Georgetown Steel Documents

EXHIBIT
B
<)tudy report on
'What changed the color of my boat?'
Oopotltnol'll 01 Hoa/1h and EtMronmonlal Comol
July 1996
The study was done in response to a boat owner's complaint about rust spots
that repeatedly appeared on his boat while it was docked at the Georgetown
Landing Marina. The purpose of the study was to identify the paniculate
associated with the rust-colored spots.
Samples were collected on fiberglass plates at several sites in Georgetown,
including the Georgetown Landing Marina, over a period from Sept. 26, 1995,
to April 1, 1996. The samples collected at the Georgetown sites were
compared with reference samples exposed in Myrtle Beach and in Columbia.
The types of particulate collected, any associated staining and the impact on
the, fiberglass surface were examined.
The study results were published June 27,1996, and showed the following:
1. The rust-colored spots were composed of crystals of goethite (iron
hydroxide, FEOOH). Goethite is an oxidation product of iron. The oxidation
of iron is a naturally occuningprocess that happens anywhere iron, water, and
oxygen are present together.
2. Magnetic metal fragments and magnetite were found both as part of the
rust-colored spots and as isolated particles. These particles were also found
in much lower numbers at the control sites.
The iron-containing metal fragments can be generated by any source that
grinds, abrades, or handles iron. They can be found in road dust and around
automotive repair shops and small machine shops. Georgetown Steel is the
most likely primary source of the particles causing the rust-colored spots in
the study area.
To follow up the study, DHEC is taking these actions:
.1. ~ e e t i n g with Georgetown Steel to see what action the plant plans to take
10 light of the study findings. . .
2. Examining what legal or regulatory recourse is available.
3. Assessing any health implications of exposure to the particulate.
The first evaluation of the study's findings by medical experts is that the
iron oxide itself is not a toxic material. The health risks associated with the
effects of inhaling the particles over time would depend on the size of the
particles. The magnetic metal fragments and magnetite particles
found with the stains ranged in size from 4 to 50 microns in diameter,
averaging about 10 microns. Many of these particles are large enough
to be prevented from reaching deep in the lung because of the
cleansing action of nasal breathing, entrapment of particles in the
mucus of the upper airways, and the cilia action of the lung, along with
coughing. Further assessment will be done on the particle sizes
present in Georgetown, using standard collection methods, and the
health implications.
4. Investigating the experience of other steel mills, especially those
near coastal waters, in other states to see if similar problems are
occurring and, if not, what is different in those situations.
First calls to Florida and Pittsburgh have not identified similar
problems. Additional exploration is being done.
Questions and
requests for
additional details
may go to:
Robert Schilling
Air Quality Analysis
(803) 935-7020
Kari Terry
Waccamaw EQC
District
(803) 448-1902
LillMood
Community Liaison
(803) 734-5440
STATE OF SOUTH CAROLINA )
)
COUNTY OF GEORGETOWN )
)
John and Patricia Burgess, Linda Cribb )
Davidson, L.J. Meyer, Wilbur and Shirley )
Carter, Marilyn Burkhardt, Bruce Chandler, )
C.M. Bush, Virginia Huggins, Paul I. Skoko,)
and Helen J. Keith, individually and as )
representatives of the Class, )
)
Plaintiffs, )
)
)
)
vs. )
)
Georgetown Steel Corporation, )
)
Defendant. )
------------------------- )
IN THE COURT OF COMMON PLEAS
COMPLAINT
Trespass, Nuisance, Negligence and
Violation of State and Federal Law
(Jury Trial Requested)
The plaintiffs, complaining of the defendant herein, would respectfully show unto this
Court as follows:
1. The plaintiffs, John and Patricia Burgess are citizens and residents of the County of
Georgetown, State of South Carolina.
2. The plaintiff, Linda Cribb Davidson, is a citizen and resident of the County of
3. The plaintiff, LJ. Meyer, IS a citizen and resident of the County of
4. The plaintiffs, Wilbur and Shirley Carter, are citizens and residents of the County of
5. The plaintiff, Marilyn Burkhardt, IS a citizen and resident of the
County of Georgetown, State of South Carolina.
