OWENS-ILLINOIS, INC. , et al., MOTION FOR SUMMARY
ADJUDICATION
Defendants.
[Filed Concurrently with Notice of Motion and
Motion jor Summary Judgment; Separate
‘Statement of Undisputed Facts; Slepp
Daciaration]

Hearing Date September 25, 2006
Hearing Time: 8:30 am.
Department: 53

Judge: John P. Shook

Action Filed: February 28, 2005
Trial Date: October 25, 2006

1, George B. Kirk, declare as follows:

Ll. Lam a resident of the State of California, over eighteen years of age and competent
to make this declaration, The facts contained in this declaration are true and correct based upon
my personal knowledge, information and belief.

2. T began employment with Kaiser Gypsum Company, Inc., from the date of its
I

DECLARATION OF GEORGE B. KIRK IN SUPPORT OF
KAISER GYPSUM’S NOTICE OF MOTION AND MOTION FOR SUMMARY JUDGMENT

1878859 }GEORGE KIRK TEL! 209-S86-1603 Jul 07,06 14:00 No.001 P.02

dui-O7-06 13248 From-WILLiAMS KASTNER & GIBBS PLLC BeBeOSESEE THUG P.DaGe OER

formation in 1952, I was Leet in Raiser Gypsum's rescore and development department

ond ultimutely became wt department heal. My rebponsibilitios included developing new

a
3 | drywall produots and improving dxicting drywall products.
4 i 3 In 1973, 1 foot a pomnon a8 dirgoror or process enginvermg With Kaiser Gemem = [__
5 | Corporation. While in fs povition with Kaiser Cement, Lretained rosponsibilities in Kalser
6 || Gypsum'e research and development. department, including responsibilities in the creation of
7 || Kniser Gypsum’s non-asbsatod accessory products,
8 4a Iretired from Kaiser Cement at the end of L978, I have testified as a person with
9 the moot personal knowledge deporting the prodvetb of Raiser Gypsum and Kaiser Camem in
10 | numerous asbestos action.
Wu 5 Kaiser Uy; MUe! Mair budiieey was thé suanutedlure and sale of pypsumebused
12 “Bullaing waters, prinily wallboatds Tbe vant mally oF Kaiaar Gps’ Gypsum’s products never
13 | contained asbeatos, Kaiobr ‘eypouns x never sold wallbonrd or drywall that comained asbestos as an
a | ingrodiont.
18 6. Kaiser Gypsum consed the manutacture and sale of wallboard end wallboard
16 | agoessory praducts in isis.
Ww T @eclare under penaly of perjury under the law of the State of Gulifornia that the

iy
18 |] foregoing is truc and correct and thot thik declaration was executed on July 7. 2006, ar

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MICHAEL T. McCALL, B8Q. State Bar #109580
ROBERT M. CHANNEL, ESQ. State Bar #109273

'ENGRID K. CAMPAGNE, ESQ. State Bar #162164

WALSWORTH, FRANKLIN, BEVINS & McCALL
550 Montgomery Street, Eighth Ficor
San Francisco, CA 94111-2534

(415) 781-7072 :

Attorneys for Defendant
HAMILTON MATERIALS, INC.

SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF SAN FRANCISCO

IN RE: CASE NO. 68268664

COMPLEX ASBESTOS LITIGATION RESPONSES TO PLAINTIFFS
STANDARD INTERROGATORIES FO
ALL DEFENDANTS

Ne me ee et

PROPOUNDING PARTY: Plaintiffa

RESPONDING PARTY: Defendant HAMILTON MATERIALS, INC.

SET NUMBER: General Order No. 129 interrogatories to
Defendants :

DEFINITIONS
1. "ASBEGTOS-CONTAINING PRODUCT(S)" shall mean a product {s)
which THIS DEFENDANT knows or believes to have contained any amount

of the mineral asbestos at any time.

2. "COMPANY" means any private enterprise including
corporation, partnerships, joint ventures, and sole
proprietorships.

3. A "CONTRACT UNIT" shall mean a branch, division,
subsidiary or other affiliated entity of a DEFENDANT which has been

or is now engaged in installation, disturbing or handling and/orremoval of RAW ASBESTOS and/or ASBESTOS-CONTAINING PRODUCTS,

4, “DOCUMENT (S) " or WWRITING($) " ghall include all writings
as defined by Saction 250 of the california Evidence Code.

