In Re: Methyl Tertiary Butyl Ether ("MTBE") Products Liability Litigation

Filing 4532

RESPONSE to Discovery Request from ConocoPhillips Company and Phillips 66 Company.Document filed by PHILLIPS 66.(Dillard, Stephen)

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
In Re: Methyl Tertiary Butyl Ether (“MTBE”)
Products Liability Litigation
Master File No. 1:00-1898 (SAS)
MDL 1358
This document relates to:
Commonwealth of Pennsylvania v. Exxon
Mobil Corporation, et al., Case No. 14-cv06228
DEFENDANTS CONOCOPHILLIPS COMPANY AND PHILLIPS 66 COMPANY’S
RESPONSES TO PLAINTIFF’S THIRD REQUEST FOR PRODUCTION
Pursuant to Rules 26 and 34 of the Federal Rules of Civil Procedure, ConocoPhillips
Company and Phillips 66 Company (“Defendants”), by and through their attorney, Stephen C.
Dillard, Norton Rose Fulbright, hereby responds to Plaintiff’s Third Request for Production of
Documents (“the Requests”), as follows:
GENERAL OBJECTION
Defendants object to the definition of “YOU” and “YOUR” as overly broad and unduly
burdensome by including “affiliates, subsidiaries, predecessors, agents and employees”.
REQUEST NO. 1:
All DOCUMENTS which mention, CONCERN or refer to any funding provided to
Charles River Laboratories, Inc. with respect to the Methyl Tertiary Butyl Ether (MTBE): TwoYear Combined Chronic Toxicity/Carcinogenicity Drinking Water Study in Wistar Rates (the
“Study”).
RESPONSE: Following a reasonable search, Defendants have located no documents responsive
to this request.
REQUEST NO. 2:

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A copy of all contracts or agreements between YOU and Charles River Laboratories, Inc.
which mention, CONCERN or refer to the Study.
RESPONSE: Following a reasonable search, Defendants have located no documents responsive
to this request.
REQUEST NO. 3:
All COMMUNICATIONS between YOU and Charles River Laboratories, Inc. which
mention, CONCERN or refer to the Study.
RESPONSE: Following a reasonable search, Defendants have located no documents responsive
to this request.
REQUEST NO 4:
All DOCUMENTS YOU received from, or sent to, Charles River Laboratories, Inc.
which mention, CONCERN or refer to the Study.
RESPONSE: Following a reasonable search, Defendants have located no documents responsive
to this request.
REQUEST NO 5:
All DOCUMENTS YOU received from, or sent to, the Pathology Working Group which
mention, CONCERN or refer to the Study.
RESPONSE: Following a reasonable search, Defendants have located no documents responsive
to this request.
REQUEST NO. 6:.
All COMMUNICATIONS between YOU and the Pathology Working Group which
mention, CONCERN or refer to the Study.

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RESPONSE: Following a reasonable search, Defendants have located no documents responsive
to this request.
REQUEST NO. 7:
All COMMUNICATIONS between YOU and Shari A. Price which mention, CONCERN
or refer to the Study.
RESPONSE: Following a reasonable search, Defendants have located no documents responsive
to this request.
REQUEST NO. 8:
All COMMUNICATIONS between YOU and Kevin McDorman which mention,
CONCERN or refer to the Study.
RESPONSE: Following a reasonable search, Defendants have located no documents responsive
to this request.
REQUEST NO. 9:
All COMMUNICATIONS between YOU and Hussain Shaffi which mention,
CONCERN or refer to the Study.
RESPONSE: Following a reasonable search, Defendants have located no documents responsive
to this request.
REQUEST NO. 10:
All COMMUNICATIONS between each of YOU which mention, CONCERN or refer to
the Study and/or the Final Report Amendment No. 1.
RESPONSE: Following a reasonable search, Defendants have located no documents responsive
to this request.
REQUEST NO. 11:

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All COMMUNICATIONS between YOU and the United States Environmental
Protection Agency which mention, CONCERN or refer to the Study and/or the Final Report
Amendment No. 1.
RESPONSE: Following a reasonable search, Defendants have located no documents responsive
to this request.
REQUEST NO. 12:
All COMMUNICATIONS between YOU and the California Office of Environmental
Health Hazard Assessment which mention, CONCERN or refer to the Study and/or the Final
Report Amendment No. 1.
RESPONSE: Following a reasonable search, Defendants have located no documents responsive
to this request.
Dated: January 4, 2019.

/s/ Stephen C. Dillard
Stephen C. Dillard
Norton Rose Fulbright US LP
1301 McKinney, Suite 5100
Houston, Texas 77010-3095
Phone: [phone]
Fax: [phone]
ATTORNEY FOR CONOCOPHILLIPS
COMPANY AND PHILLIPS 66 COMPANY
CERTIFICATE OF SERVICE

I hereby certify that on January 4, 2019 a copy of the foregoing document was served
electronically on all counsel of record in accordance with the Federal Rules of Civil Procedure.
/s/ Stephen C. Dillard
Stephen C. Dillard

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