Manville Fund's Answers to Interrogatories in Gunn v. Celotex (1989)

The sworn answers of the Manville Corporation Asbestos Disease Compensation Fund, answering for Johns-Manville, to the Form B interrogatories in Gunn v. The Celotex Corporation, Civil Action 86-5090 in the U.S. District Court for New Jersey, sworn by the Fund's general counsel, David T. Austern, on December 7, 1989. The answers cover Manville's corporate history and subsidiaries, trade associations, warning labels, the studies it funded, the claims of insulation workers before 1970, and the products it sold in New Jersey. Attached as Exhibit A is a 39-page chart of Manville's asbestos thermal insulation and shipyard products, giving each product's fiber type, percent of fiber by weight, and the years it was made, discontinued and first labeled.

What it shows

Manville says it had "confirmation" of asbestosis in the early 1930s, from the medical literature and from employee claims filed in 1929 and the early 1930s, and it lists 53 claims by insulators and other users from 1935 to 1969. That is a different account from its 1958 answers in Le Grande, which dated the first case among its own workers to 1946 and said J-M had "no reason to issue any warnings." Here Manville dates its insulation labels to 1964 and its fiber-bag labels to 1969, and says labeling had been discussed in 1944, 1952 and about July 1958 (for Marinite) without labels being adopted.

About this copy

The scan repeats 23 pages of Exhibit A: PDF pages 129–151 are a second scan of pages 106–128 (exhibit pages 17–39). Another scan of the same answers, with fewer exhibit pages, came in at the same time and is marked as a likely duplicate.