Preview
FILED: NEW YORK COUNTY CLERK 07/10/2023 10:29 PM INDEX NO. 190002/2023
NYSCEF DOC. NO. 149 RECEIVED NYSCEF: 07/10/2023
EXHIBIT 64
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FOLEY & MANSFIELD, PLLP
Madelyn Iulo, Esq. (N.J. Bar No. 025051998)
Erika Muse, Esq. (N.J. Bar No. 283572018)
86 Chambers Street, Suite 202
New York, New York 10007
Tel: (212) 421-0436
Attorneys for Defendant LORNAMEAD, INC.
------------------------------------------------------------ X
KELLEY MALONEY-NAJJAR and TALIB
NAJJAR, SUPERIOR COURT OF NEW JERSEY
LAW DIVISION: MIDDLESEX COUNTY
Plaintiff,
Docket No. MID L-3900-22-AS
-v-
CIVIL ACTION ASBESTOS LITIGATION
ARKEMA, INC., et al., DEFENDANT LORNAMEAD, INC.’S
OBJECTIONS AND RESPONSES TO
Defendants. FORM B AND C INTERROGATORIES
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Defendant LORNAMEAD, INC (hereinafter “Lornamead” or “Defendant”), subject to and
without waiving any defenses set forth, provides the following objections and responses to Form
B and C Interrogatories:
PRELIMINARY STATEMENT
The following Preliminary Statement is incorporated by reference into each specific
Response set forth below. Lornamead is a Delaware corporation with its principal place of business
in New York. Lornamead purchased certain Yardley trademarks from a set of companies affiliated
with Procter & Gamble (“P&G”) on September 30, 2005. Lornamead did not assume any liabilities
related to the Yardley brand or P&G for any products sold or distributed prior to the Yardley
acquisition in 2005. Lornamead is not now, and has never been, affiliated in any manner with P&G
or its affiliates. Lornamead has never manufactured Yardley talc products. Any Yardley talc
product sold to a customer in the United States after 2012 was distributed by an unrelated third
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party named Wipro Cyprus Ltd., through its subsidiary, Yardley of London Ltd., in accordance
with the Yardley license agreement, and their North American distributor.
Lornamead and its attorneys have not completed their discovery or preparation for trial, nor
have they concluded their analysis of information gathered to date. These responses, therefore, are
based upon information presently available to Lornamead and its attorneys and specifically known
to individuals preparing these interrogatory responses. Therefore, the interrogatory responses
herein are made without prejudice to the right of Lornamead to supplement, amend, revise, correct
or otherwise clarify any objection or response or to provide evidence at the time of trial.
GENERAL OBJECTIONS / RESERVATION OF RIGHTS
1. Lornamead objects to each Interrogatory on the grounds that Lornamead did not
assume any liabilities related to the Yardley brand or P&G for any products sold or distributed prior
to the Yardley acquisition in 2005.
2. Lornamead objects to each Interrogatory on the grounds that Lornamead has never
been in the business of designing, developing, manufacturing, selling, distributing, brokering, or
installing asbestos-containing products or materials or raw asbestos fibers of any type. Lornamead
understands the terms “asbestos-containing products” and “asbestos products” as meaning “any
supplies, products, materials or equipment containing or including asbestos in whole or in mixture
with other products.” No Lornamead product falls within the definition of “asbestos-containing”
products or “asbestos products.”
3. Lornamead has never intentionally included any form of asbestos as a part of the
composition or as an ingredient in its cosmetics products, and therefore the interrogatories are
inapplicable and not reasonably calculated to lead to the discovery of admissible evidence to the
extent they are falsely predicated on the assumption that Lornamead incorporated asbestos as an
ingredient in any of its products.
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4. Lornamead objects to each Interrogatory to the extent that they impose greater
obligations than those permitted or required under the New Jersey Rules of Civil Procedure and
New Jersey Asbestos General Order.
5. Lornamead objects to these interrogatories to the extent that they seek information
from or regarding third parties. Lornamead objects to any demand for information that would
require Lornamead to conduct investigations into the operations of other companies unrelated to
Lornamead’s business operations. Such information is neither admissible nor in any way calculated
to lead to the discovery of admissible evidence.
6. Lornamead objects to each Interrogatory to the extent that they seek information
protected by the attorney-client privilege and/or the attorney work product doctrine, or by any other
applicable privilege.
7. Lornamead objects to all interrogatories, which may be interpreted to include any
time period other than the time period at issue in this matter. Any inquiry about other time periods
is irrelevant, overbroad, unduly burdensome, and not reasonably calculated to lead to the discovery
of admissible evidence.
8. Lornamead objects to each Interrogatory to the extent that they seek information
that is not within Lornamead’s custody or control or is equally available to Plaintiffs.
9. Lornamead objects to the instructions and definitions contained in these
Interrogatories to the extent that they are vague, ambiguous, overbroad, and unduly burdensome.
Lornamead’s Responses herein are based upon the ordinary meanings of the words used and
Lornamead’s understanding of any technical terms.
10. Lornamead objects to each Interrogatory to the extent that they seek information not
reasonably calculated to lead to the discovery of relevant admissible evidence, are not reasonably
limited in duration, are vague, over broad, irrelevant and unduly burdensome, and is otherwise not
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within the realm of permissible discovery under the New Jersey Rules of Civil Procedure and the
standing orders of this Court. Each of these objections are incorporated by reference and adopted
in response to each and every discovery response contained herein.
11. Lornamead also objects to the extent the Interrogatory as premature as Lornamead
and its attorneys have not completed discovery or preparation for trial, and per the Case
Management Order governing this action, fact discovery in this case remains open. Lornamead will
supplement this response within the time limits imposed by the Case Management Order and the
New Jersey Rules of Civil Procedure.
12. Lornamead reserves the right to supplement, amend, revise, correct or otherwise
clarify the Objections and Responses set forth herein, as discovery and investigation is ongoing.
Subject to the above Preliminary Statement, Defendant Lornamead, pursuant to the New
Jersey Rules of Civil Procedure and New Jersey Asbestos General Order, hereby submits its
Objections and Responses to Form B and C Interrogatories.
FORM B AND C INTERROGATORIES
B.1. State the name, address and job position of each and every individual signing these
interrogatories on behalf of the defendant.
a. State the name, address and employer and job position of each
person, whether defendant’s employees or otherwise who was consulted
with or who assisted in the answering of these interrogatories.
RESPONSE:
Lornamead objects to this Interrogatory and incorporates by reference its Preliminary
Statement and General Objections above. Lornamead also objects to the extent this Interrogatory
is unduly burdensome, overbroad, and seeking information not reasonably calculated to lead to the
discovery of admissible evidence. Lornamead objects on the ground and to the extent that it seeks
information outside Lornamead’s possession or information already in Plaintiffs’ possession, and
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to the extent it is duplicative of other discovery requests. Lornamead also objects to this
Interrogatory to the extent that it seeks information irrelevant to Plaintiffs’ claims in time, scope,
and geography.
Subject to and without waiving these objections, Lornamead states that these responses
were assembled by authorized employees and counsel for Lornamead in part from ongoing review
of Lornamead’s records and discussions with Lornamead employees. Accordingly, the person
verifying these interrogatory responses may not have personal knowledge regarding any specific
answer and may be unaware of the identities of all persons who may have knowledge regarding
any specific answer and may be responsive to these interrogatories. Lornamead further states that
these responses represent the response of Lornamead and are verified by Mr. Scott Pestyner, Senior
Vice President, Finance, of Lornamead, Inc.
B.2. Give a full and detailed description of the nature of the business that your company is
engaged in.
RESPONSE:
Lornamead objects to this Interrogatory and incorporates by reference its Preliminary
Statement and General Objections above. Lornamead also objects to the extent this Interrogatory
is unduly burdensome, overbroad, and seeking information not reasonably calculated to lead to the
discovery of admissible evidence. Lornamead objects on the ground and to the extent that it seeks
information outside Lornamead’s possession or information already in Plaintiffs’ possession, and
to the extent it is duplicative of other discovery requests. Lornamead also objects to this
Interrogatory to the extent that it seeks information irrelevant to Plaintiffs’ claims in time, scope,
and geography. Lornamead objects to this interrogatory as vague and ambiguous as the terms
“full and detailed description” and “nature of the business” are undefined. Lornamead further
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objects to this interrogatory to the extent it seeks publicly available information that is equally
accessible by Plaintiff.