5. “GEOGRAPHIC AREA" means the 46 counties of Northern
California (Alameda, Alpine, Amador, Butte, Calaveras, Colusa,
Contra Costa, Del Norte, El Dorado, Fresno, Glenn, Humboldt, Kern,
Kings, Lake, “Lassen, Marin, Mariposa, Mendocino, Merced, Modoc,
Mono, Monterey, Napa, Nevada, Placer, Plumas, Sacramento, San
Francisco, San Joaquin, San Mateo, Santa Clara, Santa Cruz; Shasta,
Sierra, Siskiyou, Solano, Sonoma, Stanislaus, Sutter, Tehama,
Trinity, Tulare, Tuolumne, Yolo, Yuba} and military
facilities/installations in the State of California, or the
following shipyards: Bethlehem Shipbuilding, San Pedro; California
Shipbuilding, Terminal Island; Consolidated Steel Shipyard,
Wilmington; Los Angeles Shipbuilding and Dry Dock aka L.A. Ship,
San Pedro; National Steel and Shipbuilding Corporation, San Diego;
Todd Shipyards Corporation, San Pedro; Triple "A" Machine, San

Diego; Western Pipe and Steel Company, Log Angeles and San Pedro

Divisions; Naval Air Station, North Island; Thixty-second Street

Naval Repaix Facility, San Diego; Long Beach Naval Shipyard; and
San Diego Destroyer Base. :
6. A vequest to "IDENTIFY" a "WRITING" or "DOCUMENT" or

‘study shall wean a request to either attach such an exhibit to YOUR

answers to these Interrogatories, or to deseribe such with
sufficient particularity that it may be made the subject of a
request for production of documents. YOUR deseription should
include an indication of: (a) the author; (b) addressee{s); (c)

date of origin; (d) the nature of the writing or document (e.g.,

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letter, telephone memorandum, audio tape recording, photograph,
etc.); and (e) its present location, name and present address of
custodian thereof.

7 AR request to "IDENTIFY" an oral communication shall mean
a wequest to describe the communication with particularity, and
shall include the following information; (a) the identity of all
parties to the communication; {b) the identity of the person whom
you contend initiated the communication; (c) the identity of all
persons present at the time of the communication; and (@) the time,
date and place of the communication.

8, A request to "IDENTIFY" ox to state the "IDENTITY" of a
person or individual means to state his or her name, the place of
employment, job title, present business or present or laat known ;
home address, years of employment and last known telephone number
if not employed by DEFENDANT. .

3. A vequest to "IDENTIPY" the product shall mean a request
to describe the product, the material or compound by the following
means: (1) by nickname or slang name used in YOUR industry and/or
occupation; (2) by the name under which it ia gold in the
marketplace (trade name); (3) by its generic name; and {4) by
manufacturer.

20. "MARKETING" or "MARKETED" shall mean the mining, supply,
sale, labeling, distribution, importing, processing or manufacture
of RAW ASBESTOS and/or ASBESTOS-CONTAINING PRODUCTS (8) .

11. A request to describe the "NATURE" of a product means to
deseribe the {a} color; {b) texture; {c) form (1.6., powder,
liquid, paste, solid, beard, cloth, blanket, wire insulation,

etc.); {ad} physical dimensions, if solid (length, width and

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height); (e) the type of shipping package and shipping package
dimensions if net solid; (f) type of asbestos fiber used in the
composition of _ the product (a.g., chrysotile, amosite,
crocidolite); (g) the intended use or function of such’ preduct as
recommended by this DEFENDANT as the miner, producer, supplier,
contractor, manufacturer, distributor, owner or seller; and (h) the
type of worksite in which it wags intended to be used (e.g.,
shipyard, refinery, commercial building construction, manufacturing
plant, home, power generating plant, etc,).

12. PREMISES" includes, but is not limited to, buildings,
structures ina vefinery, hollers, generators, tract housing,
commercial buildings and other such structures.

