Union Carbide's Objections and Responses to Plaintiffs' Requests for Admission (Set No. 1), Von Raeder v. Crown Cork and Seal (2002)

Union Carbide's general objections and responses to the plaintiffs' first set of Requests for Admission in a Dallas County, Texas asbestos case (Cause No. 02-02436-C). The responses cover Union Carbide's mining and sale of Calidria chrysotile, warning labels, joint compound customers, industry association memberships, and whether Calidria causes disease. Pages 41-71 were not provided; the exhibit ends with a December 2, 2002 certificate-of-written-discovery cover letter to plaintiffs' counsel.

What the document holds

• Pages 1-2: Caption, introduction, signature block and certificate of service dated December 2, 2002
• Pages 3-5: General Objections Nos. 1-7, including a history of the Coalinga mine and Calidria
• Pages 6-40: Responses to Requests for Admission Nos. 1-69
• Pages 41-71: Not provided in this exhibit
• Pages 72-74: Responses to Requests for Admission Nos. 133-138 (partial)
• Pages 75-76: Cover letter of December 2, 2002 from Tina M. Stamps to Scott Frost (Certificate of Written Discovery)

People and organizations

From Gary D. Elliston (DeHay & Elliston, L.L.P., attorney for Defendant Union Carbide Corporation); Jennifer Judin (DeHay & Elliston, L.L.P., attorney for Defendant Union Carbide Corporation); Tina M. Stamps (DeHay & Elliston, L.L.P., attorney for Defendant Union Carbide Corporation) to Lonnie Hubert Von Raeder and Linda Gail Von Raeder, through their attorney Scott Frost, Baron & Budd, P.C. (Plaintiffs).

• Gary D. Elliston (author)
• Union Carbide Corporation (its organization)
• 138th Judicial District Court (named)
• Baron & Budd (named)
• DeHay & Elliston, L.L.P (named)

Related pages

Pages on our site about what this document covers: Asbestos Joint Compound, Drywall Mud, and Texture Coatings · Calidria · California Asbestos Exposure Sites: Worksites, Industries, and Trust Coverage · Chrysotile: White Asbestos, the Most Common Type · Duty to Warn.

About this copy

This is document UC-5434 of the Union Carbide documents, documents produced and used as evidence in asbestos lawsuits against Union Carbide, 76 pages.