Subject to and without waiving these objections, Lornamead states that it is a personal care
company engaged in the sale of skin and oral care, and bath products. Lornamead has never been
in the business of designing, developing, manufacturing, selling, distributing, brokering, or
installing asbestos-containing products or raw asbestos fibers of any type.
B.3. When did your company commence its business?
RESPONSE:
Lornamead objects to this Interrogatory and incorporates by reference its Preliminary
Statement and General Objections above. Lornamead also objects to the extent this Interrogatory
is unduly burdensome, overbroad, and seeking information not reasonably calculated to lead to the
discovery of admissible evidence. Lornamead objects on the ground and to the extent that it seeks
information outside Lornamead’s possession or information already in Plaintiffs’ possession, and
to the extent it is duplicative of other discovery requests. Lornamead also objects to this
Interrogatory to the extent that it seeks information irrelevant to Plaintiffs’ claims in time, scope,
and geography. Lornamead objects to this interrogatory to the extent it seeks publicly available
information that is equally accessible by Plaintiff.
Subject to and without waiving these objections, Lornamead states that it was incorporated
under the laws of Delaware in 2002.
B.4. a. Are or have any of defendant’s predecessors, affiliates, subsidiaries, or parent
corporations engaged in the mining, sale and distribution of asbestos and/or
asbestos fiber and/or asbestos containing insulation products? If so, state the
name of each such entity, describe the nature of the involvement that each entity
has or has had in the mining, distribution or sale of these products and materials,
and set forth the inclusive dates each was involved in each aspect of this business.
b. As to each such entity referred to in (a) above, state:
1. The relationship between defendant and each such entity;
2. The date each such relationship began and terminated;
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3. The names and addresses of each such entity’s corporate officers and
Board of Directors; and
4. The names and addresses of your corporate officers and Board of
Directors.
RESPONSE:
Lornamead objects to this Interrogatory and incorporates by reference its Preliminary
Statement and General Objections above. Lornamead also objects to the extent this Interrogatory
is unduly burdensome, overbroad, and seeking information not reasonably calculated to lead to the
discovery of admissible evidence. Lornamead objects on the ground and to the extent that it seeks
information outside Lornamead’s possession or information already in Plaintiffs’ possession, and
to the extent it is duplicative of other discovery requests. Lornamead also objects to this
Interrogatory to the extent that it seeks information irrelevant to Plaintiffs’ claims in time, scope,
and geography. Lornamead objects to this interrogatory to the extent it seeks publicly available
information that is equally accessible by Plaintiff. Lornamead also objects to this interrogatory as
inapplicable, irrelevant, and not reasonably calculated to lead to the discovery of admissible
evidence as it has never used asbestos, asbestos products or asbestos fiber. Nor has any predecessor,
affiliate, subsidiary, or parent corporation engaged in such business.
Subject to and without waiving these objections, Lornamead states that it is not aware of
any predecessors, affiliates, subsidiaries, or parent corporations that engaged in the mining, sale
and distribution of asbestos and/or asbestos fiber and/or asbestos containing insulation products.
B.5. From the year 1925 until the present, identify and state the address of any organization in
which defendant, its officers, agents or employees have belonged, having anything to do
with setting standards, regulations or the conducting of research into the use of asbestos,
asbestos products or asbestos fiber.
RESPONSE:
Lornamead objects to this Interrogatory and incorporates by reference its Preliminary
Statement and General Objections above. Lornamead also objects to the extent this Interrogatory
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is unduly burdensome, overbroad, and seeking information not reasonably calculated to lead to the
discovery of admissible evidence. Lornamead objects on the ground and to the extent that it seeks
information outside Lornamead’s possession or information already in Plaintiffs’ possession, and
to the extent it is duplicative of other discovery requests. Lornamead also objects to this
Interrogatory to the extent that it seeks information irrelevant to Plaintiffs’ claims in time, scope,
and geography. Lornamead objects to this interrogatory to the extent it seeks publicly available
information that is equally accessible by Plaintiff. Lornamead also objects to this interrogatory as
inapplicable, irrelevant, and not reasonably calculated to lead to the discovery of admissible
evidence as it has never used asbestos, asbestos products or asbestos fiber.
Subject to and without waiving these objections, Lornamead states: Not Applicable.
Lornamead has never been in the business of designing, developing, manufacturing, selling,
distributing, brokering, or installing asbestos-containing products or raw asbestos fibers of any
type.
B.6. Has defendant ever been a member of or affiliated with any trade groups,
professional associates or organization? If so, identify each such group, association or
organization and set forth the inclusive dates of defendant’s membership in each.
RESPONSE:
Lornamead objects to this Interrogatory and incorporates by reference its Preliminary
Statement and General Objections above. Lornamead also objects to the extent this Interrogatory
is unduly burdensome, overbroad, and seeking information not reasonably calculated to lead to the
discovery of admissible evidence. Lornamead objects on the ground and to the extent that it seeks
information outside Lornamead’s possession or information already in Plaintiffs’ possession, and
to the extent it is duplicative of other discovery requests. Lornamead also objects to this
Interrogatory to the extent that it seeks information irrelevant to Plaintiffs’ claims in time, scope,
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and geography. Lornamead objects to this interrogatory to the extent it seeks publicly available
information that is equally accessible by Plaintiff. Lornamead also objects to this interrogatory as
irrelevant, overbroad and unduly burdensome, and not reasonably calculated to lead to the
discovery of admissible evidence to the extent that it is not limited to trade groups, professional
associates or organizations involved in addressing issues relevant to this litigation. Lornamead
further objects to this interrogatory as vague and ambiguous to the extent the term “professional
associates” is undefined.
Subject to and without waiving these objections, Lornamead states: Not Applicable.
Lornamead has never been in the business of designing, developing, manufacturing, selling,
distributing, brokering, or installing asbestos-containing products or raw asbestos fibers of any
type.
B.7. Has defendant ever been a member of or affiliated with the Asbestos Textile Institute?
If so, indicate when your company was affiliated or was a member of this organization.
RESPONSE:
Lornamead objects to this Interrogatory and incorporates by reference its Preliminary
Statement and General Objections above. Lornamead also objects to the extent this Interrogatory
is unduly burdensome, overbroad, and seeking information not reasonably calculated to lead to the
discovery of admissible evidence. Lornamead objects on the ground and to the extent that it seeks
information outside Lornamead’s possession or information already in Plaintiffs’ possession, and
to the extent it is duplicative of other discovery requests. Lornamead also objects to this
Interrogatory to the extent that it seeks information irrelevant to Plaintiffs’ claims in time, scope,
and geography. Lornamead objects to this interrogatory to the extent it seeks publicly available
information that is equally accessible by Plaintiff. Lornamead also objects to this interrogatory as
irrelevant, overbroad and unduly burdensome, and not reasonably calculated to lead to the
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discovery of admissible evidence to the extent that it is not limited to trade groups, professional
associates or organizations involved in addressing issues relevant to this litigation.
Subject to and without waiving these objections, Lornamead states: Not Applicable.
Lornamead has never been in the business of designing, developing, manufacturing, selling,
distributing, brokering, or installing asbestos-containing products or raw asbestos fibers of any
type.
B.8. Does your company publish or distribute a manual or booklet which describes the nature
of the business that defendant is engaged in? If so, set forth the title of such manual or
booklet, indicate when it was published and attach a copy of same hereto.
RESPONSE:
Lornamead objects to this Interrogatory and incorporates by reference its Preliminary
Statement and General Objections above. Lornamead also objects to the extent this Interrogatory
is unduly burdensome, overbroad, and seeking information not reasonably calculated to lead to the
discovery of admissible evidence. Lornamead objects on the ground and to the extent that it seeks
information outside Lornamead’s possession or information already in Plaintiffs’ possession, and
to the extent it is duplicative of other discovery requests. Lornamead also objects to this
Interrogatory to the extent that it seeks information irrelevant to Plaintiffs’ claims in time, scope,
and geography. Lornamead objects to this interrogatory to the extent it seeks publicly available
information that is equally accessible by Plaintiff.