23. "RAW ASBESTOS” means asbestos fiber mined or milled,

either packaged or in buik, not compounded with other substances
and esgentially pure with the exception of naturally occurring
trace amounts of other substances. :
. 14. "THIS DEFENDANT" or "DEFENDANT" shall mean the named
defendant herein, all of ite divisions and subsidiaries in which it
holds a controlling interest, and all “alternate entities" ag
defined and identified by name in any complaint pending against YOu
as of the date of YOUR answers.

a5, "you" and “YOUR" refer to the DEFENDANT who is named
above as responding party.

INTERROGATORIES
INTERROGATORY NO. i:
IDENTIFY the person verifying these answers on YOUR behalf.

RESPONSE TO INTERROGATORY NO. 1:

Mx. Eugene Hatz, Vice President, Hamilton Materials, Inc., 345

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West Meats Avenue, Orange, California. 92665.
INTBRROGATORY NO. 2:

State the date of first employment with YOU, and the dates and
titles of each job position the person verifying these
interrogatories has held while employed by YOU.

RESPONSE ENTERROGATORY NO. 2:

Mr. Hatz firat became employed by Hamilton Materials in 1970
as a sales manager apprentice and then later in 1970 as sales
manager. in approximately 1935 or 1986 he gave up the title ‘sales
manager"! and became the acting general manager. Since
approximately 1983, Mr. Matz has also served aa Vice-President and
Secretary of Hamilton Materials,

INTERROGATORY NO. 3:

State whether or nof YOU are a corporation, and if so, state:

A. YOUR correct corporate name;

Be ¥OUR atate of incorporation;

Cc. The date of YOUR incorporation;

De The address of YOUR principal place of husinesa;

z. Whethex ox not YOU have ever held a certificate of

authority to do buginess in the State of California, and if so, the

inclusive dates of any certificate;

B. Y£ 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 TO INTERROGATORY NO, 33

Yes.se

AL Hamilton Materials, Inc,

B. California.

Cc. 1959.

DBD. 345 West Meats Avenue, Orange, California 92665.

z. Hamilton Materials has been licensed to do business in
the State of California since 1959.

F, Not applicable.

e 345 West Meats Avenue, Orange, California 92665.
INTERROGAT: 3

Have YOU ever been identified, known, ox done business under

any other name in the State of California?

RESPONSE TO INTHRROGATORY NO. 4:
’ Yes.

ENTERROGATORY NO. 5:

If YOUR answer to Interrogatory No. 4 is in the affixmative,
please state such name or names and the time period during which
THIS DEFENDANT was known or identified.

RESPONSE TO INTERROGATORY NO. 5:

Two California corporations, Hamilton Materials and Hamilton
Distributing, existed from 1959 until 1983. In 1983, Hamilton
Distributing was merged into Hamilton Materials.
INTERROGATORY NO. 6:

rf YOU are not a corporation, what is YOUR business structure
(partnership, joint venture, sole proprietorship, etc.}?

ONS: NDERR! NO t

Not applicable.

RROGATORY NO. 7:

T£ YOU are not a corporation, please IDENTIFY all persons or

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other entities with an ownership interest in YOU.
RESPONSE TO INTERROGATORY NO. 7+
, Not applicable.

ENTERROGATORY NO. 8+

If YOU are not a coxporation, please state the following:

A. The address where the HISTORICAL RECORDS of THIS
DEFENDANT are currently located; and

B. The name, job title and current addresa of the Custodian
for THIS DEFENDANT’S HISTORICAL RECORDS.

As used herein, “HISTORICAL RECORDS" shall include all
DOCUMENTS relating to the formation of THIS DEFENDANT, ali minutes

of partners’, general partners’, or other owners’ meetings, and all
P

“NOCUMENTS relating to THIS DEFENDANT’s merger with, acquisition of

ox purchase, ox sale of or by any other COMPANY.
RESPONSE TO _INTERROGATORY NO. 8:

Not applicable.
ENTERROGATORY NO. 9:

IDENTIFY YOUR custodian of Business Records.
RESPONSE TO INTERROGATORY NO. 9+

Mr. Eugene Hatz, Vice President, Hamilton Materials, Inc., 345
West Meats Avenue, Orange California 92665,
INTERROGATORY NO. 410:

