Johns-Manville Products Corporation's Answers to Interrogatories in Le Grande v. Johns-Manville (1958)

J-M's sworn interrogatory answers in Frederick Le Grande v. Johns-Manville Products Corporation, Civil No. 741-57 in the U.S. District Court for New Jersey, a suit by a worker for H. W. Porter & Co., a Newark insulation contractor, with a one-page set of supplemental answers. J-M lists the insulation it sold Porter from 1952 to 1956 (Superex, Thermobestos, magnesia pipe covering, Asbestocel, millboard and others) with their asbestos content, from 5–10 percent to 90–100 percent. It says it had "no knowledge of any case of asbestosis ever being contracted by an applicator," that asbestosis "was first contracted by an employee of this defendant at one of its plants in 1946," and that, having had no claims from anyone but its own factory workers, it "had no reason to issue any warnings" to others.

What it shows

The answers concede that J-M's insulation could cause fibrosis if enough dust was inhaled and that "workmen engaged in the formation of these products have developed such a disease." Yet they also say J-M "never had any reason to believe its products were toxic or noxious" and so took no steps to reduce the hazard in its products. The 1946 date for J-M's first case of asbestosis is contradicted by the company's own earlier papers, such as the 1932 report of asbestosis cases at Waukegan and the Waukegan workers' suits of 1934.

In Johns-Manville's chronology

Johns-Manville's own chronology of what the company knew describes this document as follows:

J-M answers LeGrande interrogatory: J-M is aware of asbestos health risk to third parties who, e.g., saw J-M products. Other cases including Brock and Swerski were settled.

Editor's note: J-M's description says J-M answered that it was aware of an asbestos health risk to third parties. The answers say the opposite: J-M had "no knowledge of any case of asbestosis ever being contracted by an applicator" and "had no reason to issue any warnings." The settlements of the Brock and Swerski cases are not mentioned in these papers.