B.9. Has any employee or representative of your corporation ever attended a conference or
meeting of the Asbestos Textile Institute? If so, identify each such individual who
attended these conferences or meetings and set forth the dates on which each such
individual went to such a conference or meeting.
RESPONSE:
Lornamead objects to this Interrogatory and incorporates by reference its Preliminary
Statement and General Objections above. Lornamead also objects to the extent this Interrogatory
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is unduly burdensome, overbroad, and seeking information not reasonably calculated to lead to the
discovery of admissible evidence. Lornamead objects on the ground and to the extent that it seeks
information outside Lornamead’s possession or information already in Plaintiffs’ possession, and
to the extent it is duplicative of other discovery requests. Lornamead also objects to this
Interrogatory to the extent that it seeks information irrelevant to Plaintiffs’ claims in time, scope,
and geography. Lornamead objects to this interrogatory to the extent it seeks publicly available
information that is equally accessible by Plaintiff. Lornamead also objects to this interrogatory as
irrelevant, overbroad and unduly burdensome, and not reasonably calculated to lead to the
discovery of admissible evidence to the extent that it is not limited to trade groups, professional
associates or organizations involved in addressing issues relevant to this litigation.
B.10. Has your company ever been a member of, been affiliated with or provided funding for
the Industrial Hygiene Foundation? If so, indicate when your company was a member
or affiliate of this organization and set forth the dates, if applicable, when you provided
funding to this organization.
RESPONSE:
Lornamead objects to this Interrogatory and incorporates by reference its Preliminary
Statement and General Objections above. Lornamead also objects to the extent this Interrogatory
is unduly burdensome, overbroad, and seeking information not reasonably calculated to lead to the
discovery of admissible evidence. Lornamead objects on the ground and to the extent that it seeks
information outside Lornamead’s possession or information already in Plaintiffs’ possession, and
to the extent it is duplicative of other discovery requests. Lornamead also objects to this
Interrogatory to the extent that it seeks information irrelevant to Plaintiffs’ claims in time, scope,
and geography. Lornamead objects to this interrogatory to the extent it seeks publicly available
information that is equally accessible by Plaintiff. Lornamead also objects to this interrogatory as
irrelevant, overbroad and unduly burdensome, and not reasonably calculated to lead to the
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discovery of admissible evidence to the extent that it is not limited to trade groups, professional
associates or organizations involved in addressing issues relevant to this litigation.
Subject to and without waiving these objections, Lornamead states: Not Applicable.
Lornamead has never been in the business of designing, developing, manufacturing, selling,
distributing, brokering, or installing asbestos-containing products or raw asbestos fibers of any
type.
B.11. Does your company have a Board of Directors?
RESPONSE:
Lornamead objects to this Interrogatory and incorporates by reference its Preliminary
Statement and General Objections above. Lornamead also objects to the extent this Interrogatory
is unduly burdensome, overbroad, and seeking information not reasonably calculated to lead to the
discovery of admissible evidence. Lornamead also objects to this Interrogatory to the extent that it
seeks information irrelevant to Plaintiffs’ claims in time, scope, and geography. Lornamead objects
to this interrogatory to the extent it seeks publicly available information that is equally accessible
by Plaintiff. Lornamead also objects to this interrogatory as irrelevant, overbroad and unduly
burdensome, and not reasonably calculated to lead to the discovery of admissible evidence to the
extent that it is not addressing issues relevant to this litigation.
Subject to and without waiving these objections, Lornamead states: Not Applicable.
Lornamead has never been in the business of designing, developing, manufacturing, selling,
distributing, brokering, or installing asbestos-containing products or raw asbestos fibers of any
type.
B.12. Does your company’s Board of Directors conduct meetings?
RESPONSE:
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Lornamead objects to this Interrogatory and incorporates by reference its Preliminary
Statement and General Objections above. Lornamead also objects to the extent this Interrogatory
is unduly burdensome, overbroad, and seeking information not reasonably calculated to lead to the
discovery of admissible evidence. Lornamead also objects to this Interrogatory to the extent that it
seeks information irrelevant to Plaintiffs’ claims in time, scope, and geography. Lornamead objects
to this interrogatory to the extent it seeks publicly available information that is equally accessible
by Plaintiff. Lornamead also objects to this interrogatory as irrelevant, overbroad and unduly
burdensome, and not reasonably calculated to lead to the discovery of admissible evidence to the
extent that it is not addressing issues relevant to this litigation.
Subject to and without waiving these objections, Lornamead states: Not Applicable.
Lornamead has never been in the business of designing, developing, manufacturing, selling,
distributing, brokering, or installing asbestos-containing products or raw asbestos fibers of any
type.
B.13. Have minutes of the Board of Directors meetings been taken and maintained by your
company? If so, indicate who has custody of the minutes at this time.
RESPONSE:
Lornamead refers Plaintiff to its objections and response to Interrogatory B.11, which is
hereby incorporated by reference.
B.14. Has your company, and/or its subsidiaries or affiliates ever manufactured or distributed
asbestos containing products?
RESPONSE:
Lornamead objects to this Interrogatory and incorporates by reference its Preliminary
Statement and General Objections above. Lornamead also objects to the extent this Interrogatory
is unduly burdensome, overbroad, and seeking information not reasonably calculated to lead to the
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discovery of admissible evidence. Lornamead objects on the ground and to the extent that it seeks
information outside Lornamead’s possession or information already in Plaintiffs’ possession, and
to the extent it is duplicative of other discovery requests. Lornamead also objects to this
Interrogatory to the extent that it seeks information irrelevant to Plaintiffs’ claims in time, scope,
and geography.
Subject to and without waiving these objections, Lornamead states: Not Applicable.
Lornamead has never manufactured, sold, distributed, applied and/or installed asbestos or asbestos-
containing products.
B.15. Give a complete and detailed description of the particular qualities that asbestos has or had
that caused your company and/or its subsidiary or affiliate to utilize asbestos in your
products.
RESPONSE:
Lornamead refers Plaintiff to its objections and response to Plaintiff’s Standard
Interrogatory No. B.14, which is hereby incorporated by reference.
B.16. Did any of the entities from whom you received asbestos fiber or any of the entities
referred to in B6, B7, B9 and B10 ever inform you or your company’s employees
that asbestos was potentially hazardous to the health of individuals who were
exposed to it?
RESPONSE:
Lornamead objects to this Interrogatory and incorporates by reference its Preliminary
Statement and General Objections above. Lornamead also objects to the extent this Interrogatory
is unduly burdensome, overbroad, and seeking information not reasonably calculated to lead to the
discovery of admissible evidence. Lornamead objects on the ground and to the extent that it seeks
information outside Lornamead’s possession or information already in Plaintiffs’ possession, and
to the extent it is duplicative of other discovery requests. Lornamead also objects to this
Interrogatory to the extent that it seeks information irrelevant to Plaintiffs’ claims in time, scope,
and geography. Lornamead objects to this interrogatory as inapplicable, irrelevant, and not
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reasonably calculated to lead to the discovery of admissible evidence as it has never received
asbestos fiber from any entity identified or referred to in Interrogatories B.6, B.7, B.9, or B.10.
B.17. If so, for each such company that transmitted such information to you and your company,
set forth the following information.
a. The name of each and every entity that informed your company that
asbestos was potentially hazardous to health;
b. The dates you received this information from each such company;
c. Indicate how this information was transmitted to you;
d. The substance of each warning; and
e. Annex hereto copies of each such warning.
RESPONSE:
Lornamead refers Plaintiff to its objections and response to Standard Interrogatory No.
B.16, which is hereby incorporated by reference.
B.18. Has defendant distributed or sold asbestos or asbestos containing products in the State
of New Jersey? If so, set forth the following information:
a. The date that defendant commenced selling asbestos or asbestos
containing products in the State of New Jersey;
b. The date the defendant terminated the sale of asbestos or asbestos
containing products in the State of New Jersey; and
c. The areas of New Jersey where asbestos or asbestos containing products
were sold.
