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Pharmacia Corporation (f/k/a Monsanto Company) Objections and Responses to Plaintiff Bobby Lloyd Gilmore's First Interrogatories, Requests for Production and Requests for Admissions, Gillum v. GAF Corp. (2001)

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Monsanto's (Pharmacia's) written objections and responses to a plaintiff's first interrogatories, requests for production and requests for admission in a Dallas County asbestos case brought by premises-based claimants. The responses address Monsanto's use of asbestos-containing materials at its Texas facilities, abatement, contractors, safety practices, dust sampling, and its control of its premises. The exhibit also includes a March 9, 2001 cover letter, a certificate of filing discovery, and a certificate of service with a counsel list.

Author
Edward M. Carstarphen (Woodard, Hall & Primm, P.C., attorney for Defendant Pharmacia Corporation f/k/a Monsanto Company); G. Joe Ellis (Woodard, Hall & Primm, P.C., attorney for Defendant); Douglas B. Dougherty (Woodard, Hall & Primm, P.C., attorney for Defendant); Diane K. Bounds (Woodard, Hall & Primm, P.C., attorney for Defendant)
Published by
Woodard, Hall & Primm, P.C., for Defendant Pharmacia Corporation, formerly Monsanto Company
Series
Union Carbide documents, UC-1892
Date
March 9, 2001
Library no.
ACL Doc 16956 · asbestosclaims.law/library/16956
Rights
A document from asbestos litigation, published for research and historical study.

Read or download

Read online Download the PDF Document UC-1892 · 92 pages · 4.3 MB

What the document holds

  • Pages 1-2: Cover pleading serving Pharmacia/Monsanto's objections and responses, with signature block and certificate of service (March 2001)
  • Pages 3-5: Exhibit 1: objections to instructions and definitions, general response on documents, and assertion of privilege
  • Pages 6-40: Responses to Interrogatories 1-16, Requests for Production 1-41 and Requests for Admission 1-38 (as sent)
  • Pages 41-87: Not provided in this exhibit text; contents unknown
  • Page 88: Letter from Diane K. Bounds to Pat Robinson, Asbestos Court Administrator, transmitting certificate of filing discovery (March 9, 2001)
  • Page 89: Certificate of Filing Certain Discovery
  • Pages 90-92: Certificate of service and list of counsel of record

People and organizations

From Edward M. Carstarphen (Woodard, Hall & Primm, P.C., attorney for Defendant Pharmacia Corporation f/k/a Monsanto Company); G. Joe Ellis (Woodard, Hall & Primm, P.C., attorney for Defendant); Douglas B. Dougherty (Woodard, Hall & Primm, P.C., attorney for Defendant); Diane K. Bounds (Woodard, Hall & Primm, P.C., attorney for Defendant) to Bobby Lloyd Gilmore, through attorneys Holly Huart and Stephanie Finch (Plaintiff; Baron & Budd, Dallas); Pat Robinson (Asbestos Court Administrator, Civil Section (cover letter, p. 88)).

Pages on our site about what this document covers: Air Sampling · Texas Asbestos Exposure Sites: Worksites, Industries, and Trust Coverage.

About this copy

This is document UC-1892 of the Union Carbide documents, documents produced and used as evidence in asbestos lawsuits against Union Carbide, 92 pages.

Cited on this site

Cite this document

Edward M. Carstarphen (Woodard, Hall & Primm, P.C., attorney for Defendant Pharmacia Corporation f/k/a Monsanto Company), G. Joe Ellis (Woodard, Hall & Primm, P.C., attorney for Defendant), Douglas B. Dougherty (Woodard, Hall & Primm, P.C., attorney for Defendant), Diane K. Bounds (Woodard, Hall & Primm, P.C., attorney for Defendant). “Pharmacia Corporation (f/k/a Monsanto Company) Objections and Responses to Plaintiff Bobby Lloyd Gilmore's First Interrogatories, Requests for Production and Requests for Admissions, Gillum v. GAF Corp.” March 9, 2001. Union Carbide documents, UC-1892. Woodard, Hall & Primm, P.C., for Defendant Pharmacia Corporation, formerly Monsanto Company. AsbestosClaims.Law Library, ACL Doc 16956. https://asbestosclaims.law/library/16956.

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