6. The plaintiff, Bruce Chandler, is a citizen and resident of the County of
7. The plaintiff, C.M. Bush, is a citizen and resident of the County of Georgetown,
State of South Carolina.
8. The plaintUI: Virginia Huggins, is a citizen and resident of the County of
9. The plaintiff, Paul!. Skoko, IS a citizen and resident of the County of
10. The plaintiff, Helen 1. Keith, IS citizen and resident of the County of
11. The plaintiffs, John and Patricia Burgess, Linda Cribb Davidson, L. 1. Meyer, Wilbur
and Shirley Carter, Marilyn Burkhardt, Bruce Chandler, C. M. Bush, Virginia Huggins, Paul I. Skoko
and Helen 1. Keith are real property owners in the city of Georgetown, State of South Carolina,
whose real property has been adversely effected and damaged by the actions of Georgetown Steel
Corporation as set forth below and, at all relevant times in this Complaint the term "Plaintiffs' shall
refer to the Plaintiffs individually and/or representatives of the "class".
12 (a)(l) The defendant, Georgetown Steel Corporation, is a Delaware Corporation with
its principle place of business in Georgetown, South Carolina. At all times relevant
herein, the defendant, Georgetown Steel Corporation (Georgetown Steel) owns and
operates a steel mill located in downtown Georgetown, South Carolina. The steel
mill operates virtually twenty-four hours per day and, as a result of the steel mill's
2
life.
operations, it produces literally tons of wastes, toxins, harmful chemicals, harmful and
noxious residue and other by-products which is hereinafter referred to as "mill-dust".
(a)(2) The defendant, Georgetown Steel Corporation, also allows on a daily basis
thousands of pounds of noxious and dangerous "gases" to be released into the
atmosphere which also causes the plaintiffs to be exposed to the "gases" which pose
significant health hazards.
(b) "Mill-dust" causes immediate and severe damage to real property by pitting
and destroying the paint, woodwork, brick, windows, roofs and other parts of the
structure, it causes permanent discoloration to the areas to which it attaches and
causes severe deterioration to the structure. Because of the constant daily barrage of
" mill dust" the real property requires increased maintenance, constant cleaning, more
frequent painting and other cleaning.
(c) Georgetown Steel Corporation operates its steel mill in an area of the city
which is in close proximity to the Plaintiffs. The extreme noise generated by the
operation of the steel mill causes substantial noises that cause the Plaintiffs to be
distracted and interfere with their enjoyment of their property, as well as discomfort
and mental distress.
(d) The Plaintiffs have suffered diminution of property values because of the steel mill's
( e) The "mill dust" and gasses produced by the steel mill are dangerous to health and
13. This action is broUght on behalf of the named plaintiffs, individually and, pursuant to
Rule 23 of the South Carolina Rules of Civil Procedure as a Class action on behalf of the following:
3
All persons who own real property with improvements (residential and
commercial) located within a five (5) mile radius of the defendant's
steel mill located in downtown Georgetown, South Carolina.
14. The plaintiffs and members of the Class are real property owners whose real property
and other structures are adversely effected, damaged, harmed and otherwise by the defendant's steel
mill which produces large volumes of "mill-dust" which, through the actions of the defendant steel
mill are caused to trespass on and adhere to the plaintiffs' property and improvements on their
property. Property owners refer to those who currently own real property (homeowners and business
owners) within the five (5) mile radius of Georgetown Steel Mill.
15. This action is properly brought as a class action, under Rule 23, S.C.R.C.P., for the
following reasons:
a. [Rule 23(a)(1), S.C.RC.P.] The Class consists of hundreds or perhaps
thousands of persons and is so numerous that joinder of all members is impractical.
b. [Rule 23(a)(l), S.c.R.c.P.] There are questions oflaw and/or facts common
to the Class which predominate over any questions effecting individual members, including:
(i) whether the defendant, Georgetown Steel Corporation, knowingly and
intentionally caused the plaintiffs homes and businesses upon their property to be damaged by
allowing "mill-dust" to enter onto the plaintiffs property and cause the plaintiffs real property and
improvements thereon to be damaged;
(ii) Whether Georgetown Steel Corporation has caused through its actions
a nuisance (public and/ private) in regards to its negligent, gross negligence, willful, wanton and
reckless conduct in allowing the "mill-dust" to harm and damage the plaintiffs property;
4
(iii) Whether Georgetown Steel Corporation was negligent, gross negligent,
reckless willful and wanton in the acts complained of in Paragraph 24; ,
(iv) Whether Georgetown Steel Corporation has created a nuisance which
adversely effects the plaintiffs through intentionally and knowingly allowing the "mill-dust" to
accumulate on the plaintiffs property in such volumes as to create severe injury to the plaintiffs
property.