RESPONSE:
Lornamead objects to this Interrogatory and incorporates by reference its Preliminary
Statement and General Objections above. Lornamead also objects to the extent this Interrogatory
is unduly burdensome, overbroad, and seeking information not reasonably calculated to lead to the
discovery of admissible evidence. Lornamead objects on the ground and to the extent that it seeks
information outside Lornamead’s possession or information already in Plaintiffs’ possession, and
to the extent it is duplicative of other discovery requests. Lornamead also objects to this
Interrogatory to the extent that it seeks information irrelevant to Plaintiffs’ claims in time, scope,
and geography. Lornamead objects to this interrogatory as inapplicable, irrelevant, and not
reasonably calculated to lead to the discovery of admissible evidence as it has never distributed or
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sold asbestos or asbestos containing products. Lornamead has never intentionally included any
form of asbestos as a part of the composition or as an ingredient of these products.
Subject to and without waiving these objections, Lornamead states: Not Applicable.
Lornamead has never manufactured, sold, distributed, applied and/or installed asbestos or asbestos-
containing products.
B.19. Did defendant ever affix any warnings to any of the asbestos or asbestos containing
products it marketed and distributed? If so for each such product that contained a warning
set forth the following information:
a. The brand and trade name of each such product that contained a warning;
b. The date a warning was attached to each such product;
c. The substance of each warning; and
d. Annex hereto copies of each such warning.
RESPONSE:
Lornamead objects to this Interrogatory and incorporates by reference its Preliminary
Statement and General Objections above. Lornamead also objects to the extent this Interrogatory
is unduly burdensome, overbroad, and seeking information not reasonably calculated to lead to
the discovery of admissible evidence. Lornamead objects on the ground and to the extent that it
seeks information outside Lornamead’s possession or information already in Plaintiffs’
possession, and to the extent it is duplicative of other discovery requests. Lornamead also objects
to this Interrogatory to the extent that it seeks information irrelevant to Plaintiffs’ claims in time,
scope, and geography.
Subject to and without waiving these objections, Lornamead states: Not Applicable.
Lornamead has never manufactured, sold, distributed, applied and/or installed asbestos or asbestos-
containing products, and therefore has not included any such warnings and/or cautions with its
products.
B.20. Set forth the name, address and job position of each and every individual who took part
in your company’s decision to place a warning on its asbestos or asbestos containing
products.
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RESPONSE:
Lornamead objects to this Interrogatory and incorporates by reference its Preliminary
Statement and General Objections above. Lornamead also objects to the extent this Interrogatory
is unduly burdensome, overbroad, and seeking information not reasonably calculated to lead to
the discovery of admissible evidence. Lornamead objects on the ground and to the extent that it
seeks information outside Lornamead’s possession or information already in Plaintiffs’
possession, and to the extent it is duplicative of other discovery requests. Lornamead also objects
to this Interrogatory to the extent that it seeks information irrelevant to Plaintiffs’ claims in time,
scope, and geography.
Subject to and without waiving these objections, Lornamead states: Not Applicable.
Lornamead has never manufactured, sold, distributed, applied and/or installed asbestos or asbestos-
containing products.
B.21. Prior to 1964, did any employee of the defendant ever recommend that it utilize a
warning on its asbestos containing products? If so, identify each such employee, indicate
when he made such a recommendation, indicate what the recommendation was, to whom
it was given and what action was taken thereon.
RESPONSE:
Lornamead refers Plaintiff to its objections and response to Plaintiff’s Standard
Interrogatory No. B.20, which are hereby incorporated by reference.
B.22. Has defendant ever established or maintained a library or libraries which in any way dealt
with industrial hygiene, medicine, safety and engineering? If so, state:
a. Where the library was or is located;
b. The names of all journals which that library subscribed to:
c. For whom and for what purpose the library was established; and
d. Whether there is an inventory of the books and publications which
are or were housed in this library, and if so, attach a copy hereto.
RESPONSE:
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Lornamead objects to this Interrogatory and incorporates by reference its Preliminary Statement
and General Objections above. Lornamead also objects to the extent this Interrogatory is unduly
burdensome, overbroad, and seeking information not reasonably calculated to lead to the discovery
of admissible evidence. Lornamead objects on the ground and to the extent that it seeks
information outside Lornamead’s possession or information already in Plaintiffs’ possession, and
to the extent it is duplicative of other discovery requests. Lornamead also objects to this
Interrogatory to the extent that it seeks information irrelevant to Plaintiffs’ claims in time, scope,
and geography.
Subject to and without waiving these objections, Lornamead states: Not Applicable.
Lornamead has never manufactured, sold, distributed, applied and/or installed asbestos or asbestos-
containing products.
B.23. Did defendant or its agents or employees ever make any effort to keep abreast of medical
literature concerning potential health hazards posed by the use of and/or exposure to
asbestos? Indicate the name, addresses and job positions of all your company’s employees
who reviewed this literature.
RESPONSE:
Lornamead objects to this Interrogatory and incorporates by reference its Preliminary
Statement and General Objections above. Lornamead also objects to the extent this Interrogatory
is unduly burdensome, overbroad, and seeking information not reasonably calculated to lead to
the discovery of admissible evidence. Lornamead objects on the ground and to the extent that it
seeks information outside Lornamead’s possession or information already in Plaintiffs’
possession, and to the extent it is duplicative of other discovery requests. Lornamead also objects
to this Interrogatory to the extent that it seeks information irrelevant to Plaintiffs’ claims in time,
scope, and geography.
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Subject to and without waiving these objections, Lornamead states: Not Applicable.
Lornamead has never manufactured, sold, distributed, applied and/or installed asbestos or
asbestos-containing products.
B.24. Prior to 1964 had your company done any studies or tests or had your company participated
in, been the subject of, or been aware of any studies or tests by others concerning the
potential effects of inhalation of asbestos dust or fibers by one using or being exposed to
asbestos or asbestos containing products. If so, state:
a. The date each study or test was conducted and the date defendant became
aware of said study or test;
b. The names and addresses of the persons conducting each test or study;
c. The purpose of the study or test;
d. The results of each study or test; and
e. If reduced to writing attach a copy hereto.
RESPONSE:
Lornamead objects to this Interrogatory and incorporates by reference its Preliminary
Statement and General Objections above. Lornamead also objects to the extent this Interrogatory
is unduly burdensome, overbroad, and seeking information not reasonably calculated to lead to the
discovery of admissible evidence. Lornamead objects on the ground and to the extent that it seeks
information outside Lornamead’s possession or information already in Plaintiffs’ possession, and
to the extent it is duplicative of other discovery requests. Lornamead also objects to this
Interrogatory to the extent that it seeks information irrelevant to Plaintiffs’ claims in time, scope,
and geography.
Subject to and without waiving these objections, Lornamead states: Not Applicable.
