Exhibit,Appendix: 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. ee Bar #260852)
YARON & ASSOCIATES

601 California Street, 21* Floor

San Francisco, California 94108

Telephone: (415) 658-2929

Facsimile: (415) 658-2930

Attorneys for Defendant
84 LUMBER COMPANY

ELECTRONICALLY
FILED

Superior Court of Califotnia,
County of San Francisto

FEB 26 201

Clerk of the Cou
BY: CHRISTLE ARRIO!
Deputy Clerk

SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN FRANCISCO

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

v.
ASBESTOS DEFENDANTS (BP) As)

Reflected on Exhibits B, B-1, C; and DOES 1-)
8500; and SEE ATTACHED LIST,

Saat el

Defendants.

Se ee

CASE NO. CGC-09-275212

EXHIBIT I THROUGH J TO
DECLARATION OF MICHAEL J.
PENG IN SUPPORT OF 84 LUMBER:
COMPANY’S MOTION FOR
SUMMARY JUDGMENT, OR, IN THE

ALTERNATIVE, SUMMARY

ADJUDICATION OF ISSUES

Hearing Date: March 18, 2010

Hearing Time: 9:30 a.m.

Depart. No.: 220

Hearing Judge: Hon. Harold E.
Kahn

Date Action Filed: | May 20, 2009

Date Set For Trial: April 5, 2010EXHIBIT ISAN JOAQUIN COUNTY BUILDING.

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

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

WALSWORTH, FRANKLIN, BEVINS & McCALL
550 Montgomery Street, Eighth Floor
San Francisca, CA 94111-2534

(415) 784-7072

Attorneys for Defendant
HAMILTON MATERIALS, INC.

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

IN RE: CASE NO. 628684

COMPLEX ASBESTOS LITIGATION RESPONSES TO PLAINYiIFRS’
STANDARD INTERROGATORIES TO
ALL DEFENDANTS

PROPOUNDING PARTY: Plaintiffs

RESPONDING PARTY: Defendant HAMILTON MATERIALS, INC.

SET NUMBER: General Order No. 129 interrogatories to
Defendants
DEFINITIONS
1. “ASBESTOS-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" weans 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/orwon

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removal of RAW ASBESTOS and/or ASBESTOS-CONTAINING PRODUCTS,

4. "DOCUMENT (8) " ox “RITING (8) " shall include all writings ,
as defined by Section 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, Bl Dorado, Fresno, Glenn, Humboldt, Kern,
Kings, Lake, Lassen, Marin, Mariposa, Mendocino, Merced, Modoc,
Meno, 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 o£ 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, Los Angeles and San Pedro
Divisions; Naval Air Station, Nocth Island; Thirty-second Street
Naval Repair Facility, San Diego; Long Beach Naval Shipyard; and
San Diego Destroyer Base. ,

6, A request to "IDENTIFY" a "WRITING" or "DOCUMENT" or

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

answers to these Interrogatories, ox to describe such with
sufficient particularity that it may be made the subject of a
request for production of documenta. YOUR description 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,
ete.); and ({e) ita present location, name and present address of
custodian thereof.

q. A request to "IDENTIFY" an oral communication shall mean
a request to describe the commmication 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 (d) the time,
date and place of the communication.

8. A request to "IDENTIFY" or 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 last known

home address, years of employment and last known telephone number
if not employed by DEFENDANT.

3, A request to "IDENTIFY" 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 is sold 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 (S) .

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

etc.); (a) physical dimensions, if solid (length, width and

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height); (e) the type of shipping package an@ shipping package
dimensions if net solid; (£) type of asbestos fiber used in the
composition of the product {e.g., chrysotile, amosite,
erocidolite); {g) the intended use or function of such product as
recommended by this DEFENDANT as the miner, producer, supplier,
contractor, manufacturer, distributor, owner or seller; and th) the
type of worksite in which it was 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, boilers, generators, tract housing,
commercial buildings and other such structures.