(v) Whether Georgetown Steel has created a public health hazzard which
is harmful to the Plaintiffs' health and well being.
(vi) Whether Georgetown Steel Corporation violated Federal and State
laws in regards to their emissions and other dangerous and damaging wastes and by-products;
c. [Rule 23(a)(3), S.c.R.C.P.] The claims asserted by the plaintiffs are typical of
the claims of the members of the Class.
d. [Rule 23(a)(4), S.C.R.C.P.] The plaintiffs will fairly and adequately protect
the interest of the Class and the plaintiff have retained counsel experienced in Class action and
complex litigation.
e. [Rule 23 (a)(4), S.C.R.c.P.] The Class, as defined, involves only Class
members for whom the amount in controversy exceeds one hundred dollars ($100.00).
f A class action is superior to other available methods for the fair and efficient
adjudication of this controversy for at least the following reasons:
(i) Given the size of individual Class member's claims, few, ifany, Class
members could afford to seek legal redress individually for the wrongs Georgetown Steel has
5
committed against them and the absent Class members have no substantial interest in individually
controlling the prosecution of individual actions;
(ii) Other available means of adjudicating the claims of the Plaintiffs and
members of the Class, such as thousands of individual actions brought separately and pursued
independently in state or federal courts are impracticable and inefficient;
(iii) This action will cause an orderly and expeditious administration of the
class claims, economics of time, effort and expense will be fostered and uniformity of decisions will
be insured;
(iv) without a class action, the Class members will continue to suffer
damages and Georgetown Steel' s tortuous and wrongful conduct and possible violations of law will
proceed without remedy while the Defendant continues to retain and reap the proceeds and profits
of its wrongful conduct;
(v) Management of this action poses no unusual difficulties that would
impede its management by the Court as a class action;
(vi) The claims brought by the plaintiff and members of the Class are not
now, nor have they been, the subject of another class action to the best of Plaintiff's knowledge.
FOR A FIRST CAUSE OF ACTION
TRESPASS
16. The above set forth facts and jurisdictional matters are made a part of this First Cause
of Action through incorporation by reference.
6
17. The d e f'endant. G eorgetov..rn Steel Corpora tion, has operated a steel mill in the
downtown area of Georgetown, South Carolina for approximately twenty nine (29) years.
18. The steel mill takes raw materials, scrap metal and other materials and through its
process manufactures certain and various kinds of steel products, which are shipped to various other
companies throughout the United States and other areas.
19. Raw products, scrap metal, and other materials are received by Georgetown Steel
Corporation by ship, rail car, and truck and the finished products are shipped out in similar fashions.
20. During the manufacturing process, the steel mill converts the raw material to the
finished product and creates various by-products which are harmful, hazardous, toxic, carcinogenic,
and noxious. (mill-dust)
21 . As a result of the creation of the by-products and the resulting "mill-dust", large
amounts of the dangerous by-products are spewed into the air and/or water from, the premises of
Georgetown Steel Corporation and allowed to drift to and invade onto the plaintiffs property.
22. Plaintiffs have never given the defendants permission to use their property in any
fashion and especially have not given permission to the defendants to allow the "mill-dust" to invade
and/or enter their property.
23 . Over the years and more particular, over the last several years, Georgetown Steel has
been informed by certain members of the class that they objected to the harm and filth being forced
upon their property by the Defendant. .
24. The defendant, Georgetown Steel Corporation, has been for many years, aware of the
plaintiffs' and the communities' objections to the enormous volume of "mill-dust" which is allowed
7
to escape and leave the defendant ' s property, which through various methods e entually arrives in
and onto the plaintiffs' property.