Lornamead has never manufactured,
Preview
FILED: NEW YORK COUNTY CLERK 07/10/2023 10:29 PM INDEX NO. 190002/2023 NYSCEF DOC. NO. 149 RECEIVED NYSCEF: 07/10/2023 EXHIBIT 64 FILED: NEW YORK COUNTY CLERK 07/10/2023 10:29 PM INDEX NO. 190002/2023 NYSCEF DOC. NO. 149 RECEIVED NYSCEF: 07/10/2023 FOLEY & MANSFIELD, PLLP Madelyn Iulo, Esq. (N.J. Bar No. 025051998) Erika Muse, Esq. (N.J. Bar No. 283572018) 86 Chambers Street, Suite 202 New York, New York 10007 Tel: (212) 421-0436 Attorneys for Defendant LORNAMEAD, INC. ------------------------------------------------------------ X KELLEY MALONEY-NAJJAR and TALIB NAJJAR, SUPERIOR COURT OF NEW JERSEY LAW DIVISION: MIDDLESEX COUNTY Plaintiff, Docket No. MID L-3900-22-AS -v- CIVIL ACTION ASBESTOS LITIGATION ARKEMA, INC., et al., DEFENDANT LORNAMEAD, INC.’S OBJECTIONS AND RESPONSES TO Defendants. FORM B AND C INTERROGATORIES ------------------------------------------------------------ X Defendant LORNAMEAD, INC (hereinafter “Lornamead” or “Defendant”), subject to and without waiving any defenses set forth, provides the following objections and responses to Form B and C Interrogatories: PRELIMINARY STATEMENT The following Preliminary Statement is incorporated by reference into each specific Response set forth below. Lornamead is a Delaware corporation with its principal place of business in New York. Lornamead purchased certain Yardley trademarks from a set of companies affiliated with Procter & Gamble (“P&G”) on September 30, 2005. Lornamead did not assume any liabilities related to the Yardley brand or P&G for any products sold or distributed prior to the Yardley acquisition in 2005. Lornamead is not now, and has never been, affiliated in any manner with P&G or its affiliates. Lornamead has never manufactured Yardley talc products. Any Yardley talc product sold to a customer in the United States after 2012 was distributed by an unrelated third 1 FILED: NEW YORK COUNTY CLERK 07/10/2023 10:29 PM INDEX NO. 190002/2023 NYSCEF DOC. NO. 149 RECEIVED NYSCEF: 07/10/2023 party named Wipro Cyprus Ltd., through its subsidiary, Yardley of London Ltd., in accordance with the Yardley license agreement, and their North American distributor. Lornamead and its attorneys have not completed their discovery or preparation for trial, nor have they concluded their analysis of information gathered to date. These responses, therefore, are based upon information presently available to Lornamead and its attorneys and specifically known to individuals preparing these interrogatory responses. Therefore, the interrogatory responses herein are made without prejudice to the right of Lornamead to supplement, amend, revise, correct or otherwise clarify any objection or response or to provide evidence at the time of trial. GENERAL OBJECTIONS / RESERVATION OF RIGHTS 1. Lornamead objects to each Interrogatory on the grounds that Lornamead did not assume any liabilities related to the Yardley brand or P&G for any products sold or distributed prior to the Yardley acquisition in 2005. 2. Lornamead objects to each Interrogatory on the grounds that Lornamead has never been in the business of designing, developing, manufacturing, selling, distributing, brokering, or installing asbestos-containing products or materials or raw asbestos fibers of any type. Lornamead understands the terms “asbestos-containing products” and “asbestos products” as meaning “any supplies, products, materials or equipment containing or including asbestos in whole or in mixture with other products.” No Lornamead product falls within the definition of “asbestos-containing” products or “asbestos products.” 3. Lornamead has never intentionally included any form of asbestos as a part of the composition or as an ingredient in its cosmetics products, and therefore the interrogatories are inapplicable and not reasonably calculated to lead to the discovery of admissible evidence to the extent they are falsely predicated on the assumption that Lornamead incorporated asbestos as an ingredient in any of its products. 2 FILED: NEW YORK COUNTY CLERK 07/10/2023 10:29 PM INDEX NO. 190002/2023 NYSCEF DOC. NO. 149 RECEIVED NYSCEF: 07/10/2023 4. Lornamead objects to each Interrogatory to the extent that they impose greater obligations than those permitted or required under the New Jersey Rules of Civil Procedure and New Jersey Asbestos General Order. 5. Lornamead objects to these interrogatories to the extent that they seek information from or regarding third parties. Lornamead objects to any demand for information that would require Lornamead to conduct investigations into the operations of other companies unrelated to Lornamead’s business operations. Such information is neither admissible nor in any way calculated to lead to the discovery of admissible evidence. 6. Lornamead objects to each Interrogatory to the extent that they seek information protected by the attorney-client privilege and/or the attorney work product doctrine, or by any other applicable privilege. 7. Lornamead objects to all interrogatories, which may be interpreted to include any time period other than the time period at issue in this matter. Any inquiry about other time periods is irrelevant, overbroad, unduly burdensome, and not reasonably calculated to lead to the discovery of admissible evidence. 8. Lornamead objects to each Interrogatory to the extent that they seek information that is not within Lornamead’s custody or control or is equally available to Plaintiffs. 9. Lornamead objects to the instructions and definitions contained in these Interrogatories to the extent that they are vague, ambiguous, overbroad, and unduly burdensome. Lornamead’s Responses herein are based upon the ordinary meanings of the words used and Lornamead’s understanding of any technical terms. 10. Lornamead objects to each Interrogatory to the extent that they seek information not reasonably calculated to lead to the discovery of relevant admissible evidence, are not reasonably limited in duration, are vague, over broad, irrelevant and unduly burdensome, and is otherwise not 3 FILED: NEW YORK COUNTY CLERK 07/10/2023 10:29 PM INDEX NO. 190002/2023 NYSCEF DOC. NO. 149 RECEIVED NYSCEF: 07/10/2023 within the realm of permissible discovery under the New Jersey Rules of Civil Procedure and the standing orders of this Court. Each of these objections are incorporated by reference and adopted in response to each and every discovery response contained herein. 11. Lornamead also objects to the extent the Interrogatory as premature as Lornamead and its attorneys have not completed discovery or preparation for trial, and per the Case Management Order governing this action, fact discovery in this case remains open. Lornamead will supplement this response within the time limits imposed by the Case Management Order and the New Jersey Rules of Civil Procedure. 12. Lornamead reserves the right to supplement, amend, revise, correct or otherwise clarify the Objections and Responses set forth herein, as discovery and investigation is ongoing. Subject to the above Preliminary Statement, Defendant Lornamead, pursuant to the New Jersey Rules of Civil Procedure and New Jersey Asbestos General Order, hereby submits its Objections and Responses to Form B and C Interrogatories. FORM B AND C INTERROGATORIES B.1. State the name, address and job position of each and every individual signing these interrogatories on behalf of the defendant. a. State the name, address and employer and job position of each person, whether defendant’s employees or otherwise who was consulted with or who assisted in the answering of these interrogatories. RESPONSE: Lornamead objects to this Interrogatory and incorporates by reference its Preliminary Statement and General Objections above. Lornamead also objects to the extent this Interrogatory is unduly burdensome, overbroad, and seeking information not reasonably calculated to lead to the discovery of admissible evidence. Lornamead objects on the ground and to the extent that it seeks information outside Lornamead’s possession or information already in Plaintiffs’ possession, and 4 FILED: NEW YORK COUNTY CLERK 07/10/2023 10:29 PM INDEX NO. 190002/2023 NYSCEF DOC. NO. 149 RECEIVED NYSCEF: 07/10/2023 to the extent it is duplicative of other discovery requests. Lornamead also objects to this Interrogatory to the extent that it seeks information irrelevant to Plaintiffs’ claims in time, scope, and geography. Subject to and without waiving these objections, Lornamead states that these responses were assembled by authorized employees and counsel for Lornamead in part from ongoing review of Lornamead’s records and discussions with Lornamead employees. Accordingly, the person verifying these interrogatory responses may not have personal knowledge regarding any specific answer and may be unaware of the identities of all persons who may have knowledge regarding any specific answer and may be responsive to these interrogatories. Lornamead further states that these responses represent the response of Lornamead and are verified by Mr. Scott Pestyner, Senior Vice President, Finance, of Lornamead, Inc. B.2. Give a full and detailed description of the nature of the business that your company is engaged in. RESPONSE: Lornamead objects to this Interrogatory and incorporates by reference its Preliminary Statement and General Objections above. Lornamead also objects to the extent this Interrogatory is unduly burdensome, overbroad, and seeking information not reasonably calculated to lead to the discovery of admissible evidence. Lornamead objects on the ground and to the extent that it seeks information outside Lornamead’s possession or information already in Plaintiffs’ possession, and to the extent it is duplicative of other discovery requests. Lornamead also objects to this Interrogatory to the extent that it seeks