North American Refractories Company's Answers to Plaintiffs' Request for Production in Kanawha County (1995)

North American Refractories Company's answers to the plaintiffs' request for production to all product or supplier
defendants, In re Asbestos III, Circuit Court of Kanawha County, West Virginia, Civil Action No. 92-C-8888. NARCO's
counsel, Joseph S. Beeson of Robinson & McElwee, served them on April 12, 1995 (certificate of service, p. 36). The
copy is marked Plaintiff's Exhibit NAR-166.

In the answers (pp. 1-3), NARCO objected to most requests. It said Exhibit A held catalogs and brochures "for
asbestos-containing products identified at worksites", and that its "small line of asbestos-containing products"
held very small amounts of asbestos in wet or encapsulated form.

Exhibit A (pp. 4-13) has a NARCOLITE bag, castables tables, the 1961 bulletin on an improved NARCOLITE (made at
Curwensville, Pa. and Farber, Mo.), a June 1981 gunning-mix bulletin, a page from an undated Refractories Guide, and
a boiler brochure. Exhibit B (pp. 14-30) is Refractories Institute and OSHA material from 1978-1986. Exhibit C (pp.
31-35) is a 1964 Eagle-Picher bag with an asbestos caution and four letters. In them, Eagle-Picher writes that it made
Staz-On and Unicote under NARCO's label and that the products involved "included asbestos as a constituent". NARCO
asked for the same caution on its bags, and Eagle-Picher passed the request to its Joplin Insulation Plant. Pages 34
and 35 are poor copies and partly illegible.