23, "RAW ASBESTOS" means asbestos fiber mined or milled,
either packaged or in bulk, not compounded with other substances
and essentially 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 ita divisions and subsidiaries in which it
holds a controlling interest, and all “alternate entities" aq
defined and identified by name in any complaint pending against You
as of the date of YOUR answers.

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

ENTERROGATORIES
ENTERROGATORY NO. 1:

IDENTIFY the person verifying these answerg on YOUR behalf.

RESPONSE TO INENSRROGATORY NO, 1:

Mr. Bugene Hatz, Vice President, Hamilton Materials, Inc., 345

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

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

RESPONSE, SO _ EINTERROGATORY NO. 2+

Mr. Hatz first became employed by Hamilton Materials in 1970
as a sales manager apprentice and then later in 1970 as sales
Manager. In approximately 1985 or 1986 he gave up the title "sales
manager" and became the acting general manager. Since
approximately 1983, Mr. Hatz hag also served as Vice-President and
Secretary of Hamilton Materials.

INTHRROGATORY NO. 3:

State whether or not YOU are a corporation, and if so, state:

B. YOUR correct corporate name;

Be YOUR state of incorporation;

GQ The date of YOUR incorporation;

D. The address of YOUR principal place of business;

EB, Whether or not YOU have ever held a certificate of

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

inclusive dates of any certificate;

¥. 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;

a Whether YOU have any business offices in California,

“and, if so, YOUR principal place of business in California.

RESFONSE TO INTHERROGATORY NO. 33

Yes.A. Ramilton Materials, Inc.

B. California.

c. ig5e.

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

z, Hamilton Materials has been licensed te do business in
the State of California since 1959,

F, Not applicable.

6. 345 West Meats Avenue, Orange, California 92665.
INTERROGATORY NO. 4:

Have YOU ever been identified, known, or done business under
any other name in the State of California?

RESPONSE TO GATORY NO. 4:

Yes.

INETERROGATORY NO. 5:

If YOUR answer to interrogatory No. 4 is in the affirmative,
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 Materiale and Hamilton
Distributing, existed from 1959 until 1983. In 1983, Hamilton
Distributing was merged into Hamilton Materials.
INTERROGATORY NO. 6:

If YOU are not a corporation, what is YOUR business structure
(partnership, joint venture, sole proprietorship, etc.}?
RESPONSE TO INTERRQGATORY NO, 3

Not applicable.

INTERROGAT' :
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 INTENROGATORY NO. 7:
: Not applicable.

INTERROGATORY NO. 8;

T£ 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 cf THIS DEFENDANT, all minutes

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

‘DOCUMENTS relating to THIS DEFENDANT’s merger with, acquisition of

or purchase, or sale of or hy any other COMPANY.
RESP: iE = NO. 8:

Not applicable.
ZNTERROGATORY NO. 9+

IDENTIFY YOUR custodian of Business Records.
OGATORY NO. 9

Mr, Eugene Hatz, Vice President, Hamilton Materials, Inc., 345
West Meats Avenue, Orange California 92665.
INTER! TO) 10:

IDENTIFY the person or persons most knowledgeable about:

Ae YOUR acquisition of RAW ASBESTOS and/or ASBESTOS-
CONTAINING PRODUCTS;

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

c. 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 INTERROGATORY NO. 10:

Myr. Eugene Hatz, Vice President, Hamilton Materials, Inc., 345
West Meats Avenue, Oxange, California 92556,
INTERROGATORY NO. 11

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 or physicians
employed in the area of employee health and safety. PREMISES

owners and domestic corporations need only respond as to the United

States.
RESPONSE TO INTERROGATORY NO, 31:
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 case, in
which THIS DEFENDANT was a party, wherein-the plaintiff hae 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;

c. The date of deposition or trial testimony;

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

“BHa

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E. The name and address of the court reporter.

