IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF ALAMEDA

Transcription

1 DOUGLAS G. WAH, ESQ. L.,AW olrgr; l[ll OP FSHER. 8 HUST POW_ Zk_ANCAO[mO l[ntl[q _AN lrnan :_ :O, :Al_;fOqNA F" "1"1[ *'P*.*O_l[ 4sS_ Om6-OOO0 "" ATTORNEYSFOR Specally Appearng 6 for Served Defendants N THE SUPEROR COURT OF THE STATE OF CALFORNA N AND FOR THE COUNTY OF ALAMEDA 12 ) NO: ) 13 ) DEFENDANTS' STANDARD Plantff, ). NTERROGATORES TO 14 ) plantff VS. ) 15 ) (Wrongful Death) FREBOARD CORPORATON, et al., ) 16 ) 17 Defendant. ) r.,,, ) 18 " 19 PROPOUNDED: ON BEHALF OF DEFENDANTS 20 COORDNATNG DEFENDANT: Please contact wth any questons concernng these 21 nterrogatores, ncludng extensons of tme, etc.. 22 RESPONDNG PARTY: Plantlff, SET NUMBER: WRONGFULDEATH (WD ) Maled: Plantff's Arty:,, Due Date: 1

2 F f / _.. [., NTRODUCTON B" 2 These wrtten questons are "nterrogatores".submtted to 3 you under the provsons of Secton 2030 of the Code of Cvl 4 Procedure of Calforna. You are requred to respond 5 separately and fully to each of these questons. Your answer 6 must be responsve to the queston whch s asked. 7 You are requred to serve your responses to these questons 8 on each party not later than thrty (30) days after the date on 9 whch these questons were served on your attorneys. 0 f any defendant s not satsfed wth the responses to these nterrogatores, any one defendant, after consultaton 12 wth the coordnatng defendant, may move to compel approprate 13 responses under the applcable Calforna Code of Cvl 14 Procedure sectons and after complyng wth Local Rules of 15 court. 16 n answerng these questons, you are requred to furnsh 17 all nformaton whch s avalable to you, even f you do not S. have personal knowledge of the answer. Ths means that you ' 19 _ must furnsh all nformaton on the subject covered by the _ questons whch your attorneys, assstants advsors or _, 21 nvestgators may have, even f they had not told you about t 22 _ up to the tme you answered these questons. 23 f you cannot answer one of these questons fully, you ", 24 _ stll have to furnsh all of the nformaton whch you do have 25 and then you must explan why you cannot answer any further. 26 : o

3 < < 1 DEFNTONS z '. 2. "Document(S)" or "Wrtng(s)" shall "nclude all 3 wrtngs as defned by the Calforna Evdence Code. A 2. A request to "dentfy" a wrtng or document means a 5 request to ether attach such as an exhbt to your answers to 6 these nterrogatores, or to descrbe such wth suffcent 7 specfcty that t may be made the subject of a request for 8 producton of documents. Your descrpton should nclude, 9 wthout lmtaton, an ndcaton of: (a) the author; (b) 0 addressee(s); (c) ts date; (d) the nature of the wrtng or 11 document (e.g., letter, telephone memorandum, audo tape 12 recordng, photograph, etc.); (e) a summary or descrpton of 13 the contents; and (f) the present locaton and custodan 14 thereof A request to "dentfy" an oral communcaton shall 16 " l mean a request to descrbe these communcaton wth lj 17 partcularty, and shall nclude, wthout lmtaton, the 18 :: followng nformaton: (a) the d?ntty of all partes to the 9 communcaton; (b) the dentty of the person whom you contend 20 _ ntated the communcaton; (c) the dentty of all persons : 21 present at the tme of the communcaton; and (d) the tme,.t 22 '_ ;, date and place of the communcaton, t 23' 4. A request to "dentfy" a person or ndvdual means 24 J to state hs or her name, place of employment, present busness l 25 or home address and present busness or home telephone number, j 26,. :,// t o 3 _

4 5. A request to "dentfy" a product, materal or 2 compound means a request to descrbe the product,.materal or 3 compound by the followng means: (a) by the nckname or slang name used n your occupaton; (b) by the name under whch t s 5 sold n the marketplace (trade name); and (c) by ts generc 6 name A request to "dentfy" an employer or busness entty 8 means to state sad entty's address and telephone number. "9 7. As used n these questons, "you" and "your" refer to 0 0 the person who s named above as the respondng party. f more than one respondng party s name, "you" and "your" refer to 12 each respondng party separately, not jontly. A separate copy 13 of these questons has been provded for each respondng party. 14 NTERROGATORES 15, 16 NTERROGATORY NO. : 17 Please state for yourself: l 18 (a) Name:. 19 ' Frst Mddle Last m 20 (b) Relatonshp to the decedent: 21 (c) Date of Brth: "_--_ (d) Place of Brth: s, 23 _ (e) Address: 24 _ (f) Heght: Weght:. 25 (g) Socal Securty Number: -. l 26 _ (h) Kaser Number: ; \ _ -4- o

5 () Mltary Seral Number: ' 2 (j) Government Seral Number: 3 (k) Drver's Lcense Number & State: 4 () All of the names by whch you have been known: 5 6 (m) Hghest grade level completed: 7 (n) Current Spouse's Name: 8 (o) Date of Current Marrage: 9 (p) Name of any Former Spouse: 0 (q) Date of any Former Marrage: (r) Place, date and crcumstances under whch any 12 marrage(s) was (were) dssolved or termnated: 13 ANSWER: NTERROGATORY NO 2: 17 : Please state for the decedent: ': (a) Name: 19 Frst Mddle Last 20, (C) Date of Brth: ' 21 (d) Date of Death: 22 (e) Last Resdence Address: 23, (f) Heght: Weght:..24 (g) Socal Securty Number: 25 (h) Kaser Number: l 26, () Government Seral Number:. : ; \

6 1 (j) Mltary Seral Number: 2 (k) Drver's Lcense Number & State: -- 3 () All of the names by whch the Decedent Was Known: 5 (m) Hghest grade, level completed: 6 (n) Spouse's Name: 7 (o) Spouse's Date of Brth: 8 (p) Date of Marrage: 9 (q) Spouse's Current Address: 0 (r) Spouse's Occupaton/Employer: 11 (s) Name of any Former Spouse(s): 12 (t) Date of any Former Marrage(s): 13 (u) Place, date and crcumstances under whch any 14 marrage(s) was (were) dssolved or termnated. 15 ANSWER: ' _ NTERROGATORY NO. 3: 19 ;'. For each chld of the decedent, of any marrage (ether 20 ; natural or adopted), state: (Attach addtonal sheets, f ' necessary.) a: 22 ' Name Da e of Brth Address., J.. o t 26 { l : - o 4-6-