25. The defendant, Georgetown Steel Corporation, has made the conscious, intentional
and economic decisions to continue to allow the "mill-dust" to enter into and onto the plaintiffs'
property knowing full well that the "mill-dust" would cause the plaintiffs property damage and health
problems.
26. The defendant, Georgetown Steel Corporation, by and through its actions in allowing
the "mill-dust" to enter onto the plaintiffs' property has trespassed on the plaintiffs' property and
has interfered with the plaintiffs' right to exclusive, peaceable possession of their property and said
trespass is ongoing and continuous.
27. As a direct and proximate result of the defendant's trespass onto plaintiffs' property,
plaintiffs have been injured and damaged in ACTUAL, CONSEQUENTIAL and PUNITIVE
damages.
FOR A SECOND CAUSE OF ACTION
NUISANCE
28. The allegations of paragraphs 1-27 are made a part of this Second Cause of Action
through incorporation by reference.
29. The defendants have created through their unreasonable, intentional and conscious
actions, a nuisance which interferes with andlor is inconvenient to the enjoyment of the plaintiffs' life
and/or property, and which directly and adversely effects the plaintiffs.
8
30. As a direct and proximate result, the plaintiffs ha e been injured and damaged in
ACTUAL, CONSEQUENTIAL, and PUNITIVE damages.
FOR A TBIRD CAUSE OF ACTION
NEGLIGENCE
31 . The allegations of paragraphs 1-30 are made a part of this Third Cause of Action
32. The defendant, in allowing the "mill-dust" and gasses to escape its premises and thus
causing the plaintiffs' to be damaged, has been negligent, grossly negligent, reckless, willful and
wanton in one, more, or all of the following particulars:
(a) in allowing the "mill-dust" to invade and enter upon the plaintiffs' property;
(b) in failing to protect the plaintiffs' property from its "mill-dust";
(c) in failing to take the necessary precautions that would prohibit the "mill-dust"
from entering onto the plaintiffs' property;
(d) in failing to upgrade the steel mill so as to prevent and/or lessen the amount
of "mill-dust" invading the plaintiffs' property;
(e) in allowing toxins and other hazardous materials to escape from the steel mill
and enter onto the plaintiffs' property;
(f) in failing to alert and notify the plaintiffs that it was emitting toxins and other
hazardous materials from its steel plant.
(g) in allowing "mill-dust" to cause the Plaintiffs to be exposed to harmful and
dangerous
33. As a direct and proximate result of the defendant's conduct, plaintiffs have been
injured and damaged in ACTUAL, CONSEQUENTIAL, and PUNITIVE damages.
9
.... cuc "" FOllRTTJ C AnSE OF ACTION
VIOLATION OF STATE AND FEDERAL LAW AND REGULATION
31. The allegations of paragraphs 1-33 are made a part of this Third Cause of Action
32. The Defendant has violated state and federal laws, regulations, and guidelines in
allowing excessive amounts of "mill-dust" and gasses to escape from its steel mill and into the
atmosphere and onto the plaintiffs' property.
33.
The defendant, Georgetown Steel, appreciated the likelihood of harm to the plaintiffs
and has acted with indifference to the requirements of state and federal laws, regulations, and
guidelines.
34. As a direct and proximate result of the defendant's violation of state and federal
laws, regulations, and guidelines, the plaintiffs have suffered and will continue to suffer harm and
damage.
35. The plaintiffs are informed and believe that, as a result of the defendant's violation
of state and federal laws, regulations, and guidelines, they are entitled to ACTUAL,
CONSEQUENTIAL, and PUNITIVE damages.
WHEREFORE, plaintiffs pray for certification of the class defined herein and for judgment
against the defendants for ACTUAL, CONSEQUENTIAL, and PUNITIVE damages together with
the costs of this action and for such other and further relief as may be deemed just and proper.
10
June, 1998
RESPECTFULLY UB. fITTED:
BELL & MOORE, P.A.