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

Ae 1. and Anita P. vs. Fi
et al., Case NO. C85-539T;

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., S40 Central Building, Third & Columbia Streets, Seattle,
Washington 98104)

E. 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, va. W.R. Grace and Co., et al.,
Cape No, #86-2055-~-2;

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

Cc. December 15, 1986;

vb. Blatt and Fales, A Professional Association, by J.
Anderson Berly III, 174 Hast Bay Street, Charleston, South Carolina
29464;

&. Charmaine M. Whalen, CSR #6133, Amack, Shorthand Reporting
Corporation, 1519 East Chapman Avenue, Orange, CA 92666.
Deposition of Eugene Hatz:

AL Harmon __ George Ford  v. Owens -Corning  Fiberqlas
Corporation, et al., Case No. SOC 66188;

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

-9-County of Los Angeles;

c. January 15, 1987;

DR. 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. 3rd
Street, Los Angeles, CA 90020.

Deposition of Willis Hamilton:

A. Frank J. Vukasin, Jx. v. Georgia Pacific Corporation, et
al., Case No. #RBVD-86-943;

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

¢. dune 9, 1987;

D. Blatt and Fales, by J. Anderson Berry III, 174 Hast Bay
Street, Suite #100, Charleston, South Carolina 29402;

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

A-B. Iona Cunningham, et. al. v. Hamilton Materials, Case No.
751113-2; In Re: Complex Asbsetos 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. 607734~9;
In Re: Shipyard and Applicator Asbestos Cases, Superior Court of
the State of California, for the County of Alameda, Case No.
537868-7.

c. Dacember 5, 1996; December 6, 1996; January 9, 1997;
January 10, 1997;

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

-10-Shingler, ESQ., 171 Twelfth Street, ard Floor, Oakland, California
94607; /

EB. Martha 4. Smith, CSR. #8992, Atkinson-Baker Court
Reporters, 330 N. Brand Blvd, Suite #250, Glendale, CA 91203.
Deposition of Willis Hamilton;

A-B. Iona cu mningham, et. al. vy, Hamiiton Materials, Case No.
751113-2; 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 of the
State of Califoxnia for 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.
53 7868-7.

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

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

E. Martha 4b. Smith, CSR #8992, Atkingson-Baker Court
Reporters, 330 N. Brand Blvd, Suite #250, Glendale, CA 91203.
INTERROGA, Y NO. 135

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 for 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;

B.
G.
D.
Ke
B

through

e.

(please
H.

I.

American Industrial fygiene Association;

American Petroleum Institute;

American Railroad Association;

Agbestos Cement Producers Association;

Asbestos Information Association (AIA) (please answer
date of youx answers);

Asbestos Information Association/North America {AIA/NA)
answer through date of your answers) ;

Asbestos Textile Institute (ATI);

Industrial Hygiene Foundation and/or Industrial Health

Foundation (IHF) ;

a.

R.

Industrial Mineral Insulation Manufactures Institute;
Magnesia Insulation Manufacturers’ Association;
Magnesia Silica Insulation Manufacturers Association;
Mineral Wool Institute;

National Insulation Manufacturers Association (NIMA);
National Safety Council;

New York Academy of Sciences;

Quebec Asbestos Mining Association ({QAMA);
Refractories Institute;

Safe Building Alliance (please answer through date of

your answers);

T.
ue

v.

Thexmal Insulation Manufacturers Association (TIMA);
U.S. Maritime Commission;

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 DEPENDANT was a member;

WwW. IDENTIFY any such representative of THIS DEFENDANT.
RE; IN TO_INTERROGATORY NO. 2133

A-U. No.

Vv. None.

Ww. Not applicable.
INTERROGRTORY NQ. 143

Fox each organization, association or other entity identified

in YOUR Response to Interrogatory No. 13, please state:

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

a. The name(s) of any publication{s) received by THIS
DEFENDANT from such association ox organization;

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

RESPONSE TO INTHRROGATORY NO. 14:

Not applicable.
INTERROGATORY NO. 25:

Had THIS DEFENDANT prior to 1973 yeceived any DOCUMENTS
containing results or conclusions of any studies and/or tests
conducted by Bonsib for Standard Oj1 of New Jersey ‘relating to
asbestos exposure in the workplace or the human health consequences
of exposure to asbestos? If so: ,

Ae Either (1) attach all DOCUMENTS evidencing the
information sought in this Interrogatory and its subparts to your
answers to these interrogatories, ox (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 documenta;

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

c State the IDENTITY of the custodian of such DOCUMENTS;

DQ. This interrogatory does not apply to DOCUMENTS contained
in a library maintained by a DEFENDANT hospital or @ DEFENDANT’s
library ‘providing access to the general public.