information irrelevant to Plaintiffs’ claims in time, scope, and geography. Lornamead objects to this interrogatory as vague and ambiguous as the terms “full and detailed description” and “nature of the business” are undefined. Lornamead further 5 FILED: NEW YORK COUNTY CLERK 07/10/2023 10:29 PM INDEX NO. 190002/2023 NYSCEF DOC. NO. 149 RECEIVED NYSCEF: 07/10/2023 objects to this interrogatory to the extent it seeks publicly available information that is equally accessible by Plaintiff. Subject to and without waiving these objections, Lornamead states that it is a personal care company engaged in the sale of skin and oral care, and bath products. Lornamead has never been in the business of designing, developing, manufacturing, selling, distributing, brokering, or installing asbestos-containing products or raw asbestos fibers of any type. B.3. When did your company commence its business? RESPONSE: Lornamead objects to this Interrogatory and incorporates by reference its Preliminary Statement and General Objections above. Lornamead also objects to the extent this Interrogatory is unduly burdensome, overbroad, and seeking information not reasonably calculated to lead to the discovery of admissible evidence. Lornamead objects on the ground and to the extent that it seeks information outside Lornamead’s possession or information already in Plaintiffs’ possession, and to the extent it is duplicative of other discovery requests. Lornamead also objects to this Interrogatory to the extent that it seeks information irrelevant to Plaintiffs’ claims in time, scope, and geography. Lornamead objects to this interrogatory to the extent it seeks publicly available information that is equally accessible by Plaintiff. Subject to and without waiving these objections, Lornamead states that it was incorporated under the laws of Delaware in 2002. B.4. a. Are or have any of defendant’s predecessors, affiliates, subsidiaries, or parent corporations engaged in the mining, sale and distribution of asbestos and/or asbestos fiber and/or asbestos containing insulation products? If so, state the name of each such entity, describe the nature of the involvement that each entity has or has had in the mining, distribution or sale of these products and materials, and set forth the inclusive dates each was involved in each aspect of this business. b. As to each such entity referred to in (a) above, state: 1. The relationship between defendant and each such entity; 2. The date each such relationship began and terminated; 6 FILED: NEW YORK COUNTY CLERK 07/10/2023 10:29 PM INDEX NO. 190002/2023 NYSCEF DOC. NO. 149 RECEIVED NYSCEF: 07/10/2023 3. The names and addresses of each such entity’s corporate officers and Board of Directors; and 4. The names and addresses of your corporate officers and Board of Directors. RESPONSE: Lornamead objects to this Interrogatory and incorporates by reference its Preliminary Statement and General Objections above. Lornamead also objects to the extent this Interrogatory is unduly burdensome, overbroad, and seeking information not reasonably calculated to lead to the discovery of admissible evidence. Lornamead objects on the ground and to the extent that it seeks information outside Lornamead’s possession or information already in Plaintiffs’ possession, and to the extent it is duplicative of other discovery requests. Lornamead also objects to this Interrogatory to the extent that it seeks information irrelevant to Plaintiffs’ claims in time, scope, and geography. Lornamead objects to this interrogatory to the extent it seeks publicly available information that is equally accessible by Plaintiff. Lornamead also objects to this interrogatory as inapplicable, irrelevant, and not reasonably calculated to lead to the discovery of admissible evidence as it has never used asbestos, asbestos products or asbestos fiber. Nor has any predecessor, affiliate, subsidiary, or parent corporation engaged in such business. Subject to and without waiving these objections, Lornamead states that it is not aware of any predecessors, affiliates, subsidiaries, or parent corporations that engaged in the mining, sale and distribution of asbestos and/or asbestos fiber and/or asbestos containing insulation products. B.5. From the year 1925 until the present, identify and state the address of any organization in which defendant, its officers, agents or employees have belonged, having anything to do with setting standards, regulations or the conducting of research into the use of asbestos, asbestos products or asbestos fiber. RESPONSE: Lornamead objects to this Interrogatory and incorporates by reference its Preliminary Statement and General Objections above. Lornamead also objects to the extent this Interrogatory 7 FILED: NEW YORK COUNTY CLERK 07/10/2023 10:29 PM INDEX NO. 190002/2023 NYSCEF DOC. NO. 149 RECEIVED NYSCEF: 07/10/2023 is unduly burdensome, overbroad, and seeking information not reasonably calculated to lead to the discovery of admissible evidence. Lornamead objects on the ground and to the extent that it seeks information outside Lornamead’s possession or information already in Plaintiffs’ possession, and to the extent it is duplicative of other discovery requests. Lornamead also objects to this Interrogatory to the extent that it seeks information irrelevant to Plaintiffs’ claims in time, scope, and geography. Lornamead objects to this interrogatory to the extent it seeks publicly available information that is equally accessible by Plaintiff. Lornamead also objects to this interrogatory as inapplicable, irrelevant, and not reasonably calculated to lead to the discovery of admissible evidence as it has never used asbestos, asbestos products or asbestos fiber. Subject to and without waiving these objections, Lornamead states: Not Applicable. Lornamead has never been in the business of designing, developing, manufacturing, selling, distributing, brokering, or installing asbestos-containing products or raw asbestos fibers of any type. B.6. Has defendant ever been a member of or affiliated with any trade groups, professional associates or organization? If so, identify each such group, association or organization and set forth the inclusive dates of defendant’s membership in each. RESPONSE: Lornamead objects to this Interrogatory and incorporates by reference its Preliminary Statement and General Objections above. Lornamead also objects to the extent this Interrogatory is unduly burdensome, overbroad, and seeking information not reasonably calculated to lead to the discovery of admissible evidence. Lornamead objects on the ground and to the extent that it seeks information outside Lornamead’s possession or information already in Plaintiffs’ possession, and to the extent it is duplicative of other discovery requests. Lornamead also objects to this Interrogatory to the extent that it seeks information irrelevant to Plaintiffs’ claims in time, scope, 8 FILED: NEW YORK COUNTY CLERK 07/10/2023 10:29 PM INDEX NO. 190002/2023 NYSCEF DOC. NO. 149 RECEIVED NYSCEF: 07/10/2023 and geography. Lornamead objects to this interrogatory to the extent it seeks publicly available information that is equally accessible by Plaintiff. Lornamead also objects to this interrogatory as irrelevant, overbroad and unduly burdensome, and not reasonably calculated to lead to the discovery of admissible evidence to the extent that it is not limited to trade groups, professional associates or organizations involved in addressing issues relevant to this litigation. Lornamead further objects to this interrogatory as vague and ambiguous to the extent the term “professional associates” is undefined. Subject to and without waiving these objections, Lornamead states: Not Applicable. Lornamead has never been in the business of designing, developing, manufacturing, selling, distributing, brokering, or installing asbestos-containing products or raw asbestos fibers of any type. B.7. Has defendant ever been a member of or affiliated with the Asbestos Textile Institute? If so, indicate when your company was affiliated or was a member of this organization. RESPONSE: Lornamead objects to this Interrogatory and incorporates by reference its Preliminary Statement and General Objections above. Lornamead also objects to the extent this Interrogatory is unduly burdensome, overbroad, and seeking information not reasonably calculated to lead to the discovery of admissible evidence. Lornamead objects on the ground and to the extent that it seeks information outside Lornamead’s possession or information already in Plaintiffs’ possession, and to the extent it is duplicative of other discovery requests. Lornamead also objects to this Interrogatory to the extent that it seeks information irrelevant to Plaintiffs’ claims in time, scope, and geography. Lornamead objects to this interrogatory to the extent it seeks publicly available information that is equally accessible by Plaintiff. Lornamead also objects to this interrogatory as irrelevant, overbroad and unduly burdensome, and not reasonably calculated to lead to the 9 FILED: NEW YORK COUNTY CLERK 07/10/2023 10:29 PM INDEX NO. 190002/2023 NYSCEF DOC. NO. 149 RECEIVED NYSCEF: 07/10/2023 discovery of admissible evidence to the extent that it is not limited to trade groups, professional associates or organizations involved in addressing issues relevant to this litigation. Subject to and without waiving these objections, Lornamead states: Not Applicable. Lornamead has never been in the business of designing, developing, manufacturing, selling, distributing, brokering, or installing asbestos-containing products or raw asbestos fibers of any type. B.8. Does your company publish or distribute a manual or booklet which describes the nature of the business that defendant is engaged in? If so, set forth the title of such manual or booklet, indicate