BY: ~ ~ ~ ~
1. WARD BELL, ill
11
C. CARTER ELLIOTT, JR.
232 King Street
Post Office Box 2590
Georgetown, South Carolina 29442
(803) 546-2408
ATTORNEY FOR PLAINTIFFS
STATE OF SOUTH CAROLINA )
)
COUNTY OF GEORGETOWN )
)
John and Patricia Burgess, )
Linda Cribb Davidson, L.J. Myers, )
Wilbur and Shirley Carter, )
Marilyn Burkhardt, Bruce Chandler ,)
C.M. Bush, Virginia Huggins, )
Paul I. Skoko, Helen J. Keith, )
Marilyn Rowe, John and Mamie )
Cunningham, Leola Alston, )
Eunice Fraser, T. Goudy Miller, )
Leonard Roach, and Patricia and )
John Wiley, on behalf of )
themselves and others similarly )
situated, )
)
Plaintiffs, )
)
Y. )
)
Georgetown Steel Corporation, )
)
Defendant. )
)
FIFTEENTH JUDICIAL CIRCUIT
C.A. NO. 98-CP-22-385
PLAINTIFFS' MEMORANDUM
IN SUPPORT OF MOTION FOR
PROTECTIVE ORDER
NOW COME PLAINTIFFS, by and through counsel, and on their own behalf as well
as on behalf of those similarly situated, and state the following in support of their Motion for
Protective Order:
Introduction
On August 25, 1998, in conjunction with answering the complaint in this action, the
defendant served extensive interrogatories and requests to produce on the plaintiffs that clearly
exceed the permissible boundaries of discovery allowed by the South Carolina Rules of Civil
Procedure. (See, attaclunent A, hereinafter referred to as udiscovery".) The plaintiffs were
given a thirty-day extension to respond to defendant's discovery requests, but on September
25, 1998 attempted in good faith to respond, reserving their rights to supplement answers and
objections. For numerous reasons detailed below, the oppressive nature of this discovery
necessitates plaintiffs' motion for protective order pursuant to SCRCP 26(c). The plaintiffs
submit herein good cause to justify the exercise of discretion by this Court in granting the
relief sought.
I. Factual and Procedural Background
Three related class actions to which this motion applies were filed on June 18, 1998,
June 29, 1998, and July 16, 1998 by the named plaintiffs on behalf of themselves and similarly
situated classes of watercraft, automobile and residence owners against Georgetown Steel
Corporation ("GSC"). The class definitions as set forth in these complaints state:
1. All persons who own real property with improvements
(residential and commercial) located within a five (5) mile
radius of the defendant's steel mill located in downtown
Georgetown, South Carolina;
2. All persons who own motor vehicles and reside within a
five (5) mile radius of the defendant's steel mill located in
downtown Georgetown, South Carolina; and
3. A. All persons who live within a five (5) mile radius of
the Georgetown Steel Mill and own a watercraft;
B. Also, those persons who own a watercraft and keep,
board and/or store a watercraft within a five (5) mile
radius of the steel mill.
The named plaintiffs, as well as those who are absent class members in the third class
definition set forth above, are watercraft owners who operated, stored, docked or anchored
their watercraft in geographic proximity to the Georgetown steel mill. As a result of
Georgetown Steel Corporation's failure to control noxious or hannful pollutants into the air
and water, the watercraft belonging to class members have incurred severe damages. What
were originally attractive white fiberglass or colored watercraft, as a result of Georgetown
Steel Corporation's conduct, are now ugly, pitted-out, rusty-looking, filthy boats. A report
from the South Carolina Department of Environmental Control ("DHEC") investigating this
matter is attached hereto as Attaclunent B, and the Court is respectfully requested to refer to
this as it bears significantly on this matter. DHEC concluded that a substance called goethite
was spewed by GSC into the atmosphere and was the primary factor in causing the damage.
Two other class actions have also been filed which stem from the same underlying facts . One
case is for property owners in the proximity of GSC who have had their houses virtually
destroyed of aesthetic value. The houses, once painted and clean or with an otherwise
attractive appearance, now appear corroded and covered with rust-colored stains, and are
simply filthy. The other case is for automobile owners in proximity to the steel mill . The
emissions of the mill have a similar effect on automobiles as on boats . Ordinary maintenance
does not eliminate the problem. After a car remains outside for a couple of weeks, the painted
surface appears pitted-out and filthy. The longer a car or boat remains outside, the worse the
problem and the damage incurred.