ESPONSE TO INTERROGA'T jO. 25:

No.

JNTBRROGATORY NO. 16:

Had THIS DEFENDANT prior to 1973 received a copy or any
portion of any studies and/or tests conducted by any insurance
company, including but not limited te Metropolitan Life Insurance
Company and Aetna Insurance relating to asbestos exposure in the
workplace or the human health consequences of exposure to asbestos?
Tf se;

AL 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) desexibe 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
guch DOCUMENTS ;

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

D. This interrogatory does yot apply te DOCUMENTS contained
in a library maintained by a DEFENDANT hogpital or a DEFENDANT’s

library providing access to the general public.

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RE is CO INTERROGAT: + 16%

No.

SNTERROGATORY NO. 7:

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 ashestos? If so:

A. Bither (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. State the date upon which THIS DEFENDANT first received
such DOCUMENTS +

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

DB. This interrogatory 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 INTERROGATORY NO. 27:

No.

INTERROGATORY NO. 18+

Had THIS DEFENDANT (except for a defendant that is an
educational institution) prior to 1973 ever maintained a library
(ox libraries) which contained hooks, 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 aach such library was established;

B. The location of each such library;

@. The IDBNTITY of each librarian or other person in charge
of such library.

RESPONSE TO TNTERROGATORY » 28:

AL Since it came into existence in 1959, Hamilton Materials
hae maintained literature relevant to the types of producte 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 the
depositions of Mr. Willis Hamilton and Mr, Bugene Hatz under the
"In re Complex Asbestos Litigation" captions for San Francisco and
Alameda Superior Courts im Recember 1996 and January 1997.

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

a Mx. Eugene Hatz, Vice President, Hamilton Materials, Inc.
XINTERROGATORY NO. 19:

With the exception of OSHA compliance, had THIS DEFENDANT
(except for a gefendant that is an educational institution) prior
to 1980 exchanged DOCUMENTS or communicated with any person or
other COMPANY expressly xegarding the resulte of tests and/or
studies relating te asbestos exposure in the workplace or the human
health consequences of exposure to asbestos? If so, state:

aA. Bach person ox COMPANY with whom the information was
exchanged or to whom it was communicated;

B. The date(s) of any such exchanges or communications;

C. The IDENTITY of the custodian of such DOCUMENTS.

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RESPONSE TO INTERROGATORY NO. 19:

A- B. Responsive document exchanges. and communications are
discussed in detail in the "In re Complex” depositions of Mr.
willis Hamilton and Mr. Eugene Hatz taken in December 1936 and
January 1997.

C. Mx. Bugene Hatz, Vice President, Hamilton Materials, Inc.
INTERROGATORY NO. 20:

Has any employee or designee of THIS DEFENDANT testified as a
representative of THIS DEFENDANT before the Occupational Safety and
Health Administration, the National Institute of Occupational
Safety and Health, ox any committee or subcommittee of the United
States congress relating to asbestos exposure im the workplace or
the human health consequences of exposure to asbestos? If s0,
please state:

Ae The entity before whom such testimony was given;

Be The date(s) and location(s) of such testimony;

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

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

E. 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,
INTERROGATORY NO. 21:

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

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

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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 such test and/or study was conducted;

3. The date of each auch test and/or study;

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

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

E. The IDENTITY of the custodian of auch DOCUMENTS.
% TO INTER ai:

No.

, ‘ERROGATORY 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:

Ae The location, including name and address, at which each
guch test and/or study was conducted;

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

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

DB. Whether THIS DEFENDANT has any DOCUMENTS containing the
vesults and/or conclusions of each auch test and/or study;

E. The IDENTITY of the custedian of such DOCUMENTS.

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RESP! GATORY NO. 22:

No.
INTERRO 23t

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 tests and/or studies cf 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;

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

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

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

E. The IDENTITY of the custodian of such DOCUMENTS.
RESPONS) - 23

No.
INTERROGATORY NO. 24+

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

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

Be Whether participation in any such program was a mandatory

condition of employment ox was voluntary;

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c. Whether THIS DEFENDANT has DOCUMENTS of such program(s) ;
PD. The, IDENTITY of the custodian of such DOCUMENTS.