7 C (.. 1 NTERROGATORY NO. 4: o. 2 ' Are ether of the decedent's natural parents alve? f 3 your answer s "yes", please state for each parent: A (a) Name of parent(s); 5 (b) Current age(s) 6 (c) Any hstory of cancer or respratory dsease. 7 ANSWER: NTERROGATORY NO. 5: f ether of the decedent's natural parents are deceased, 12 please state for each parent: 13 (a) Name of deceased parents(s) 14 (b) Date of death; and 15 (c) " Place where the deceased parent(s)'s death certfcate 16 s fled.. 17 ANSWER: :s NTERROGATORY NO. 6: " 21 Have any of deceased's blood relatves (parents, 22 : grandparents, sblngs, aunts, uncles, cousns) had cancer of ' 23 _ any type? f so, please state: 24 (a) The name and exact relatonshp to the decedent of 25._ each such person; 26 t : // " 1 _ "_ J'l

8 (b) The present resdence address for each such o- lvng. 2 person. _ 3 NTERROGATORY NO. 7: 4 f any person dentfed n your answer to nterrogatory 5 No. 6 s deceased, please state for each such person: 6 (a) Hs/Her complete name; 7 (b) Date of death; 8 (c) Place of death; 9 (d) Place where hs/her death certfcate would be on 0 fle; and 11 (e) Cause of death.. 12 ANSWER: NTERROGATORY NO. 8: 15 State the complete address of each of the decedent's 16 resdences from January frst of the year n whch you contend 17 that the decedent was frst exposed to asbestos to the present, 18 and the nclusve dates of each perod of such resdence. 19 ; ANSWER: 20 _ _ NTERROGATORY NO. 9: f 23 Please state the decedent's educatonal background and 24 _dent" y all nsttutons attended, the date graduated from 25 each _nsttuton, the ma_or course of study and any specal 26 : scholastc honors or degrees receved. "1. f, -8-

9 ANSWFA: 2 o" XNTERROGATORYNO. 0: 6 Were ether you or the decedent ever convcted of a 7 felony? f so, please state fully and n detal the date, 8 place and nature of each such felony convcton. 9 ANSWER: NTERROGATORY NO. : 14 Had the decedent ever been a member of the Armed Forces? 15 f so, please state: each branch of servce n whch the 16 decedent served; the nclusve dates of servce; the date of 17 dscharge from actve duty; the decedent's servce number; each 18 place (e.g., fort, base, staton,.etc.) 'at whch the decedent 19 :,_served; and dutes at each place. f decedent was not a member 20. of the Armed Forces for health reasons, please state such t 21 '" 1_ reasons. t _2 lanswer: 23 "' _. - tt : -9- _ ' ee o.

10 . s / (" 1 J l 1 NTERROGATORY NO. 12 : " r- "' 2 For every doctor who ever treated or examned the decedent 3 durng the last ten (0) years precedng death for KLY 4 condton, and beyond ten (0) years for condtons related to 5 the lungs, respratory system, nternal organs, crculatory 6 sysstem and/or musculo-skeletal system of the trunk, and any 7 addtonal complants or condtons stated n Response to 8 nterrogatory No. 18, please complete the followng: (f-more 9 space s needed, please attach addtonal sheets contanng the 0 requested nformaton ) Doctor's NaMe 8nd Address Dates of Treatment Reason for Treatment, * ' 17 : 18 _. 19 '. 20 ; : 21 : ; Doctor's Name and Address "Dates of Treatment 22 :. " : 23 _ 24. 2s 26 // J :, '

11 1 Reason for Treatment 2.- " Doctor's Name and Address Dates of Treatment Reasgn for Treatment e 16 Doctor's Name and Address Dates of Treatment J " Reason for Treatment n 23" -24 l 25 _ ',, " Ol 26,e " :1 -- '

12 C C - 1 NTERROGATORY NO. 13: 2 For every hosptal n whch the decedent was ever treated,. 3 tested, or examned, whether as an "n-patent" or as an 4 "out-patent" durng the last ten (0) years precedng death 5 for _ condton, and beyond ten (0) years for condtons 6 related to the lungs, respratory system, nternal organs, 7 crculatory system, and/or musculo-skeletal system of the 8 trunk, and any addtonal complants or condtons stated n 9 Response to nterrogatory No. 18, please complete the 0 followng: (f more space s needed, please attach addtonal sheets contanng the requested nformaton.) 12 Dates of Tests, Treatment, Name and Address of Hosptal Examnaton or Hosptalzaton J_ Reason for HosPtal Vst gt z8 19 ' 20 ;: 21 t: Dates of Tests, Treatment, 23, Name add Address of Mosmltal Examnaton or Hosptallzaton. a P [ _ 26 _: 1 \, -12- ' Q

13 ,..'.t 2 "'" 3 Beason _or Hosotal Vst Dates o_ Tests, Treatment-, Name and Address of Hosotal Examnaton or Mosotalzat_n Reason for Hosptal Vst % 17.. a. 18;, _ates o5 Tests, Treatment, 19 N_me Qnd Address of RosDtal Examnaton or Rosotallzaton 20:.. 21 _?? 23 ;' t 25 ', -24., Jteason o_ Hosvtal vst :" 26:,;.t N_ t ' -1,3- --

14 1 2 -: 3 Dates of Tests, Treatment, Name and Address of ffosotal Examnaton or Hosptalzaton Reason for Hosptal Vst ' " NTERROGATORY 14 : For every X-ray of the "trunk" that was ever taken of the decedent, please complete the followng: (f more space s needed, please attach addtonal sheets contanng the 18 : requested nformatlon.) ' Name and Address Date(s) of X-ray Part(s) "of 19 1_ Where X-ray was Taken No X-rays Taken Body X-raved " _ 20 j 21 :" u j 1: 22 ": ; 23 : ;_ =, -2, //. 26 :, // q _.. : ' -14-

15 _._ 1 Results. Conclusons. and/or Daunoss from'each X-ray '" 6 Name and Address Date(s) of X-ray Part(s) of Where X-ray was Taken No. X-rays Taken Body X-raved 8 9 r" Re5%;ts. Conclusons. and/or Daanoss from each X-ray Name and Address Date(s) of X-ray Part(s) of 17 Where x-ray was Taken No. X-rays Taken Body X-raved 18 _ 19 ' 2O o 21 : ; 22,, Results. Conclusons. and/or Oaanoss from each X-ray ; : 25 : " 26 l t

16 C Name and Address Date(s) of X-ray '. Part(s) of ' 2 Where X-ray was Taken No. X-rays Taken Body X-raved Results. Conclusons. and/or Daanoss from each X-raw 8 0 9" NTERROGATORY 15: For every pulmonary functon test that the decedent had ever undergone, please complete the followng: (f more space s needed, please attach addtonal sheets contanng the 16 requested nformaton.) Name and Address Where 17 Test Was Performed Date(s_ of Tests Name of Doctor Admnsterng and/or Tnternretna Test 20 _ g. t Results. Conclusons. add/or Daanoss from each Test : 26 l.,. _ -16- "