With all due respect to GSC, it does not take a genius to figure out what is destroying
the real and personal property around the steel mill. All one has to do is get in an automobile
and drive around the area surrounding the mill . This area looks like someone dropped a
chemical bomb on it. Numerous documents from DHEC have verified the tons of pollutants
this mill has spewed into the atmosphere around it.
The plaintiffs in this action are aware of the fact that GSC is a major employer in the
town. However, plaintiffs submit that GSC does not have a license to be irresponsible, to
destroy the plaintiffs' property with immunity or to impair the aesthetic value and quality of
life in the town. Nor does it have a license to conduct abusive discovery in an attempt to ward
off those who would hold them accountable for this damage. The civil procedure rules and the
laws of this State contemplate and prevent abusive discovery tactics, and recognize the Courts'
discretion in granting relief where oppression and undue burden on a party will occur. SCRCP
26(c).
The text of this memorandum discusses certain discovery related to the watercraft class
as an example of the nature of the abuses complained of by plaintiffs. However, attached to
this memorandum is the discovery served in all three cases. The nature of the demands are
virtually identical. In fact, the discovery demanded appears in large part to be identical except
as to the type of property involved in all three cases . Therefore, to eliminate the filing of
duplicative memorandums or motions for protective order, this memorandum is being filed in
all three cases and is requested to be considered in all three cases .
II. Legal Standards
A. Legitimate Goals and Means of Discovery
The legitimate discovery of relevant information regarding the issues in a case is critical
to our civil justice system. Hickman v. Taylor, 329 U.S. 495 (1947); (mutual knowledge of
relevant facts gathered by both parties is essential to proper litigation); Tiedman v. American
Pigment Corp., 253 F.2d 803, 808 (4th Cir. 1958) ("discovery is founded upon the policy that
the search for truth should be aided") . The free exchange of information is a necessary and
desirable goal of the discovery process, and one that the plaintiffs herein wholeheartedly
support. However, a parties' right to discovery is not an unfettered one. The rules proscribe
the permissible boundaries of properly discoverable information: "Parties may obtain
discovery regarding any matter, not privileged, which is relevant to the subject matter involved
.. , (or), , . appears reasonably calculated to lead to the discovery of admissible evidence."
SCRCP 26(b)(1); see generally, 8 C.A. Wright & A.R. Miller, Federal Practice and
Procedure, Sect. 2001 (1970, 2nd Ed. 1994) (discussing purposes of modern discovery rules
upon which the SCRCP were modeled). Where trial preparation materials are sought, a party
may obtain such materials only upon "a showing that the party seeking discovery has
substantial need of the materials in the preparation of his case and that he is unable without
undue hardship to obtain the substantial equivalent of the materials by other means. " SCRCP
26(b)(3); Belcher, el. al. v. Bassett Furniture Industries, et. al., 588 F.2d 904 (4th Cir. 1978).
In promoting full disclosure, the discovery rules do not permit blanket or oppressive discovery
absent this showing of need. Bassett Furniture Industries, supra.
Rule 33(a) requires that a party answering interrogatories furnish such information as is
"available to the party." SCRCP 33(a). The rule governing interrogatories recognizes the
potential burden on parties and allows production of business records rather than forcing the
respondent to conduct expensive compilations . SCRCP 33(c). The burden of extracting
available information is placed on the requesting party where the parties face the same burden
in obtaining the information sought. SCRCP 33(c). Responses contemplated by the rules do
not ordinarily require independent research by the respondent. Alliance to End Repression v.
Rockford, 75 F.R.D. 430 (D.C. Ill. 1976); Porter v. Montaldo s, 71 F.Supp. 372 (D.C. Ohio
1946). Rather, a duty of reasonable inquiry is imposed and a requirement that parties furnish
such information as is available to them. Cinema Amusements, Inc. v. Loew's Inc. , 7 F.R.D.
318 (D.C. Del. 1947). A party cannot be forced to prepare his opponent's case or to make
investigations for his adversary. Territory of Alaska v. The Arctic Maid, 185 F. Supp. 164
(D.C. Alaska 1955).