RESPONSE TO INTERROGATORY NO. 24:
No.

Prior to 1973, did any person file a Workers’ Compensation
claim fox asbestos-related injury against THIS DEFENDANT or against
any Workers! Compensation insurafee 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. fhe case number;

D. The court in which the claim was filed;

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

RESPONSE TO INTERROGATORY NO. 25;

No.

INTERROGATORY NO. 26:

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

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

B. The number and effective date of each policy;

Cc. The amount(s) ‘of coverage of each policy;

D. The applicable dates of coverage.

tif

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RESPONSE TO INTERROGATORY NO. 261

Yes. 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, wmanufactured, 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 corporation or business
entity;

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

c. The nature of the business as it pertains to asbestos.
RESPONSE TO ITNTEBRROGATORY NO. 27:

No.
INTBRROGSTORY 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;

G. Supply;

D. ‘Importing;

gE. Processing;

F. Distribution;

a. Marketing;

-21+H. Sale;

I. Brokering.
RESPONSE TQ INTERROGATORY NO, 28:
No.

ANTERROGATORY NO. 29:

If YOUR answer to any of subparts of Interrogatory No. 28
regarding RAW ASBESTOS is in the affirmative, state:

A. The trade, brand name, and/or generic nama of such RAW
ASBESTOS 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;

a. On an experimental basis;
2. On a test basis; :
3. For sale.
¢, The date(s) such RAW ASBESTOS;
a. Ceased to be produced; or
2. Was recalled from the market, if ever,

BP. A QGeseription of the chemical composition of such RAW

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

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

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

SG. Whether such RAW ASBESTOS was on the U.S. Government's
"Qualified Products List," and if se, 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 sold, shipped, or otherwise distributed, used or
installed te ox at any COMPANY (including power company or
utility), governmental agency or entity, shipyard, distributor,
veEinery, contractor, supplier, PREMISE 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 facllity, 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, etc.);

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. Either (1) attach all DOCUMENTS evidencing the
information sought in this Interrogatory and its subparts to your
anewers to these Interrogatories, or (2) attach disks containing
such data, or (3) gescribe auch DOCUMENTS with sufficient
paxticularaty that they may be made the subject of a request for

production of documents.

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Not applicable.
INTERROGATORY 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:

aA. Bupply;

B. Importing;

a. Distribution;

D. Marketing;

EB. Sale;

RP. Labeling;

Ga. Manufacturing;

He Brokering.

RESPONSE TO INTERROGATORY NO. 30: :

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

B, No.

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

BD. Some products marketed by Hamilton contained a small
percentage of chrysotile fiber Erom no earlier than 21959 until no
later than 1977.

Ee Some products sold by Hamilton contained a small
percentage of chrysotile fiber from no earlier than 1959 until no

later than 1977.

-24-F. Some products labeled by Hamilton contained a small
percentage of chrysotile fiber from no earlier than 1959 until no
later than 1977.

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

He No.

ANEBRROGATORY NO. 34:

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

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

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

Cc. The date(s) each such ASBESTOS-CONTAINING PRODUCT:
1. Ceased to be produced; or
2. Was recalled from the market, if ever,

DR. A description of the chemical composition of each auch
ASBESTOS-CONTAINING PRODUCT, including the type and/or grade of
asbestos and/or asbestos fiber contained in each such product and
the quantitative percentage of asbestos or asbestos fiber in each

such product, and all non-asbestos components of the ASBESTOS-

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CONTAINING PRODUCT, and if the chemical composition changes over
time, the inclusive dates of each formulation;

E. A description of the physical appearance and nature of
each such ASBESTOS-CONTAINING PRODUCT, including any color coding,
distinctive maxking and/or logo, either on the product or on the
packaging; :