17 Jl 1 Name and Address Where Test Was Performed Date(s) of Tests... 2 ", 3 Name of Doctor Admnsterng 4 and/or nterdretna Test Results. Conclusons. and/or Daanoss from each Test Name and Address Where 12 Test Was Performed Date(s) of Tests Name of Doctor Admnsterng 15 add/or nternret_q Test. 17 ' Results. Conclusons. and/or Daanoss from each Test 19 j. 20., : 21 ', : 22 :; 23 " ; 24 _l " t ;" j 25 _ 26, " l -17-

18 w < < NTERROGATORY 16: B-.o 2 Descrbe the name and quantty of each type of drug, 3 tranqulzer, sedatve or other medcaton taken or used by 4 decedent durng the last ten (10) years of the decedent's llfe, 5 specfyng the frequency and purpose of use. 6 ANSWER: NTERROGATORY 17: o 11 Do you or your attorney have any medcal reports from any 12 persons, hosptals, doctors, medcal practtoners or 13 nsttutons that have ever treated or examned the decedent at 14 any tme? f so, please attach copes of your reports to these 15 nterrogatores. f you wll not voluntarly attach copes of 16 reports to the answers of these nterrogatores, then please 17 statefullyandndetal: (a) The dentty of the report, or reports, by date,, 19 ' _ subject matter, name, address, Job ttle or capacty of the 20 ;_ persons to whom t s addressed or drected and the Job ttle 21 ] or capacty of the persons or persons who prepared the same; t: (b) The name, address and present whereabouts of the l 23 _ person who has present custody or control thereof and the h 24 l purpose of sad preparaton. 2slH 26 z] :_ -18-

19 A_R _ '".,, NTERROGATORY 18: fl 8 For each and every complant, symptom, adverse reacton or? other njury whch you contend s drectly or ndrectly 0 related to the decedent's a11eged exposure to asbestos or asbestos-contanng products, please state: 12 (a) The nature and descrpton of such symptom, 13 complant, adverse reacton or njury; 14 (b) The dsease, dsablty or physcal condton to 15 whch sad symptom s related and the nature and extent of Such 16 relatonshp 17.. (C) The date, tme, place and manner n whch such 18 complant, symptom, adverse reacton or njury frst manfested : 19 tself or was made known to the decedent, ncludng all s s 20 l pertnent nformaton as to the source of such knowledge; 21 } (d) Any physcal change n the appearance of the decedent 22.: occasoned by such complant, symptom, adverse reacton or ' njury; 34 (e) Each part of the decedent s body whch you contend t wasaffected; 26 (f) The date upon whch each complant, symptom, adverse Jt 0 reacton or njury was reported to a doctor or physcan; " '

20 ( (.- (g) The name, address and telephone "number of each such 2 l physcan to whom sad complant, symptom, adversereacton or 3 H njury was reported; 4 (h) Whether you clam that such njury. caused the 5 decedent to suffer a =dsablty = as that term s used n Code 6 of Cvl Procedure S 340.2, and f so, when you beleve that 7 the decedent frst suffered such "dsablty. =? lo NTERROGATORY 19: 16 Please state when you were frst advsed that the decedent 17 was sufferng from an asbestos-related dsease. Please'nclude 18 n your answer: e 19 : (a) The date and tme of such determnaton; :. 20 " (b) The name, address and telephone number of the 21. physcan makng such a determnaton; 22.. (c) The method and nformaton upon whch such 23 " determnaton was based; -24 (d).the name, address and telephone number, of any : 25 _ hosptal, medcal nsttuton, laboratort, physcan, nurse, 26 laboratory, technlcan, etc. nvolved n any part of such._. _s,, -20-

21 determnaton;.. 2 (e) The name, address and telephone number of every 3 person, ncludng decedent's relatves, employer or anyone 4 actng n the decedent's behalf, to whom such determnaton was 5 made known. Please nclude the date, tme and place of such 6 revelaton, and the name, address and telephone number of 7 anyone wtnessng sad revelaton; 8 (f) The name, address and telephone number of the 9 decedent's employer(s) at the tme you were so advsed; 10 (g) The specfc course(s) of treatment or therapy, ncludng any medcne prescrbed, as a result of such a e 12 determnaton and the name, phone number and telephone number 13 of each prescrbng physcan; 14 (h) State whether the decedent" followed the medcaton or 15 therapy regme prescrbed by each of the sad physcans for 6 the treatment of sad complant, symptom, adverse reacton or 17 njury; and 18 : _ () Please state the names "and addresses of any other t: t 19 [ physcans or practtoners subsequently affrmng or makng ' 20 _ the same determnaton _ ANSWER: 22 ; t 23 J 24 2s ; l l " "

22 C < 1 NTERROGATOBY 20:.. 2 Dd any of the sad treatng physcans nform the decedent 3 at any tme that the complants, symptoms, adverse reactons or njures may have been caused by factors other than. exposure to 5 asbestos or asbestos-contanng products? f so, please state: 6 (a) The other factors or reasons nvolved; 7 (b) The names, addresses and telephone numbers of the t 8 physcans belevng or suspectng such other factors or 9 reasons to be nvolved; 10 (c) The dates that sad physcans told the decedent that they beleved or suspected that other factors or reasons mght 12 be nvolved; and 13 (d) The reason that sad factors or reasons were excluded z { 14' as possble sources or causes of the symptoms. 15 ANSW_:R: " 16, 17 { 18_ - 19 t t 20 : "24. NTERROGATORY 21: 25 _ Was a Death Certfcate prepared after the death of the 26 decedent? f so, state: "% -22-

23 l 1 (a) Whether t was fled; "," o_. - 2 (b) The offce n whch t was fled; 3 (c) The address and occupaton of the person lsted on 4 the certfcate as the nformant; 5 (d) The relatonshp to or connecton wth decedent of [ 6 the person lsted as the nformant; 7 (e) The name, address and specalty of each doctor 8 furnshng nformaton appearng on the Death Certfcate; : 9 (f) The mmedate cause of death shown on the Death ; 0 Certfcate; and 11 (g) The exact tme, date, and place of death shown on the 12 DeathCertfcate. 13 A S R: 14 s l 16 :, 17_ NTERROGATORY 22:. 18 _ Was an autopsy performed on the body of the decedent? f ' 19" so, for each autopsy, state: 20; (a) The name, address, and offcal capacty of each t 21 : person authorzng or orderng the autopsy; 22 (b) The relatonshp to or connecton wth decedent of 23 each person authorzng or orderng the autopsy; 24 (c) Why the autopsy was ordered; 25 (d) The name, addtess, occupaton and professonal 26 specalty of each person performng the autopsy; -23-