Thus, if the requests meet the above requirements regarding subject matter and relevance,
the rules require a party only to produce documents and things that are in the party's
"possession, custody or control." SCRCP 34(a)(1). In the rules governing requests for
admission, although not currently before the Court, a similar rationale exists. If after
reasonable inquiry the information is not known or readily obtainable, the rules acknowledge a
party may legitimately be unable to answer. See, SCRCP 36(a), see also; sect. III.g, infra,
regarding impropriety of contention Where material is equally available to
both parties, it is improper to require the answering party to bear the burden. Reynolds v.
Southern Ry. Co., 45 F.R.D. 526 (D.C. Ga. 1968).
The modern rules provide for a broad range of discoverable materials, and the liberal
interpretation of these rules. See, SCRCP 26(a). Policies encouraging access to knowledge
are necessary in ascertaining the truth. See, Cox v. E.!. DuPont de Nemours & Co., 38
F.R.D. 396 (D.S.C. 1965). However, the rules also require courts to step in and establish
reasonable limits to prevent abuses in civil discovery.
B. Courts are Granted Wide Discretion in Controlling Discovery and Preventing
Discovery Abuse
Despite the need for full disclosure of relevant, non privileged information, the
discovery rules expressly recognize that courts are given the discretion, and at times the duty,
to limit discovery under SCRCP 26:
The frequency or intent of use of discovery methods set forth
(herein) shall be limited by the court if it determines that: (i) the
discovery sought is unreasonably cumulative or duplicative, or is
obtainable from some other source that is more convenient, less
burdensome, or less expensive; (ii) the party seeking discovery
has had ample opportunity by discovery to in the action to obtain
the information sought; or (iii) the discovery is unreasonably
burdensome or expensive taking into account the needs of the
case, the amount in controversy, limitations on the parties'
resources, and the importance of the issues at stake in the
litigation. The Court may act upon its own initiative after
reasonable notice or pursuant to a motion under subdivision (c) of
this Rule. SCRCP 26(a)
It is undisputed that the courts have wide discretion with respect to discovery generally,
and regarding issuance of protective orders. Mack v. Great Atlantic and Pacific Tea Co., 871
F.2d 179 (C.A. 1st 1989); Samples v. Mitchell, 329 S.C. 105, 495 S.E.2d 213 (Ct. App.
1997). Invocation of the courts' discretion and duty to reasonably limit discovery is imperative
where one party seeks to overburden an opponent. South Carolina courts have held that
failure to exercise discretion can amount to an abuse of the discretion. Samples, supra, 218.
Other courts note that the trial courts' discretion will only be reversed if "the action taken was
improvident and affected substantial rights." Tiedman v. American Pigment Corporation, 253
F.2d 803, 808 (4th Cir. 1958). The discovery process is not properly used to outspend or gain
leverage over another party. The remedy for oppressive discovery is relief provided for in the
rules and is sought herein. That remedy is the protective order .
C. The Standard for Issuance of Protective Order
The South Carolina rules expressly provide that "for good cause shown" in discovery
matters the court may "protect a party or person from annoyance, embarrassment, oppression,
or undue burden or expense" by issuing a protective order. SCRCP 26(c). This provision
promotes the goals and policies which lie at the very heart of our civil justice system. See,
SCRCP 1. Rule 1 provides the rationale for the provisions contained within the rules ,
including the protective order standards, and provides courts a benchmark in making these
determinations. The Rule provides that the civil procedure rules "shall be construed to secure
the just, speedy, ' and inexpensive determination of every action." SCRCP 1. The degree to
which the requested discovery will aid in the search for truth must be balanced against the
burdens of expense, delay imposed by requests . Bassett Industries, at 908. In this instance,
oppression, not truth seeking, is being advanced. There is no justification for the burden
imposed on the plaintiffs by this discovery. The standard of good cause is met, and an
appropriate protective order should be issued.
III. Demonstration of Good Cause for Issuance of a Protective Order
A. A Protective Order Must Be Granted Under SCRCP 26(c) to Prevent Undue
Burden, Expense and Oppression to the Plaintiffs
The discovery at issue in this motion will serve only to create undue burden,
immeasurable expense, and resulting oppression to the plaintiffs. Moreover, much of the
information demanded, the defendants should know is not available in the foml demanded.