BF. A detailed description of the intended use of each such
ASBESTOS-CONTAINING PRODUCT, 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
used in each such product and the time period of such supply;

I. Whether any of THIS DEPENDANT’ s RAW ASBESTOS or ASBESTOS ~
CONTAINING PRODUCTS have, at any time, been sold, shipped, or
otherwise distributed to any COMPANY (including power company or
utility), governmental agency or entity, shipyard, distributor,
refinery, contracter, supplier, . manufacturer, PREMISE owner or
occupant, ship owner, or other PREMISE or site in the GEOGRAPHIC
AREA. If so, 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 ASBESTOS-CONTAINING PRODUCE sold;

3. Whether YOU have any records indicating any such

-26~gale, shipment, distribution, use or installation and, if so, the
name, address and job classification of each person who currently
has possession of such records;

a. Bither (1) attach ali DOCUMENTS evidencing the
information sought in thie Interrogatory and its subparts to your
anavers 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 TO INTERROGATORY NO. 341
Z. DRYWALL JOINT FINISHING COMPOUNDS

Hamilton Materials has’ manufactured products for finishing
drywall joints since approximately 1963. Some of the products
contained a small percentage of chrysotile asbestos fiber, as
discussed in greater detail below, at certain times between 1963
and 1977. The great majority of Hamilton’ s drywall joint finishing
compounds solid between 1363 and 1977, however, did not contain any
asbestos, including the preduct that constituted most of Hamilton’s
sales of products for this purpose between 1963 and 1977,
Hamilton's "Topping Compound" or "Finishing Compound," which has
never contained asbestos at any time. ‘The Hamilton products that
contained any asbestos at any time are discussed below:

A-C. Taping Joint System contained from 0 to 3% chrysotile
from approximately 1970 to 1977. All Burpose Joint System
contained from 6 to 3% chrysotile from approximately 1963 to 1977.
Multi-Purpese (also known as Formula V or Purekote}, contained from
QO to 4% chrysotile in 1974 only. Orange Dot Multi-Purpose {also

known as Formula II) contained from 0 to 3% chrysotile from 1974 to

+Q7-1977, Sof-Top Joint System contained from 0 to 1% chrysotile from
1975 to 1977. Sunburst Joint Compound, which was sold in the state
of Arizona only, contained from 0 to 1% chrysotile in parts of 1975
and 1976.

D. Hamilton drywall joint finishing compounds waxe mica~
based products containing between 0 and 3% chrysotile asbestos
during certain years of manufacture, as discussed above,

E. All of the Hamilton drywall joint £inishing compounds
discussed above came in semi-liquid pre-mixed form and were
packaged either in buckets or cardboard boxes with plastic liners.

#. All of the Hamilton drywall joint finishing compounds
were to be used for the purpose of filling joints and imbedding
tape between pieces of Grywall, and were designed to be used in
conjunction with Hamilten Topping Compound whieh wag to be used for
the final coats and which was the material to be sanded if any

sanding were to be done on a particular job.

G. No.
H. Hamilton believes most of the chrysotile was purchased
from Union Carbide Company. Hamilton algo may have at times

purchased some chrysotile from Carey Canada, Atlas, Jacques and
Johne-Manville.

I. Please refer to the depositions of Hamilton President
Willis Hamilton and Vice-President Eugene Hatz taken under the
caption "In xe Complex Asbestos Litigation" referenced in the
response to Interrogatory Number 12 and the documents produced in
connection with and made exhibits to those depositions.

a. All responsive documents were produced in connection with

ang made exhibits to the depositions of Hamilton President. Willis

-28-’ Hamilton and Vice-President Eugene Hatz taken under the caption "In

xe Complex Asbestos Litigation” referenced in the response to
Interrogatory Number 12.
Il. WALL TEXTURE PRODUCTS

Hamilton has manufactured wall texture products, seme of which
contained a small percentage ef chrysotile asbestos fiber as
discussed in greater detail below, since 1959. No Hamilton wall
texture product contained any asbestos after July 1976, and no
Hamilton wall texture product contained more than 0.5% chrysotile
from July 1975 through July 1976. In addition, many contractors
have used Hamilton Topping Compound, which has never contained
asbestos, for the purpose of texturing walis since 1963.