24 ". < C, o, 1 (e) The tme and date the autopsy was performed; 2 (f) The cause of death shown by the autopsy; 9 3 (g) The name, address, and occupaton of each person : 4 havng custody of the report of the results of the a_topsy; and : 5 (h) Whether you have or can obtan a copy of the autopsy j 6 report,, or f you wll doso wthout a moton to produced, ' 7 attach a copy of each autopsy report to your answers to these ;. 8 nterrogatores. 9 ANSWER: lo ll ' NTERROGATORY 23: 14 DO you know of any pathology sldes that were made of any 15 tssue samples of the decedent at any tme? f your answer.s 1 16 n the affrmatve, for each set of sldes made please state: 17 _ (f more than one, please attach llst.) 18 :. (a) The name of the hosptal; 19 :' (b) The name of the doctor; 6 20.: (C) The-current locatlon; and :. 21 : _ "24 ' 25 " 26 (d) The date sad sldes were made

25 C NTERROGATORY 24: " 21. Please state the name, address, and telephone number of, :.t each and every physcan not dentfed above to whom the ' 4 decedent's records were submtted for analyss, revew, and who ' 5, subsequently examned the decedent exceptng consultants, 6 ANSWER: J; " NTERROGATORY 25: 11 Had the decedent ever suffered any personal njures or 12 llnesses other than those nvolved n ths lawsut? f yes, 13 state for each such njury: 14 (a) The date, place, names of persons nvolved, and 15 crcumstances surroundng such njury or llness; 16 " (b) The nature and extent of the njures or llnesses - 17 ncludng any ll effects or dsabltes remanng at'the tme S ;, of the last treatment or examnaton; 19 (c) The nature and extent of the njures or llnesses 20. ncludng all ll effects or dsabltes remanngat the tme 21 of death of decedent; " (d) The names and addresses of all persons who treated or 23 examned decedent, together wth the date of last treatment or "24 examnaton; and 0 25 (e) "The nature, source and amount of any dsablty : 26. benefts, pensons or other payments for such njures or \ -25-

26 < C 1 llnesses. 2 ANSWER: 3,l : t 4 "_ 5 6 NTERROGATORY 26: 7 Dd the decedent ever smoke tobacco products of any type? 8 ANSWER: 9 _ 10 t 11 NTERROGATORY 27: t 12 f your response to the above nterrogatory s "yes," 13 please state fully and n detal: " "" 14 (a) The dates and tme perods durng whch the decedent 15 smoked; 16 (b) The type of tobacco products the decedent smoked. 17 Please state whether the decedent nhaled the smoke or not; 18 _ ;; _, (c) The daly frequency wth _ whch _he decedent smoked; " :, 19, (d) For any tme perod durng whch the decedent ceased ' 20 smokng tobacco products, please state the reasons for stoppng; 21 l., (e) For any tme perod that the decedent commenced 22 smokng tobacco products after a perod of havng stopped 23..smokng, please state the reasons for begnnng agan; "24,. (f) f the decedent ever smoked cgarettes, please state ). the average number of packs per day so consumed; and 26 _ (g) Please state the commercal brand name(s) of any ' -26-

27 , ] tobacco products that the decedent used... 2 _1 ANSWER: ": NTERROGATORY 28: 6 Was the decedent ever advsed by a physcan to stop ; 7 smokng? f so, gve the date and the name and address of each 8 physcan who gave any such advce. Please state whether the l 9 decedent followed such advce; f so, for how long. f not, " 0 state why not 12 ANSWER: ; _: Z5 l NTERROGATORY 29: 16 : : Descrbe the extent to whch the decedent drank alcoholc 17 ; beverages durng the decedent's lfetme, specfyng the. '' 18: [ partcular knd of alcoholc beverages and the 9uantty 19 consumed per week 20 _ ANSWER: :. "24 _, NTERROGATORY 30: ; 25 _' For every type of employment that the decedent has ever " 26 had, whether self-employed or employed by others, please : -27-

28 l Z complete the followng: (f more space s needed, please 2 attach addtonal sheets contanng the requested nformaton.) ; 3 4 DateSta.rted - : Employers' Name Date Ended J. 5 and Address mo.day,year) DescrPton of Job Dutes: " Do you or your attorneys clam that the decedent was l 14 exposed to asbestos at ths employment? Yes No 15 l Date Started ' Employers' Name Date Ended, 16 and Address _ (mo.dav.vear_ 18 :: 19 Descro on of Job Dutes: 20 ' " Do you or your attorneys clam that the decedent was 25 :' exposed to asbestos at ths employment? Yes No

29 ( (,,. ;.ị 'Date Started -,,Employers' Name Date Ended 2 l and Address _ (mo.dav.vear_ 3 : 4 : 6sl Descr_tonofJobDut.s:, 7, 10 Do you or your attorneys clam that the decedent was exposed to asbestos at ths employment? Yes No Date Started - Employers' Name Date Ended _, 13 and Address mo.dav.vear_ t l 14, l ;_ "" 16 : Deserpto_ of Job Dutes:. * 18 ' : 19, ' Do you or your attorneys clam tha_ the decedent was 22 exposed to asbestos at ths employment? Yes No 23 NTERROGATORY NO. 31: "24 :: _, For each employment n whch you or-your attorneys clam 25-_ the decedent was exposed to asbestos, please llst: 26 _ -29-

30 " (a) The dates of your clamed exposure to asbestos; 2 (b) The manner and duraton of exposure; _: 3 (c) Whether the _ decedent's dutes ncluded the 4 nstallaton of asbestos-contanng materals; 5 (d) Whether the decedent's dutes ncluded the tearng 6 out or removal of asbestos-contanng materals; 7 (e) The type of asbestos-contanng materals to whch.8 the decedent was exposed; 9 (f) The locaton of each job ste, ncludng the name of 0 each plant, state and cty where located, along wth the begnnng and endng date of each job; 12 (g) f the decedent at any tme worked n a shpyard, 13 please dentfy the names of all shps upon whch you worked; 14 (h) For each such job dentfed n response to subparts 15 (f) and/or (g), please state the name and last known address of 16 the decedent's mmedate supervsor or job superntendent on 17 ' such job; 18 () For each such job dentfed 0 n response to subparts 19 (f) and/or (g), please state the names and last know addresses 20 of all persons wth whom the decedent woeked regularly on such 21, job; t 22 ANSWER: :_ 26 " -30-