IDENTIFY the person or persons most knowledgeable about:

A. YOUR acquisition of RAW ASBESTOS and/or ASBESTOS~-
CONTAINING PRODUCTS;

B. YOUR use of RAW ASBESTOS and/or ASBESTOS-CONTAINING
PRODUCTS ;

a. YOUR contracting with others to do work involving use or

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‘handling of RAW ASBESTOS and/or ASBESTOS-CONTAINING PRODUCTS;

RESPONSE TO INSERROGATORY NO. 1.0:

Mr. Eugene Hatz, Vice President, Hamilton Materials, Inc., 345
West Meats Avenue, Orange, California 92556.

INTERROGATORY NO. ii:

For DEFENDANTS involved in the MARKETING of ASBESTOS-
CONTAINING PRODUCTS, state the IDENTITY of 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 ox physicians
employed in the area of employee health and safety. PREMISES
ownera and domestic corperations need only respond as to the United
States.

RESPONSE TO INEBRROGATORY NO. dd:

None.

ENTERROGATORY NO. 12:

Has any employee of THIS DEFENDANT testified by deposition or
at trial on behalf of THIS DEFENDANT in a third-party cane, din
which THIS DEFENDANT was a party, wherein the plaintiff has alleged
an asbestos-related injury? If so, for each such third-party case
(except that Premises Defendants and Contractor Defendants need
answer only with respect to cases relating to sites within the
GEOGRAPHIC AREA) please state:

A. the caption and case number;

B. The court filing including state and county;

qc. The date of deposition or trial testimony;

Dd. The name and address of plaintiff's counsel of record;

=Besw

E. The name and address of the court reporter.

RESPONSE, TO SNTERROGATORY NO. 12:
Deposition of Eugene Hatz:

A. Ponsaid B. Strawn and Anita P. Strawn vs. Pibreboard Corp...
et al., Case NO. €85-539T;

B. United States District Court,Western District of
Washington at Tacoma;

Cc. December 5, 1986;

D. Schroeter, Goldmark & Bender, P.S., by William Rutzick,
ESQ,, $40 Central Building, Third & Columbia Streets, Seattle,
Washington 98104;

B. Kathleen s. McLaughlin, CSR #5845, Hahn and Bowersock,
4029 Westerly Place, Suite 113, Newport Beach, CA 92660.
Deposition of Eugene Hatz: :

A. Clemson University, et al. vs. W.R. Grace and Co.. et al.,
Case No. #86-2055~-2;

B. United States District Court For the District of South
Carolina;

-G Decenber 15, 1986;

QD. Blatt and Pales, A Professional Asaociation, by J.
Angerson Berly 111, 174 Rast Bay Street, Charleston, South Carolina
29464;

E. Charmaine M. Whalen, CSR #6133, Amack, Shorthand Reporting
Corporation, 1519 Bast Chapman Avenue, Orange, CA 92666.
Deposition of Hugene Hatar

A. Harmon George Ford ov. Qwens- Corning Fibarqias
Corporation, et al., Case No. SOC 66188;

8, Superior Court of the State of California in and for the

9.a mob

County of Los Angeles;

Cc. January 15, 1987;

D. Nordstrom, Steele and Jefferson, by Allan K. Nicolette,
BSQ., 4526 Wilshire Bivd., Los Angeles, CA 90010;

BE. Betty Olsen, CSR #3555, Pelletier and Jones, 3200 W. ara
Street, Los Angeles, CA 90020.
Deposition of Willis Hamilton:

A Frank J. Vukasin, Jr. v. Georgia Pacific Cornoration, et
1., Case No, #RVD-86-943;

B. The Bighth Judicial District of the State of Montana for
the County of Cascade;

a. dune 9, 1987;

DB. Blatt and Fales, by J. Anderson Berry III, 174 East Bay
Street, Suite #100, Charleston, South Carolina 25402;

E. dulie K. Knowlton, CSR #6021, Amack, Shorthand Reporting
Corporation, 1519 East Chapman Avenue, Orange, CA 92666.
Deposition of Eugene Matz (Volumes 1-4):

 A-~B. Iona Cunningham, et. al. v. Hamilton Materials, Case No.
781433-2; yn Re: Complex Asbestos Litigation, Superior Court of the
State of California, for the County of San Francisco, Case No.
828684; In Re: Complex Asbestos Litigation, Superior Court of the
State of California for the County of Alameda, Case No. 607734~3;7
In Re: Shipyard and Applicator Asbestos Cases, Superior Court of
the State of California, for the County of Alameda, Case No.
537868-7.