A-C. Standard Wall Texture contained from 0 to 3.3% chrysotile
from approximately 1959 to 1975. Hi-Stipple contained from 0 to
3.3% chrysotile from approximately the mid-1960's to 1973. Hi-
Miler contained from 0 to 3% chrysotile from 1967 to mid 1972.
Regular EZ Spray contained from 0 to 3.3% chrysotile from the early
1970's to 1975. California Whiteline contained 09 to 0.5%
chrysotile from the early 1970's to July 1976.

D. Hamilton wall textures were calcium carbonate-based
products that contained a small percentage of chrysotile fibers
during certain years as discussed above.

E. Hamilton wall textures came in powder form and were
packaged in bags.

F. Hamilton wall textures were designed to be sprayed onto
walla as decorative textures and were not designed to have acoustic
properties.

Gg. Not applicable.

"29~os AF RF Fe WD HE

H. Hamilton believes most of the chrysotile was purchased
from Union Carbide Company. Hamilton algo may at times have
purchased some chryectile from Carey Canada, Atlas, Jacques and
Johns-Manville.

rz. Please refer to the depositions of Hamilton President
Willie Hamilton and Vice-President Eugene Hatz taken under the
caption "In re Complex Asbestos Litigation" referenced in the
response to Interxrogatory Number 12 and the documents preduced in
connection with and made exhibits to those depositions.

a. All responsive documents were produced in connection with
and made exhibits to the depositions of Hamilton President Willis
Hamilton and Vice-President Eugene Hatz taken under the caption "In
xe Complex Asbestos Litigation" referenced in the response to
Interrogatory Number 12.

III. CBILING TEXTURE PRODUCTS

Hamilton has manufactured ceiling texture products, some of
which contained a small percentage of chrysotile asbestos fiber as
discussed in greater detail below, since 1959. No Hamilton ceiling
texture product contained any asbestos after July 1976, and no
Hamilton ceiling texture product contained more than 0.5%
chrysotile from duly 1975 through duly 1976.

A-C, Plas-Tex California Premium contained from 0 ta 0.5%
chrysotile fiber from approximately 1975 to July 1976. Plas-Tex
Premium contained from 0 to 4% chrysotile from approximately the
early 1960's to July 1975 and from 0 to 0.5% from July 1975 to July
1976, Plas-Tex Regular contained from 0 to 4% chrysotile fiber
from approximately the late 1960's until July 1976. Plas-Tex 2121P

contained From 0 to 3.5% chrysotile from the early 1960's to July

-30-1975 and from 0 to 0.5% from July 1975 to July 1976. .

dD. Hamilten ceiling textures were calcium carbonate-baged
products that contained a small percentage of chrysotile fibers
during certain years as discussed above.

E. Hamilton ceiling textures came in powder form and were
packaged in bags.

¥. Hamilton ceiling textures were designed to be sprayed
onto ceilings ag decorative textures and were not deaigned to have
acoustic properties.

G. Not applicable,

Ez. Hamilton believes most of the chrysotile was purchased
from Union Carbide Company. Hamilton also may at times have
purchased some chrysotile from Carey Canada, Atlas, Jacques and
Johns-Manville.

I. Please refer to the depositions of Hamilton President
Willis Hamilton and Vice-President Eugene Hatz taken under the
caption "In re Complex Asbestos Litigation" referenced in the
response to Interrogatory Number 12 and the documents produced in
comnection with and made exhibits to those depositions.

a. All responsive documents were produced in connection with
and made exhibits to the depositions of Hamilton President Willis
Hamilton and Vice-President Bugene Hats taken under the caption "In
re Complex Asbestos Litigation" referenced in the response to
interrogatory Number 12.