31 ( ( 1 NTERROGATORY NO. 32: 2 was you ever exposed to asbestos products outsde of the 3 work envronment? f so, please state: 4 (a) Date and place of such exposure; 5 (b) The crcumstances surroundng each exposure; and 6 (c) The manner and duraton of exposure., t- 7 ANSWER: NTERROGATORY NO. 33: 1 13 For each type of asbestos materal and/or t 14 asbestos-contanng product for whch you or your attorney 15 clam that the decedent was exposed, please state: 16 (a) The employer, job ste and dates were contact wth ' t 17 :. each such asbestos materal or product occurred_ 18 " _ (b) The name of the manufacturer of that asbestos materal or product_ 20 (c) The trade name of that materal or produc_ 21 _; (d) Any name used by the decedent or other workers n 22 ". referrng to that materal or product, such as nckname or 23 _' 0 slang term of that materal or product_ "24 ; (e) A descrpton of the box or contaner or wrappng 25 that contaned that product, ncludng sze, color and all 26 wrtng on that box, ncludng sze and color or wrtng_ and ; \, :' -31-

32 1 (f) A descrpton of any labels, tags or warnngs on the o- 2 box, contaner or wrappng advsng of possble health hazards : 3 or advsng of methods of use or precautons to be taken. 4 ANSWER: 5 6, NTERROGATORY NO. 34: 0 At any locaton where you or your attorney clam the 11 decedent was exposed to asbestos, were there any carto: 12 contaners or wrappngs bearng the name, the trade name or any 13 other dentfcaton of any of the defendants n ths lawsut? 0 14 f so, please state separately for each defendant: 15 (a) "Each locaton, the nclusve dates and the frequency 16 ' that these cartons, contaners or wrappngs were present_ 17 _: (b) The dentty of each person who can testfy that such " _ 18 _., cartons, contaners or wrappngs were present; 19 (c) The dentty of each document that ndcates that 20.: such cartons, contaners or wrappngs were present_ t 211 (d) The type of asbestos materal and/or 22 asbestos-contanng products whch were contaned n each 23 carton, contaner or wrappng.. -24,,'ANSWER: s 25 :

33 1 NTERROGATORY NO. 35: "'. 2 f the decedent was ever exposed to asbestos produces 3 manufactured by companes not named as defendants n ths 4 lawsut, please state: 5 (a) The dentty of the manufacturer of sad product; 6 (b) The date and place of each such exposure; 7 (c) The crcumstances surroundng each such exposure 8 (.e., whether you were workng wth the product or merely-near 2 9 an area where t was beng used); j 0 (d) The nature of the product; and 11 (e) As to any such exposure n a work stuaton, the 12 dentty of the decedent's employer, as well as the address of 13 the partcular _ob ste at whch you was so exposed. 14 " ANSWER: '_. 18 " ' ". : 19 ;' NTERROGATORY NO. 36: 20 TO the best of your personal knowledge, based on any 21 nformaton decedent may have communcated to you, what 22 percentage of your total alleged contact or exposure to 23 _ asbestos or materals contanng asbestos do you attrbute to..24 : each ndvdual or entty whch you clam was a manufacturer or. 25 ; suppler of asbestos or materals contanng asbestos? 26 ". (a) Please ndcate the manner and factors reled upon n ' -33-

34 ' : ;. : l makng each usch percentage calculaton; ". 2 (b) Please state the dentty, capactes an_ job ttles : 3 :[ of all ndvduals assstng you or otherwse nvolved n 4 calculatng the above percentages; 5 (c) Please dentfy all documents, wrtngs or other 6 records, f any reled upon n calculatng the percentages : 7 referred to above and further, state the present locaton and 8 the dentty of the present custodan of each such document or 1 9 wrtng; 0 (d) f you are unable to attrbute such percentages, please state all efforts you have made to ascertan suct. 12 percentages, 13 ANSWER: ,. "" 17 '" NTERROGATORY NO. 37: t 18 For each person that worked wth the "decedent durng any " 19 _..tme n whch you clam that the decedent was exposed to t 20 asbestos, please state: 21 _ (a) That person's name; 22 (b) That person's place of employment where sad asbestos 23 " exposure occurred; 24. (c) The nclusve dates durng whch decedent worked, wth 25 _ that person; t 26 (d) The current address of that person; and \ -34--

35 5 ' C C, ḷ : (e) The current phone number of that p_rson, 2 ANSWER: 3 4 _ 6 NTERROGATORY NO. 38: 7 For any person that. you or your attorney s aware of that 8 can dentfy the supply, use or dstrbuton of products 9 contanng asbestos to whch decedent may have been exposed, 1 0 please state:.(a) That person's name; l 12 (b) That person's place of employment' a 13 (c) The dates of sad employment;. J 14 : l (d) The address of sad person; and 15,, j " 16 _ ANS_,,_R: (e) Thephonenumber ls: ", 19 _- " 20 ::, NTERROGATORY NO. _9:" 21: Please dentfy by date, purchaser, seller and product each 22 and every nvoce, bll or statement n your possesson, or 23 _' your attorney's whch demonstrate the sale of any products.: -24 contanng asbestos to any of the places of employment at whch 25 ': 26 " // you clam that the decedent was ezposed to asbestos. N -35-

36 _t 1 ANSWER: 2.,:- t. 4 5 NTERROGATORY NO. 40: 6 Other than as dentfed above, dd the decedent at any, 7 tme receve or have knowledge of any advce, whether wrtten 8 or oral, whch purported to advse or warn the decedent of the - 9 possble harmful affects of exposure to, or nhalaton of, 1 0 asbestos or asbestos-contanng products? f so, please state: 11 // 12 (a) The nature and exact wordng of such advce, warnng, 13 etc. ; " 14 (b) The date, tme, place, manner and crcumstances when J t 15 each such advce, warnng, recommendaton, etc., was gven; and 16 (c) dentfy each wtness to the recepton of such advce, 6 17 warnng, etc. " 18 b ANSWER: ; : 19" 20 :l 21 ; zz :. NTERROGATORY NO. 41: 23 t,. Dd anyone every suggest or recommend that the decedent -24.._ should wear a resprator or dust mask to reduce exposure to, or, 25 J nhalaton of asbestos dust or fbers? f your answer s n t 26 : the affrmatve, please state for each and every such person: o

37 _-. (,+, ' (a) The name, address and telephone number; 2 11 (b) The date, tme and place when such suggeston OE 3 J recommendaton was made; : 4 l.. (c) The name, address and telephone number of.each person 5 present when such suggeston or recommendaton was made to or ' 6 receved by the decedent; 7 (d) The exact wordng and content of such suggeston or 8 recommendaton; 9 (e) The type, make and model of each devce referred to n : 0 each suggeston or recommendaton? (g) The nature of any acton, f any taken by you n ' 12 response to such suggeston or recommendaton; and j 13, (h) Descrbe n detal the reasons for any response to.. 14 l such suggeston or recommendaton, short of complete : 15 l conformance thereto ANSt: 17t' : 18 :: : " 21 " NTER_QGATORY NO. 42: _2 Dd the decedent ever see any warnng labels on packages or 23 :' contaners of asbestos products? f so, please state: '.24 ; (a) The type of product; 25.. (b) The name of the manufacturer; 26 (c) Where the decedent saw the labels; \ -37-