G. December 5, 1996; December 6, 1996; January 9, 1897;
January 10, 1997;

ve Kazan, McClain, Edises, Simon and Abrams, by Ronald J.

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Shingler, ESQ., 171 Twelfth Street, 3xd Floor, oakland, California
94607; / :
HE. Martha U. Smith, CSR. #8992, Atkinson-Baker Court
Reporters, 330 N. Brand Blvd, Suite #250, Glendale, CA 91203.
Deposition of Willie Hamilton;
A-B. Iona Cunningham, et. al. v. Hamilton Materials, Case No.
751213-2; In Re: Complex Asbestos Litigation, Superior Court of the

State of California, for the County of San Francisco, Case No.
828684; In Re: Complex Asbestos Litigation, Superior Court @£ the
State of California fox the County of Alameda, Case No. 607734-9;
In Re: Shipyard and Applicator Asbestos Cases, Superior Court of
the State of California, for the County of Alameda, Case No.
537868-7.

Cc. December 4, 1996; January 7, 1997; January 8, 1997;

Dd. Kazan, McClain, Edises, Simon and Abrams, by Ronald J.
Shingler, BSQ., 171 Twelfth Street, 3axd Floor, Oakland, California
94607;

E. Martha &, smith, CSR #8992, “Atkingon-Bakex court
Reporters, 330 N. Brand Blvd, Suite #250, Glendale, CA 91203.
INTER! TORY NO. 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 ox ASBESTOS-CONTAINING
PRODUCTS discontinued ‘the MARKETING of such products, THIS
DEFENDANT was a member or paid dues fox any representative of THIS
DEFENDANT (excluding faculty members of educational institutions)
to be a member of the following:

A. American Conference of Governmental Industrial

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Hygienists;

%. American Industrial Hygiene Association;

C. American Petroleum Institute;

Dd. American Railroad Association;

E. Asbestos Cement Producers Association;

F. Asbestos Information Association

through date of your answers);

{AIA) (please answer

G, Asbestos Information Association/North America {AIA/NA)

(please answer through date of your answexs) ;

H. Asbestos Textile Institute (ATI);

Ir. Industrial Hygiene Foundation and/or Industrial Health

Foundation (EHF) ;

“a. Industrial Mineral Insulation Manufactures Institute;

K. Magnesia. Insulation Manufacturers’ Association;

ot. Magnesia Silica Insulation Manufacturers Association;

M. Mineral Wool Inatitute;

LN, National Insulation Manufacturers Association (NIMA);

oO. National Safety Council;

P. New York Academy of Sciences;

Q@. Quebec Asbestos Mining Association (QAMA);

R. Refractories Institute;

a. Safe Building Alliance (please answer through date of

your answers) 7

Y, Thermal Insulation Manu£acturers Association {(TIMA);

U. U.S. Maritime Commisgion;

Vv. IDENTIFY any other organizations, associations or groups

of manufacturers,

miners,

distributors,

importers,

labelers,

suppliers, and/or sellers of ASBESTOS-CONTAINING PRODUCTS of which

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{THIS DEFENDANT was a member;

WwW. IDENTIFY any such representative of THIS DEFENDANT.
RE Tr OGATORY NO. 13:

A-U. No.

Vv. None.

W. Not applicable.
ENTERROGATORY NO. 14:

For each organization, association or other entity identified

in YOUR Response to Interrogatory Ne. 13, please state:

A. The dates during which THIS DEFENDANT was a member;

B. The name(s) of any publication(s) received by THIS
DEFENDANT from such association or organization;

a. The name of any committee or subcommittee of which THIS
DEFENDANT was @ member, and the dates of such committee or
subcommittee mewbership.