IV, OTHER PRODUCTS

Hamilton also sold the following products manufactured by

other entities: Radiant Heat-Fil, a powder packaged in bags

intended to be used as a conductive material for imbedding ceiling

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cable; Quick Fix, a powder packaged in bags intended to be used
primarily as a drywall patching material; and Fas-Set, a powder
packaged in bags intended to be used as a patching compound,
Hamilton has no personal knowledge xegarding the chemical
composition of these products and whether or not they contained any
form of asbestos at any time, nor is Hamilton currently aware of
any sources of information relevant to these products not discussed
during the depositions of Hamilten President Willis Hamilton and
Vice President Bugene Hatz and therefore equally available to all
parties.
INTERROGATORY NO, 32: (PREMISES DEFENDANTS only)

pid YOU install, remove, or handle or contract to have others
install, remove, or handle RAW ASBESTOS or ASBESTOS-CONTAINING
PRODUCTS at any PREMISES in the GEOGRAPHIC 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?
If so:

aA. IDENTIFY the PREMISES;

B, For each of the PREMISES:

1. State the nature of your ownership or possessory
interest;

2. State the inclusive date of that interest;

3. IDENTIFY the party from whom that interest wag
acquired;

4, IDENTIFY the party, if any, to whom that interest
was transferred.
c IDENTIFY every contract to which YOU were a party or of

which YOU have knowledge wherein the pexfoxmance of such contract

~32-a

invelved the installation, removal, disturbing or handling of any
RAW ASBESTOS ox ASBESTOS-CONTAINING PRODUCTS at YOUR PREMISES. For
each guch contracts

a. IDENTIFY the parties to the contract; ©

2. Provide a general description and specific location
of the work to be performed by each party to the contract;

3. IDENTIFY and describe the NATURE of the RAW ASBESTOS
ox ASBESTOS-CONTAINING PRODUCTS installed, removed, disturbed or

handled in the performance of the contract;

4. State the dates of the contract and the dates of
performance;
D. Except as provided in response to subpart ¢., has any

work other than routine maintenance been dene on or to the PREMISES
that involved the installation, removal, disturbing or handling of
RAW ASBESTOS or ASBESTOS-CONTAINING PRODUCTS? If so, for each such
instance:

1. State the inclusive dates. of the work;

a- provide a general description and specific location
of the work;

3. State whether the work was done by YOU and/or YOUR
employees;

4. IDENTIFY and describe the NATURE of the RAW ASBESTOS
or ASBESTOS-CONTAINING PRODUCTS installed, removed, handled or
disturbed;

3. IDENTIFY from whom the RAW ASBESTOS or ASBESTOS~
CONTAINING PRODUCTS were acquired.

E Bas any asbestos abatement effort been made at the

PREMISES? If so, for each such effort:

~33~-o 1 A Nm es ww MN

1.  ‘DENTIEY who did the work;

2. State the inclusive dates thereof;

3. State whether gamples were taken, and, if the
samples still exist, IDENTIFY the custodian of the samples;

a. State whether any material was tested, and, if so,
what were the results of each test;

5, IDENTIFY each test result with sufficient
particularity for purposes of a request for production of
documents, ox, in the alternative, attach a copy to YOUR answers to
these interrogatories. :

e. Except for insurance coverage litigation, have YOU filed
suit against, ox 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 PRODUCTS on the PREMISES identified in response
to subpart (A) above? T£ go;

de IDENTIFY the person or entity against whom YOU have
filed suit or otherwise sought to recover;

2, T£ YOU have filed suit, state the court in which the
action was filed, the date on which it was filed, IDENTIFY all
Plaintiffs and Defendants and theix counsel of record;

3. State whether or not the case has been resolved,
and, if so, what was the status or disposition.

g. Bither (2) 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, ox (3) describe such DOCUMBNTS with sufficient
particularity that they may be made the subject of a request for

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production of documents.

Re IDENTIFY the person(s) presently most knowledgeable about
the information sought in this interrogatory or its subparts,
RESPONSE TO INTERROGATORY NO. 32;

Not applicabie.

INTERROGATORY NO. 33s (CONTRACTOR DEFENDANTS only)

At any time between 1930 and 1985, did YOU hold a contractor’s
license in the State of California? I£ so:

A. I