38 (d) On what occasons the decedent saw'the labels; and 2 (e) The nature of the warnngs. 3 ANS_rEm: NTERROGATORY NO, 43: 8 Was the decedent ever dscharged from, or dd the decedent "9 every voluntarly leave a poston due to health problems? f 0 so, please state n detal the tme, name of employer, place 11 and crcumstances. 12 ANSWER: 13" 14 t l NTERROGATORY NO. 44: 17, _' Please state whether any of the decedent's employers ether 18 : requred or made avalable physcal examnatons for ther ' 19 _ employees. f such physcal examnatons have ether been 20 _ requred or made avalable to you, please state: : (a) The nature and extent of examnatons_ 22 _. (b) The frequency of examnatons; 23 (c) Whether they were requred or optonal; -2_ (d) Whether x-ray examnaton was ncluded; 25 (e) The frequency, ncludng specfc dates and tmes wth._ 26 whch the decedent submtted to such examnatons; -38-

39 , 1 1 "1 (f) Whether the decedent receved theresults of any such 2 examnatons; the dates that the results were gven, and the 3 nature of the results; 4 (g) The name, address and telephone number of the " 5 examnng physcan, nurse or techncan; and 6 (h) Any reasons for falng to submt to such examnaton 0 7 when requred or made avalable, f the decedent dd so fal to - 8 submt. 9 ANSWER: 11 l 12 NTERROGATORY NO. 45: 13 Was the decedent ever a member of any labor unon, 1411 ncludng, but not lmted to, the Heat, Frost, nsulaton and J 15 llasbestos workers Unon? f your answer s "yes," please state 16 for each such unon membershp: - 17 _ (a) The name, address and telephone number of each such 118: nternatonal unon and ts number,, along wth the local number 19.. of eachsuchunon; 20. (b) The date and.tme perods durng whch you mantaned 21. membershp n such unon; and 22 (c) Any offces decedent held or commttees on whch the 23 :' decedent served n such unon, ncludng the dates of such "24 ;' "_ servce. 26 // -39-

40 l f" ' 1, 4 5 NTERROGATORY NO. 46: 6 Dd the decedent ever receve a copy of the publcaton 7 known as "The Asbestos Worker'? f so please state: 8 (a) The manner of recept e. subscrpton, provded by 9 unon or employer, purchased etc.; 0 (b) Frequency of recept,.e., regularly, occasonally, rarely, etc.; 12 (c) The name, address and telephone number of each and 13 every person or entty whch provded ths publcaton to the 14 decedent; 15 (d) The pertnent dates and tme perods durng whch the 16 decedent receved sad publcaton; and, 17 (e) The publcaton date ssue and volume number of each 10 -_ l ssue receved by the decedent n any fashon. 19 ANSWER: '" -" 23 NTERROGATORY NO. 47: 2_ Was the decedent a member of a labor unon other than the 1 25 _ nternatonal Assocaton of Heat and Frost nsulators and t 26' Asbestos Workers? -40-

41 ANSWER: 3 NTERROGATORY NO. 48: 4 Dd any unon publcatons that decedent receved, not : Q 5 mentoned above, ever dscuss the subject of worker exposure to ' 6 asbestos? f so, please state: 7 (a) The name and type of publcaton; and 8 (b) The date or dates that such publcaton dscussed the 9 subject of asbestos and the nature of sad dscusson j NTERROGATORY NO. 49: 15 Dd the decedent ever attend any nternatonal or local 16 unon meetngs, semnars, conferences, or conventons where the 17 subject of occupatonal health, and n partcular, exposure to 18 l asbestos was dscussed? f so, pl_ase dentfy: 6 19' (a) The date and place of such meetng, semnar,. 20 l conference or conventon; t_ 21 (b) The reason and/or offcal capacty for the decedent ' " 22 _ attendng; 8 23 _ (c) The name and address of the speaker; "0 "24 (d) A summary of the nformaton presented concernng :0 25 J exposure to asbestos_ and 26 :: _ (e) The names and addresses of any persons wth whom the. e _ '

42 (_,. 2 A_SWT_: l NTERROGATORY NO. 50: 6 f the decedent was not employed at the tme of death, 7 please state the last date the decedent worked, and the reason 8 for dscontnung work: (.e., retrement, lay--off, 9 dsablty, llness, etc.). 10 ANSWER: 14 NTERROGATORY NO. 51: l " 1 ' 15 f the decedent was not workng at or about the date of ' 16 death due to a dsablty, please T_ate: 17 ' t, (a) The nature of the dsablty; t h. 18 : (b) The date of the dsablty; 19' (C) Whether the decedent was recevng any form of 20 dsablty penson_ and ' 21 (d) f o, please state from whom the penson was receved 22 and the monthly amount of such penson. 23 ANSWER: J 25 ":

43 C _, ' mq 4 l _. 2 t Dd the decedent, durng the last ten years of decedent;s h 3.' lfe, engage n any other actvty or partcpate n any way n e 4 any busness desgned to produce ncome not mentoned n the ; 5 precedng nterrogatores? 6 ANSWER: 7 8 NTERROGATORY NO. 53 : _. J 9 f so, for each such actvty or busness, state: 0 (a) A descrpton of the actvty or busness_ :: 11 (b) The amount of tme decedent devoted to the actvty or 12 busness durng each of the last ten years of decedent's lfe; ' 1 and : j 14 (C) The amount of ncome receved from the actvty or j 15 busness for each of the last ten years of decedent's lfe. 16:,, 7" 18 ;," g. dl_ 19 _. 20 :_ NTERROGATORY NO. 54: 21, State fully and n detal your annual earnngs and the 22 decedent's annual earnngs for the last ten years of decedent's 23 lfe:. "24 //.. 25 _ //.. 26,. //

44 _ "_, Year Amount Year. Amount 2 3 l 11 4 ' # 11 t NTERROGATORY NO. 55: State the total hosptal expenses, f any, that" the 14, decedent ncurred to date as a result of the njures, 16 complants.,-etc., whch you attrbute to the decedent's alleged v 17 ' 19. exposure to asbestos. Please temze each charge, f more than, one hosptal s nvolved. : ANSWER: _ " : 20._ ' 21,." " NTERROQATORY NO. 56: 24,; : State the total medcal expense (other than 25 :, 26 hosptalzaton) that the decedent ncurred, or whch was "T -44-"

45 t ncurred on the decedent's behalf, as a result of the njures, : 2 complants, etc., whch you attrbute to the decedent's alleged ". exposure to asbestos, temzng each such charge,, 5 : NTERROGATORY NO. 57: 9 Has any nsurance company, unon or any other person, frm 0 or corporaton pad for, or become oblgated to pay for, any medcal or hosptal expenses ncurred by the decedent as a 12 result of the alleged exposure to asbestos? f so, please lst 13 such expenses, temzng the dates ncurred, the nature of. such 14 : J expenses and the name and address of the nsurance company, 15 unon, person, frm or corporaton who, or whch, has pad, or 16 s oblgated to pay for, the payment of, or rembursement for, 17 sad expenses. 18 t ANSWER: 20, " NTERROGATORY NO. 58: "24 What s the name and address of each undertaker and each 25 funeral home whch attended to decedent's remans?