when it was published and attach a copy of same hereto. RESPONSE: Lornamead objects to this Interrogatory and incorporates by reference its Preliminary Statement and General Objections above. Lornamead also objects to the extent this Interrogatory is unduly burdensome, overbroad, and seeking information not reasonably calculated to lead to the discovery of admissible evidence. Lornamead objects on the ground and to the extent that it seeks information outside Lornamead’s possession or information already in Plaintiffs’ possession, and to the extent it is duplicative of other discovery requests. Lornamead also objects to this Interrogatory to the extent that it seeks information irrelevant to Plaintiffs’ claims in time, scope, and geography. Lornamead objects to this interrogatory to the extent it seeks publicly available information that is equally accessible by Plaintiff. B.9. Has any employee or representative of your corporation ever attended a conference or meeting of the Asbestos Textile Institute? If so, identify each such individual who attended these conferences or meetings and set forth the dates on which each such individual went to such a conference or meeting. RESPONSE: Lornamead objects to this Interrogatory and incorporates by reference its Preliminary Statement and General Objections above. Lornamead also objects to the extent this Interrogatory 10 FILED: NEW YORK COUNTY CLERK 07/10/2023 10:29 PM INDEX NO. 190002/2023 NYSCEF DOC. NO. 149 RECEIVED NYSCEF: 07/10/2023 is unduly burdensome, overbroad, and seeking information not reasonably calculated to lead to the discovery of admissible evidence. Lornamead objects on the ground and to the extent that it seeks information outside Lornamead’s possession or information already in Plaintiffs’ possession, and to the extent it is duplicative of other discovery requests. Lornamead also objects to this Interrogatory to the extent that it seeks information irrelevant to Plaintiffs’ claims in time, scope, and geography. Lornamead objects to this interrogatory to the extent it seeks publicly available information that is equally accessible by Plaintiff. Lornamead also objects to this interrogatory as irrelevant, overbroad and unduly burdensome, and not reasonably calculated to lead to the discovery of admissible evidence to the extent that it is not limited to trade groups, professional associates or organizations involved in addressing issues relevant to this litigation. B.10. Has your company ever been a member of, been affiliated with or provided funding for the Industrial Hygiene Foundation? If so, indicate when your company was a member or affiliate of this organization and set forth the dates, if applicable, when you provided funding to this organization. RESPONSE: Lornamead objects to this Interrogatory and incorporates by reference its Preliminary Statement and General Objections above. Lornamead also objects to the extent this Interrogatory is unduly burdensome, overbroad, and seeking information not reasonably calculated to lead to the discovery of admissible evidence. Lornamead objects on the ground and to the extent that it seeks information outside Lornamead’s possession or information already in Plaintiffs’ possession, and to the extent it is duplicative of other discovery requests. Lornamead also objects to this Interrogatory to the extent that it seeks information irrelevant to Plaintiffs’ claims in time, scope, and geography. Lornamead objects to this interrogatory to the extent it seeks publicly available information that is equally accessible by Plaintiff. Lornamead also objects to this interrogatory as irrelevant, overbroad and unduly burdensome, and not reasonably calculated to lead to the 11 FILED: NEW YORK COUNTY CLERK 07/10/2023 10:29 PM INDEX NO. 190002/2023 NYSCEF DOC. NO. 149 RECEIVED NYSCEF: 07/10/2023 discovery of admissible evidence to the extent that it is not limited to trade groups, professional associates or organizations involved in addressing issues relevant to this litigation. Subject to and without waiving these objections, Lornamead states: Not Applicable. Lornamead has never been in the business of designing, developing, manufacturing, selling, distributing, brokering, or installing asbestos-containing products or raw asbestos fibers of any type. B.11. Does your company have a Board of Directors? RESPONSE: Lornamead objects to this Interrogatory and incorporates by reference its Preliminary Statement and General Objections above. Lornamead also objects to the extent this Interrogatory is unduly burdensome, overbroad, and seeking information not reasonably calculated to lead to the discovery of admissible evidence. Lornamead also objects to this Interrogatory to the extent that it seeks information irrelevant to Plaintiffs’ claims in time, scope, and geography. Lornamead objects to this interrogatory to the extent it seeks publicly available information that is equally accessible by Plaintiff. Lornamead also objects to this interrogatory as irrelevant, overbroad and unduly burdensome, and not reasonably calculated to lead to the discovery of admissible evidence to the extent that it is not addressing issues relevant to this litigation. Subject to and without waiving these objections, Lornamead states: Not Applicable. Lornamead has never been in the business of designing, developing, manufacturing, selling, distributing, brokering, or installing asbestos-containing products or raw asbestos fibers of any type. B.12. Does your company’s Board of Directors conduct meetings? RESPONSE: 12 FILED: NEW YORK COUNTY CLERK 07/10/2023 10:29 PM INDEX NO. 190002/2023 NYSCEF DOC. NO. 149 RECEIVED NYSCEF: 07/10/2023 Lornamead objects to this Interrogatory and incorporates by reference its Preliminary Statement and General Objections above. Lornamead also objects to the extent this Interrogatory is unduly burdensome, overbroad, and seeking information not reasonably calculated to lead to the discovery of admissible evidence. Lornamead also objects to this Interrogatory to the extent that it seeks information irrelevant to Plaintiffs’ claims in time, scope, and geography. Lornamead objects to this interrogatory to the extent it seeks publicly available information that is equally accessible by Plaintiff. Lornamead also objects to this interrogatory as irrelevant, overbroad and unduly burdensome, and not reasonably calculated to lead to the discovery of admissible evidence to the extent that it is not addressing issues relevant to this litigation. Subject to and without waiving these objections, Lornamead states: Not Applicable. Lornamead has never been in the business of designing, developing, manufacturing, selling, distributing, brokering, or installing asbestos-containing products or raw asbestos fibers of any type. B.13. Have minutes of the Board of Directors meetings been taken and maintained by your company? If so, indicate who has custody of the minutes at this time. RESPONSE: Lornamead refers Plaintiff to its objections and response to Interrogatory B.11, which is hereby incorporated by reference. B.14. Has your company, and/or its subsidiaries or affiliates ever manufactured or distributed asbestos containing products? RESPONSE: Lornamead objects to this Interrogatory and incorporates by reference its Preliminary Statement and General Objections above. Lornamead also objects to the extent this Interrogatory is unduly burdensome, overbroad, and seeking information not reasonably calculated to lead to the 13 FILED: NEW YORK COUNTY CLERK 07/10/2023 10:29 PM INDEX NO. 190002/2023 NYSCEF DOC. NO. 149 RECEIVED NYSCEF: 07/10/2023 discovery of admissible evidence. Lornamead objects on the ground and to the extent that it seeks information outside Lornamead’s possession or information already in Plaintiffs’ possession, and to the extent it is duplicative of other discovery requests. Lornamead also objects to this Interrogatory to the extent that it seeks information irrelevant to Plaintiffs’ claims in time, scope, and geography. Subject to and without waiving these objections, Lornamead states: Not Applicable. Lornamead has never manufactured, sold, distributed, applied and/or installed asbestos or asbestos- containing products. B.15. Give a complete and detailed description of the particular qualities that asbestos has or had that caused your company and/or its subsidiary or affiliate to utilize asbestos in your products. RESPONSE: Lornamead refers Plaintiff to its objections and response to Plaintiff’s Standard Interrogatory No. B.14, which is hereby incorporated by reference. B.16. Did any of the entities from whom you received asbestos fiber or any of the entities referred to in B6, B7, B9 and B10 ever inform you or your company’s employees that asbestos was potentially hazardous to the health of individuals who were exposed to it? RESPONSE: Lornamead objects to this Interrogatory and incorporates by reference its Preliminary Statement and General Objections above. Lornamead also objects to the extent this Interrogatory is unduly burdensome, overbroad, and seeking information not reasonably calculated to lead to the discovery of admissible evidence. Lornamead objects on the ground and to the extent that it seeks information outside Lornamead’s possession or information already in Plaintiffs’ possession, and to the extent it is duplicative of other discovery requests. Lornamead also objects to this Interrogatory to the extent that it seeks information irrelevant to Plaintiffs’ claims in time, scope, and geography. Lornamead objects to this interrogatory as inapplicable, irrelevant, and not 14 FILED: NEW YORK COUNTY CLERK 07/10/2023 10:29 PM INDEX NO. 190002/2023 NYSCEF DOC. NO. 149 RECEIVED NYSCEF: 07/10/2023 reasonably calculated to lead to the discovery of admissible evidence as it has never received asbestos fiber from