ERROG! 3

Not applicable.
SNTERROGATORY NO. 15:

Had THIS DEFENDANT prior to 1973 received any DOCUMENTS
containing results ex conclusions of any studies and/ox tests
conducted by Bonsib for Standard Oi1 of New Jersey ‘relating to
asbestos exposure in the workplace or the human heaith 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

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production of documents;

B. State the date upon which THIS DEFENDANT first received
such DOCUMENTS;

€. State the IDENTITY of the custodian of such DOCUMENTS;

Dd. This interrogatory does net apply to DOCUMENTS contained
in a library maintained by a DEFENDANT hospital or a DEFENDANT’s

library providing access to the general public.

RESPONSE TO INTERROGATORY NO. 15:
No. ,

TMTERROGATORY NO. 16:

_ Had THIS DEFENDANT prior toe 1973 received a copy or any
portion of any studies and/or tests conducted by any 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?
TE sor

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) deseribe such DOCUMENTS with sufficient
particularity that they may be made the subject of a request for
production of documents;

B. State the date upon which THIS DEFENDANT first received
such DOCUMENTS;

c. State the IDENTITY of the custodian of such DOCUMENTS;

R. This interrogatory does pot apply to DOCUMENTS contained
in a library maintained by a DEFENDANT hospital or a DEFENDANT‘s

library providing access to the general public.

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RESPONSE TO INTERROGATORY NO. 216:

No.
INTHRROGATORY. set

Had THIS DEFENDANT prior to 1973 xeceived 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
er the human health consequences of exposure to asbestos? If so:

A. Either (1) ‘attach all DOCUMENTS evidencing the
information sought in this Interrogatery 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. State the date upon which THIS DEFENDANT first received
such DOCUMENTS ;

C, State the IDENTITY of the custodian of such DOCUMENTS;

D. This interregatory does not apply to DOCUMENTS contained
in a library maintained by a DEFENDANT hospital or a DEFENDANT’s
library providing access to the general public.

RESPONSE TO _ INTER! TORY 73
No.
INTERROGATORY NO. 18:

Had THIS DEFENDANT (except for a defendant that is an
educational institution) 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

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occupational disease? If so, state:

a. The date each such library wae established;

B. The location of each such library;

a. The IDENTITY of each librarian or other person in charge
of such library.

RESPONSE TO. INTERROGATORY NO. 18:

A. Since it came into existence in 1959, Hamilton Materials
has maintained literature relevant to the types of products it has
manufactured and chemical constituents of those types of products
when such literature would come to Hamilton’s attention, Any such
documents currently in Hamilton’s possession were produced at tha
depositions of Mr. Willig Hamilton and Mr, Bugene Hatz under the
"In re Complex Asbestos Litigation" captions for San Francisco and
Alameda Superior Courts im December 1996 and January 1997.

B. 345 West Meats Avenue, Orange, California 92665,

a. Mx. Eugene Hatz, Vice President, Hamilton Materials, Inc.

INTERROGATORY NO. 319:

With the exception of OSHA compliance, had THIS DEFENDANT
(except for a defendant that is an educational institution) prior
to 1980 exchanged DOCUMENTS or commumicated with any person or
other COMPANY expresaly 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;

Be The date{s) of any such exchanges or communications;

c, The IDENTITY of the custodian of such DOCUMENTS.

Vit

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RESPONSE ZO INTERROGATORY NO. 19:

B- 3B. Responsive document exchanges and communications are
discussed in detail in the "In re Complex” depositions of Mr.
Willie Hamilton and Mr. Eugene Hatz taken in December 1996 and
January 1997.

a. Mr. Bugene Hatz, Vice President, Hamilton Materials, Inc.
INTERROGATORY NO. 20:

Has any employee or designes of THIS DEPENDANT testified as a
representative of THIS DEFENDANT before the Occupational Safety and
Health administration, the National Institute of Occupational
Safety and Health, or any committee or subcommittee of the United
States congresa relating to asbestos exposure in the workplace or
the human health consequences of exposure to. asbestos? If so,
please state:

a. fhe entity before whom such testimony was given;

B. The date(s} and location(s) of such ‘testimony;

a. The IDENTITY of the individual(s) who so testified;

D. Whether any DOCUMENTS were presented to the entity before
which testimony was given;

a Whether copies of DOCUMENTS presented were retained by
THIS DEFENDANT and, if so, state the IDENTITY of the custodian of
such DOCUMENTS.