46 2.o 4 5 NTERROGATORY NO. 59: 6 Was the decedent bured? f so, state: 7 (a) The date of bural; 8 (b) The place of bural, name of the cemetery or- othr J 9 place and ts locaton 10 ANSWER: NTERROGATORY NO. 60: 14 Was the decedent cremated? f so, state: 15 (a) The date of the crematon; tl 16,. (b) The place of crematon. 17 ANSWER: l 18, ' o, 19: 20 _ NTERROGATORY NO. 61: 21 ': ' _ Please llst, tem by tem, all expenses whch were ncurred. 22, n connecton wth the funeral, bural, crematon or other 23 _ means of attendng to decedent's remans' and the name, address 24 t and relatonshp to decedent of each person ncurrng lablty, 25 _ or contrbuton to the payment of such expendtures, lstng 26 l the porton of the lablty ncurred by each and the porton -46-

47 of expendtures pad by each. ' ' 2 ANSWER: _TERROGATORY NO. 62: 6 Had decedent ever at any tme made a clam for, or 7 receved, any health o= accdent nsurance benefts, Workers [ 8 Compensaton payments, dsablty benefts, penson, accdent 9 compensaton payments or Veterans' dsablty compensaton 0 awards? f so, state for each: (f more than one, please attach a lst.) The llnesses, njury or njures for whch 12 decedent made the clam; 13 (a) The names and addresses of decedent's employer(s) at 14 the tme of each njury or llness; 15 (b) The names and addresses of the examnng doctors for 16 J:l each njury or llness; 17 } (c) The name of the board, trbunal or superor offcer 18 j_ before whch or to Whom the clam ol clams were made or fled; 19 J " " ' (d) The date the clam was made or fled; 20 _; : (e) The clam, fle or other number by whch the clam was 21 dentfed; 22 (f) The amount of the benefts, awards or payments; 23, (g) The dates coverng the tmes durng whch the -24 t benefts, awards or payments Were receved; ; 25 ; (h) The agency or nsurance companes from whom decedent 26. receved the awards, benefts or payments; and : \ -47- "-"

48 1 () Decedent's employer at the tme ofsuch clam. : 2 ANSWER: 3 : ' NTERROGATORY NO. 63: 0 dentfy by number, date, Jursdcton, and current status, any Workers' Compensaton proceedng whch has beenfled wth ' 12 respect to any of the matters alleged n the complant. 14 ls 16 NTERROGATORY NO. 64: 17 Had decedent ever fled a sut for damages for any personal 11 S njury? f yes, please state:. " 19 (a) The names and addresses of all plantffs, defendants, 20 : and other partes and ther attorneys; 21 _, (b) The court and place where each sut was fled and the 22 :. date of flng; _. 23 (C) The nature and extent of the njures clamed; and " J 24 l (d) The present status of each sut, and f concluded, the 25 fnal result thereof, ncludng the amount of any settlement or 26 _ -48-

49 f 1 judgment. "" 2 ANSWER: 3 l, 4 o* 5 ; 6 7 NTERROGATORY NO, 6_: 8 Have you ever fled a sut for damages for any personal J 9 njury? f yes, please state:. 10 (a) The names and addresses of all plantffs, defendants, 1 and other partes and ther attorneys; 12 (b) The court and place where each sut was fled and the 13 date of flng; J -" J 14 (c) The nature and extent of the njures clamed; and J 15 (d) The..present status of each sut, and f concluded, the j 16 fnal result thereof, ncludng the amount of any settlement or 17 judgment, o 18 _ ANS,_R: e 19' l 22. : 23., NTERROGATORY NO. 6g: ; "24 _ Have you receved any compensaton of any nature Whatsoever 25 from any source as a result of the decedent's alleged exposure 26 " : to asbestos (ncludng any compensaton benefts, settlements J,o -49-

50 l wth ether a co-defendant or a party, who potentally could,_.j 2 have been a co-defendant had the settlement not been arranged)? 3 ANSWER: NTERROGATORY NO. 67: 7 f your answer to the prevous nterrogatory s n the 8 affrmatve, for each sad payment, state: 9 (a) The name of the party makng sad payment; 0 (b) The amount of sad payment; 11 (c) The year of sad payment; 12 ANSWER: NTERROGATORY NO. 68: 16 State the name, address, and telephone number of each 17 _ :. person known to you, or your attorneys, who can dentfy the ' 8 manufacturer or dstrbutor of any. asbestos-contalnng products 19 _' you allege were n the decedent's general vcnty at any tme. 20 : ;_ perod you allege decedent was exposed to such products.. 21, ANSWER: 22 o 23: 24 Jl NTERROGATORY NO. 69: t 25 l_ ' Please dentfy each and every tangble tem (not already 26, j :1 dentfed above) ncludng documents, correspondence,.. ' -50--

51 , 1 photographs, dagrams, or objects whch you contend evdences 2 ' decedent's ezposure to asbestos-contanng products. 3 A_SWER: 4, 5, 6 : 7 8 t" NTERROGATORY NO. 70: f 9 Have you or anyone on your behalf requested from the socal 0 Securty offce a lstng of all past employers and dates of, employment of the decedent? 12 ANSWER: t - t 15 ' P 16.,. 17 : NTERROGATORY NO, 71: 18 f your answer to the preced.ng n_errogatory s n the 19 affrmatve, please ether attach a copy or gve the employee's 20 ; name, address, date and quarterly socal Securty credt for 21 ' : each employer lsted. 22.: _: 23 "24. 25, 26 ' -51-

52 , C 1 NTERROGATORY NO. 72:._. 2 Dd you have or can you obtan any photographs taken of the ; decedent durng the last'twelve months o_ the decedent's lfe?. 4 ANSWER: NTERROGATORY NO. 73: 7 f SO, and f you wll do so wthout a moton to produce, 8 attach a copy of such photograph dentfed n answer to the 9 above queston to your answers to these nterrogatores ANSWER: NTERROGATORY NO. 74: 14 For every type of employment that _ have ever had, 15 whether self-employed by others, please state: 16 t Date Started- ' Employers Name and Address _ Date Ended ll ' (moo day, year), " 19' - l 19 1' :_, 21 t 22 :, - 23, _,. _. 25 _ ' 'l -52- *