any entity identified or referred to in Interrogatories B.6, B.7, B.9, or B.10. B.17. If so, for each such company that transmitted such information to you and your company, set forth the following information. a. The name of each and every entity that informed your company that asbestos was potentially hazardous to health; b. The dates you received this information from each such company; c. Indicate how this information was transmitted to you; d. The substance of each warning; and e. Annex hereto copies of each such warning. RESPONSE: Lornamead refers Plaintiff to its objections and response to Standard Interrogatory No. B.16, which is hereby incorporated by reference. B.18. Has defendant distributed or sold asbestos or asbestos containing products in the State of New Jersey? If so, set forth the following information: a. The date that defendant commenced selling asbestos or asbestos containing products in the State of New Jersey; b. The date the defendant terminated the sale of asbestos or asbestos containing products in the State of New Jersey; and c. The areas of New Jersey where asbestos or asbestos containing products were sold. RESPONSE: Lornamead objects to this Interrogatory and incorporates by reference its Preliminary Statement and General Objections above. Lornamead also objects to the extent this Interrogatory is unduly burdensome, overbroad, and seeking information not reasonably calculated to lead to the discovery of admissible evidence. Lornamead objects on the ground and to the extent that it seeks information outside Lornamead’s possession or information already in Plaintiffs’ possession, and to the extent it is duplicative of other discovery requests. Lornamead also objects to this Interrogatory to the extent that it seeks information irrelevant to Plaintiffs’ claims in time, scope, and geography. Lornamead objects to this interrogatory as inapplicable, irrelevant, and not reasonably calculated to lead to the discovery of admissible evidence as it has never distributed or 15 FILED: NEW YORK COUNTY CLERK 07/10/2023 10:29 PM INDEX NO. 190002/2023 NYSCEF DOC. NO. 149 RECEIVED NYSCEF: 07/10/2023 sold asbestos or asbestos containing products. Lornamead has never intentionally included any form of asbestos as a part of the composition or as an ingredient of these products. Subject to and without waiving these objections, Lornamead states: Not Applicable. Lornamead has never manufactured, sold, distributed, applied and/or installed asbestos or asbestos- containing products. B.19. Did defendant ever affix any warnings to any of the asbestos or asbestos containing products it marketed and distributed? If so for each such product that contained a warning set forth the following information: a. The brand and trade name of each such product that contained a warning; b. The date a warning was attached to each such product; c. The substance of each warning; and d. Annex hereto copies of each such warning. RESPONSE: Lornamead objects to this Interrogatory and incorporates by reference its Preliminary Statement and General Objections above. Lornamead also objects to the extent this Interrogatory is unduly burdensome, overbroad, and seeking information not reasonably calculated to lead to the discovery of admissible evidence. Lornamead objects on the ground and to the extent that it seeks information outside Lornamead’s possession or information already in Plaintiffs’ possession, and to the extent it is duplicative of other discovery requests. Lornamead also objects to this Interrogatory to the extent that it seeks information irrelevant to Plaintiffs’ claims in time, scope, and geography. Subject to and without waiving these objections, Lornamead states: Not Applicable. Lornamead has never manufactured, sold, distributed, applied and/or installed asbestos or asbestos- containing products, and therefore has not included any such warnings and/or cautions with its products. B.20. Set forth the name, address and job position of each and every individual who took part in your company’s decision to place a warning on its asbestos or asbestos containing products. 16 FILED: NEW YORK COUNTY CLERK 07/10/2023 10:29 PM INDEX NO. 190002/2023 NYSCEF DOC. NO. 149 RECEIVED NYSCEF: 07/10/2023 RESPONSE: Lornamead objects to this Interrogatory and incorporates by reference its Preliminary Statement and General Objections above. Lornamead also objects to the extent this Interrogatory is unduly burdensome, overbroad, and seeking information not reasonably calculated to lead to the discovery of admissible evidence. Lornamead objects on the ground and to the extent that it seeks information outside Lornamead’s possession or information already in Plaintiffs’ possession, and to the extent it is duplicative of other discovery requests. Lornamead also objects to this Interrogatory to the extent that it seeks information irrelevant to Plaintiffs’ claims in time, scope, and geography. Subject to and without waiving these objections, Lornamead states: Not Applicable. Lornamead has never manufactured, sold, distributed, applied and/or installed asbestos or asbestos- containing products. B.21. Prior to 1964, did any employee of the defendant ever recommend that it utilize a warning on its asbestos containing products? If so, identify each such employee, indicate when he made such a recommendation, indicate what the recommendation was, to whom it was given and what action was taken thereon. RESPONSE: Lornamead refers Plaintiff to its objections and response to Plaintiff’s Standard Interrogatory No. B.20, which are hereby incorporated by reference. B.22. Has defendant ever established or maintained a library or libraries which in any way dealt with industrial hygiene, medicine, safety and engineering? If so, state: a. Where the library was or is located; b. The names of all journals which that library subscribed to: c. For whom and for what purpose the library was established; and d. Whether there is an inventory of the books and publications which are or were housed in this library, and if so, attach a copy hereto. RESPONSE: 17 FILED: NEW YORK COUNTY CLERK 07/10/2023 10:29 PM INDEX NO. 190002/2023 NYSCEF DOC. NO. 149 RECEIVED NYSCEF: 07/10/2023 Lornamead objects to this Interrogatory and incorporates by reference its Preliminary Statement and General Objections above. Lornamead also objects to the extent this Interrogatory is unduly burdensome, overbroad, and seeking information not reasonably calculated to lead to the discovery of admissible evidence. Lornamead objects on the ground and to the extent that it seeks information outside Lornamead’s possession or information already in Plaintiffs’ possession, and to the extent it is duplicative of other discovery requests. Lornamead also objects to this Interrogatory to the extent that it seeks information irrelevant to Plaintiffs’ claims in time, scope, and geography. Subject to and without waiving these objections, Lornamead states: Not Applicable. Lornamead has never manufactured, sold, distributed, applied and/or installed asbestos or asbestos- containing products. B.23. Did defendant or its agents or employees ever make any effort to keep abreast of medical literature concerning potential health hazards posed by the use of and/or exposure to asbestos? Indicate the name, addresses and job positions of all your company’s employees who reviewed this literature. RESPONSE: Lornamead objects to this Interrogatory and incorporates by reference its Preliminary Statement and General Objections above. Lornamead also objects to the extent this Interrogatory is unduly burdensome, overbroad, and seeking information not reasonably calculated to lead to the discovery of admissible evidence. Lornamead objects on the ground and to the extent that it seeks information outside Lornamead’s possession or information already in Plaintiffs’ possession, and to the extent it is duplicative of other discovery requests. Lornamead also objects to this Interrogatory to the extent that it seeks information irrelevant to Plaintiffs’ claims in time, scope, and geography. 18 FILED: NEW YORK COUNTY CLERK 07/10/2023 10:29 PM INDEX NO. 190002/2023 NYSCEF DOC. NO. 149 RECEIVED NYSCEF: 07/10/2023 Subject to and without waiving these objections, Lornamead states: Not Applicable. Lornamead has never manufactured, sold, distributed, applied and/or installed asbestos or asbestos-containing products. B.24. Prior to 1964 had your company done any studies or tests or had your company participated in, been the subject of, or been aware of any studies or tests by others concerning the potential effects of inhalation of asbestos dust or fibers by one using or being exposed to asbestos or asbestos containing products. If so, state: a. The date each study or test was conducted and the date defendant became aware of said study or test; b. The names and addresses of the persons conducting each test or study; c. The purpose of the study or test; d. The results of each study or test; and e. If reduced to writing attach a copy hereto. RESPONSE: Lornamead objects to this Interrogatory and incorporates by reference its Preliminary Statement and General Objections above. Lornamead also objects to the extent this Interrogatory is unduly burdensome, overbroad, and seeking information not reasonably calculated to lead to the discovery of admissible evidence. Lornamead objects on the ground and to the extent that it seeks information outside Lornamead’s possession or information already in Plaintiffs’ possession, and to the extent it is duplicative of other discovery requests. Lornamead also objects to this Interrogatory to the extent that it seeks information irrelevant to Plaintiffs’ claims in time, scope, and geography. Subject to and without waiving these objections, Lornamead states: Not Applicable. Lornamead has never manufactured,