RESPONSE TO INTERROGATORY NO. 20+

No.

ZNTERROGATORY NO. 21:

Hage THIS DEFENDANT (except for a defendant that is an
educational institution) conducted, or caused to be conducted,

tests, and/or studies of ambient asbestos dust created during the

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manufacture, processing and/or assembling for sale of ASBESTOS-
CONTAINING PROMUCTS? If so, sbate:

A. Bach manufacturing facility, . including location and
address, at which any such test and/or study was conducted;

B. The date of each such test and/or study;

c. The individual(s) or entity conducting sach such test
and/or study;

QR. Whether THIS DEFENDANT has any DOCUMENTS containing the
results and/or conclusions of each such study;

Ee The IDENTITY of the custodian of such DOCUMENTS.
RESPONSE TO INTERROGATORY NO. 245

No. |

“INTERROGATORY NO. 22:

Has THIS 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 PRODUCTS were
installed, utilized or removed? If so, for the first 5 tests
and/or studies, state:

A. ‘The location, including name and address, at which each
such test and/or study was conducted;

B, fhe individual(s) or entity gonducting each such test
and/or study;

. The date of each such test and/or study;

D. Whether THIS DEFENDANT hag any DOCUMENTS containing the
results and/or conclusions of each such test and/or study;

BE. The IDENTITY of the custedian of such DOCUMENTS.
tit

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RESPONSE TO INTERROGATORY NO. 22:

No. :
ENTERROGATORY NO. 23:

Did THIS DEFENDANT {except for a defendant that is an
educational institution) have any laboratory or other similar type
of facility anywhere in the United States at which it conducted, or
caused to be conducted, any testa 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 PRODUCTS. If so, state:

A. The location, including name and address, at which each
such test and/or study was conducted;

3B. The individual(s) ox entity conducting each such test
and/or study;

Cc, The date of each such test and/or study;

Bw. Whether THIS DEFENDANT has any DOCUMENTS containing the
results and/or conclusions of each such teat and/or study;

KB. The IDENTITY of the custodian of such DOCUMENTS .

RESPO! Ri + 23%

No.

INTERROGATORY NO. 24:

Has THIS DEFENDANT made available to its employees a medical
examination program to determine the absence or presence of
‘asbestos-related disease? If so, state:

A. Whether chest x~xays or pulmonary function tests were
part of such program(s);

B. Whether participation in any such program was a mandatory

condition of employment ox was voluntary;

“18-a. Whether THIS DEFENDANT has DOCUMENTS of such program(s};
QR. The IDENTITY of the custodian of such DOCUMENTS.

RESPONSE TO INTERROGATORY NO. 24+
No.

ENTERROGATORY NO. 25;

Prior to 1973, did any person file a Workers' Compensation
claim for asbestos-related injury against THIS DEFENDANT or against
any Workexa! Compensation inauresice carrier which provided coverage
for THIS DEFENDANT? If so, state the total number of such claims
and, for the first 20 such claims state:

A. The date of such claim;

B, The name of the claimant;

c,. -The case number;

D. The court in which the claim was filed;

g. The IDENTITY of THIS DEFENDANT's custodian of DOCUMENTS
evidencing such claims.

ONSE TO INTERROG. 3

No-

SINTERROGATORY NO. 26:

Does THIS DEFENDANT have insurance available to cover
judgment (s) entered against it in asbestos-related personal injury
lawauits? If so, state:

A. The name and principal place of business of any insurance
carrier who has issued such policy of insurance;

B, ‘The number and effective date of each policy;

c. The amount (s) of coverage of each policy;

DB. The applicable dates of coverage.

“tt

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RESPONSE IO 7 2 TOR! - 261

Yea. Investigation is continuing and Hamilton will supplement
this response. ,
INTERROGATORY NO. 27:

State whether YOU have controlled, purchased, or in any way
acquired any 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 PRODUCTS in the stream of commerce.
If so, state:

A. The name and address of said cerporation or business
entity;

‘B. The dates YOU controlled, purchased or acquired any
interest; and

c. The nature of the business ag it pertains to asbestos,

BO INTHRROGAT [Os : ,

No.