53 2 _ 3 ZNTERROGATORY NO. 75: 4 Dd the decedent de testate? : 5 ANSWER: 6 7 NTERROGATORY NO. 76: 8 f so, state: 9 (a) The date the wll and each codcl was execute; 0 (b) Detals of decedent's attempts, f any, to revoke or. nvaldate the wll; 12 (c) Whether the wll s stll n probate' and, 13 (d) The name, address and telephone number of each 14 attorney of record to the probate of the wll. s ANS R: _TERROGATORY NO. 77:, 18 Dd the decedent de ntestate? f so, s'tate: 19 (a) Whether there s a necessty for admnstraton of 20, decedent's estate; [ 21 (b) Whether applcaton for admnstraton has been fled,,t 22 and f so, the date, name of the court, and ttle of proceedng 23 and fle number; 94 (C) The name and address of each duly qualfed and : 25 apponted admnstrator of the estate; and a 26 { (d) Whether the estate s stll beng admnstered. 1 : o

54 C ( 111 ANSWER:, ' 6 NTERROGATORY N0. 78: t 7 Has there been a proceedng to determne the hers of 8 decedent's estate: f so, state: 9 (a) The name of the court and fle number of the : 10 proceedng; e (b) The name and address of the executor/admnstrator and 12 each counsel of record to the acton, 13 _swe_: h 16 +: o t " l 17 ;: NTERROGATORY NO. 79: 18. Wth respect to each member.of the decedent's household 19' durng the last fve years of decedent's lfe, state the : 20 followng:, 21 : (a) The name, age, occupaton, present address, and 22 relatonshp to decedent; and 23. (b) The porton of the last 12 months of decedent's llfe 24 : durng whch each person was a member of the same household as 25, decedent. 26 // -54-

55 C ( ANSWER: '". t 2 s 4 NTERROGATORY NO. 80: 5 Durng the last fve years of decedent's lfe, dd anyone 6 other than decedent contrbute to decedent's support? f so, 7 for each such person, state: 8 (a) The nameand address; J 9 (b) The relatonshp to or connecton wth decedent; 0 (c) The amount of each contrbuton, specfyng whether n 1 l money servces gfts or other forms; 1 12 (d) The motvaton of the person for makng the J 13 contrbuton; and 14 (e) The annual amount of such contrbutons, j 15 _: 16,, 17" 8 8, 18 :. 19 ;' NTERROGATORY NO 81: "_. 20 Durng the last fve years of decedent's lfe dd anyone 21 _ other than decedent contrbute to support a chld, spouse or 22, parent who has survved decedent? f so, please state: 23 (a) The name and relatonshp of each person recevng "24 ' such support_ 25 :' : (h The name and address of each person other than 26 decedent contrbutng to each survlvor's support;..,.. -S5-.-.

56 (C) The amount of each contrbuton, specfyng whether n Bo-_ 2 money, servces, gfts, or other forms; 3:1 4 contrbuton; (d) The motvaton of the person for makng the ' 5 (e) The annual amount of such contrbutons; and 6 (f) A descrpton of anythng of value decedent receved 7 for such contrbuton NTERROGATORY NO. 82: e 12 Dd decedent, durng the last ten years of decedent's lfe, 13 contrbute money or other tangble benefts to a person other 14 than a chld, spouse or parent of decedent? f so, for each J 15 benefcary, state: 16 (a) The name and address; 17 " (b) The date and place of brth_. q 18 (c) The relatonshp to decedent; 19. (d) The date of each contrbuton; 20 _ ;. (e) The reason for each contrbuton_ 21,_ (f) The amount or value of each contrbuton_ and 22. (g) A descrpton of anythng of value decedent receved 23 n. exchange for such contrbuton.. "24 25 :_ " 26 _

57 1 NTERROGATORY NO. 83: J 2 Wthn the last ten years before death, was decedent ever : 3 1 _udcally determned to have faled to support any person, 4 alleged to be dependent upon decedent? f so, for each such 5 charge, state: 6 (a) The name, address, and relatonshp to decedent of the 1 7 alleged dependent; 8 (b) The date such charges were brought; J 1 9 (c) The name and address of the person makng such charges; 0 (d) The court, trbunal or other agency to. whch, or n whch, such charge was made; 12 (e) A descrpton of the charges aganst decedent; and ' 13 (f) The fnal dsposton of such charges. ] 14 ANSWER: t ' 17 1 NTERROGATORY NO. 84: f s Dd decedent perform servces.'for any parent, spquse, or t 19 : chld who survved decedent? f so, for each person, state: 20 _, (a) The name, address and relatonshp to decedent of the ; 21 '. person for whom the servce was performed; 22 t (b) A descrpton of each servce performed for such 23 ;_, person; 2 1.,, (c) The total tme spent by decedent performng the 25 servce per year and the frequency wth whch decedent 26 _, :_ performed such servce; 'l : \

58 1 (d) The date decedent last performed each such servce; 2 (e) The compensaton, f any, decedent r_ceved for 3 performng each servce; 4 (f) The name, address, and relatonshp to.decedent of 5 each person or agency compensatng decedent for each servce; 6 (g) The total cost to such person of gettng others to 7 perform each servce performed by decedent; and 8 (h) The name, address, and occupaton of each p.erson 9 performng each such servce snce decedent's death. 10 ANSWER: NTERROGATORY NO. 85: 16 DO you clam damages n ths acton based on loss of ' 17 decedent's care, gudance, advce, counsel, tranng, : h f (a) The amount of damages clamed; ; 20 (b) The method by whch such amount was computed or 21 determned; and 22 :e (C) A full descrpton of the bass for the clam. 23 _ 24 q t_ ;; oj -. :1-58- o o

59 C C NTErrOGATORY NO. 86: 2 What hobbes, sports, games, cultural, vocatonal and other 3.. nterests dd you share wth decedent or enjoy n common wth, 4 decedent?. 5 A_Sw_: 6 _ ' 9 NTERROGATORY NO. 87: j 0 How many hours per day dd you regularly spend wth decedent durng the last fve years of decedent's lfe? 12 ANSWER: NTERROGATORY NO. 88: Has there ever been any complant, charge or grevance 18 1_ asserted by decedent aganst you,.or by you aganst decedent, 19 " whether cvl or crmnal, or whether made to a governmental or J 20 :_ nongovernmental agency, company or person? f so, for each, : 21 state: a 22 " (a) The person ntatng the procedure; 23 '.: (b) A descrpton of the complant, charge, or grevance; ; " "24 _' :? (c) The court or governmental body before whch the " 25 l.proceedng was brought; and 26,. (d) The dsposton of the proceedng. " :, -59--