INTERROGATORY, NO. 283

State whether THIS 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;

B. Milling;

c Supply;

dD. Importing;

E. processing;

F. Distribution;

a. Marketing;

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H. Sale;

mr. Brokering.

RESPONSE TO 0G! x 28:
No.
NIERRt 293

If YOUR anawer to any of subparts of Interrogatory No. 28
regarding RAW ASBESTOS ia in the affirmative, state:
aA. The trade, brand name, and/or generic name of such RAW
ASRESTOS milled or MARKETED in any form or 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. On an experimental basis;
2, On a test basis; :
3. For sale.
a , The date(s} such RAW ASBESTOS:
i. Ceased to be produced; or
2 Was vecalied from the market, if ever,

D. A description of the chemical composition of such RAW

” ASBESTOS, including the type and/or grade of asbestos;

EB. A description of the physical appearance and nature of
such RAW ASBESTOS, including any colox coding, distinctive marking
and/or lego on the packaging or container;

B. A detailed description of the intended use of such RAW
ASBESTOS, including any temperature limita for each such use;

@. Whether such RAW ASBESTOS was on the U.S. Government's
"Qualified Products List," and if so, the inclusive dates it was on

such list;

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H. IDENTIFY to whom such RAW ASBESTOS has, at any time, been |
Sold. As to each such, state:

I. Whether any of THIS DEFENDANT’s RAW ASBESTOS has, at any
time, been gold, shipped, or otherwise distributed, used or
installed to of at any COMPANY (including power company or
utility), governmental agency or entity, shipyard, distributor,
refinery, contracter, supplier, PREMISE owner or occupant, ship
owner, or other PREMISE ox gite 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. 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 or brand name of such RAW ASBESTOS
Bold;

3. The manner of shipment (e.g. boat, rail, ete.);

4. Whether YOU have any records indicating any such
gale or shipment and, if so, the name, address and job
classification of each person who currently has possession of such
records;

5. Eithexs (1) attach all DOCUMENTS evidencing the
information sought in this Interrogatory and ita 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.

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RESPONSE TO INTERROGATORY NO. 29;

Not applicable.
ENTERROGATORY NO. 30:

Between 1930 and 1985, did YOU ever engaged in any of the
activities listed below with regard to ASBESTOS-CONTAINING
PRODUCTS? If so, state the inclusive dates of such activity:

Ar Supply;

B. Importing;

c. Distribution;

Dd. Maxketing;

gE. Sale;

F. Labeling;

a Manufacturing;

RH. Brokering.

RESPONSE TO INTERROGATORY NO. 30:

A. Some products supplied by Hamilton contained a small
percentage of chrysotile fiber from no earlier than 1959 until no
later than 1977. :

B. Wo.

c. Some products distributed by Hamilton contained a small
percentage of chrysotile fiber from no earlier than 1959 until no
later than 1977.

D. Some products marketed by Hamilton contained a small
percentage of chrysotile fibex from no earlier than 21959 until no
later than 1977.

Ez Some products sold by Hamilton containe@ a small
percentage of chrysotile fiber from no earlier than 1959 until no

later than 1977.

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F, Some products labeled by Hamilton contained a small
percentage of chrysotile fiber from no earlier than 1959 until no
latex than 1977. :

SG. Some products manufactured by Hamilton contained a small
percentage of chrysotile fiber from no earlier than 1959 until no
later than 1977.

H. No.

ENTERROGATORY NO. 31:

TE YOUR answex to any subpart of Interrogatory No. 30
regarding ASBESTOS~CONTAINING PRODUCTS is in the affirmative,
state:

A. 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. The date(s) each such ASBESTOS-CONTAINING PRODUCT was
first placed on the market, including the date(s) each “such
ASBESTOS-CONTAINING PRODUCT was first MARKETED;

1. On an experimental basis;
2. On a test basis; or
3. For sale.

Cc. The date(s} each such ASBESTOS-CONTAINING PRODUCT:

ke Ceased to be produced; or
2. Was recalled from the market, if ever.

Dd. A description of t