Even a cursory review reveals this fact. (See, attachment A.) The questions, as posed, provide
a textbook example of overbreadth in an attempt to outspend an opponent. This is precisely
the problem that Rule 26(c) addresses. Simply to compile the information requested would
take the plaintiffs and their counsel an inordinate amount of time, and would not lead to the
discovery of relevant information related to class certification issues, much less serve the goals
of justice. Imposition of patently burdensome discovery would only create needless expense,
delay, and make this litigation impracticable to pursue. The defendant's intent is transparent.
Even despite the overly broad, unduly burdensome, and improper nature of this discovery, the
named plaintiffs have in good faith attempted to answer this discovery to the best of their
ability in compliance with the rules. However, much of the information, as well as documents
demanded, is simply excessive, particularly in the context of a class action where the very
purpose of the device is to promote judicial efficiency. It is unfortunate that judicial
intervention into the discovery process at the very inception of this case is needed. However,
the incredible burden of these requests compel the plaintiffs to invoke the protections of
SCRCP 26(c) as described above and to invoke the discretion of the Court in managing this
case at the outset.
B. The Discovery of Information Regarding Absent Class Members is Improper
The vast majority of the discovery demanded by the defendant relates to information
and highly specific documentation from individuals who are not named class representatives.
For example, the definition section of defendant's discovery demands defines "YOU" and
"YOUR" as the named plaintiffs and "other proposed plaintiffs in the purported class." The
very nature of the demands made by defendant clearly show why class treatment is appropriate
and the discovery demands inappropriate. One of the criteria for certification of a class is
numerosity. See, SCRCP 23(a). It is illogical, impracticable and meaningless at this stage to
require the plaintiffs to essentially recite lists of potential class members. If such discovery
were appropriate or even possible at the inception of litigation, there would remain little
rationale for the notice provisions of Rule 23. See SCRCP 23(d)2. Presumably all class
members would be identified, joinder would be practical in such a situation, and the class
members would be able to proceed on their own. This turns the rationale for class actions on
its head. See SCRCP 23. It is simply impossible to cite chapter and verse on each potential
claimant prior to class certification, and plaintiffs maintain to do so at this stage constitutes
unjustified oppression and abuse.
In each of the three class actions, interrogatory 1 demands the address, telephone and
social security number as to "every potential member of the class." Despite the excessive
burden potentially imposed by this request, plaintiffs are in the process of defendants
in good faith with this information as to the class representatives. Common sense should have
been used by defendant before asking this question. Defendant could not have believed before
asking this question that the information demanded as to "every potential member" could be
known by plaintiffs. There are potentially more than a thousand absent class members. The
fact that such information is not specifically available to every potential member mitigates
toward the propriety of this action proceeding as a class action. It further goes to show why
joinder is impracticable and why the demand could not be construed as reasonable or proper
under the rules. In a similar fashion, defendant has, in each of the three class actions,
demanded photographs of every damaged car, boat and house within five miles of the steel
mill. (See Attachment A, requests for production numbers 5, 6, 7, 8, 9 and 10.) Defendant
further demands in interrogatories in each of the three class actions that plaintiffs "identify"!
every boat, automobile or house within five miles of the steel mill. See, Attachment A,
interrogatories 5, 6, 7, 8, 9 and 10.) The rational for such busywork is unclear.
As the Court is well aware, until a class has been certified, absent class members are
passive parties. American Pipe v. Utah, 414 U.S. 538 (1974). The passive nature of the
absent class plaintiffs is at the core of class action litigation. If all absent class plaintiffs were
I "Identify" as stated in the instructions means: a. When referring to a natural person, it means state the person's
full name, title, employer, job description and residence and business addresses. If the present addresses are
unknown, state the person's last know residence and business addresses; b. When referring to a corporation, it
means state the corporation's full name, its state of incorporation, and the address of its registered office, its
principal place of business, and its chief executive office; c. When referring to a partnership, an unincorporated
association or any other entity, it means state the full name of the entity, its date and state of organization and the
addresses of its registered office, its principal place of business and its chief executive office; d. When referring
to a document, it means describe the document with sufficient particularity to allow GSC to specify it in a request
for production of documents and means, without limitation, to state the name, employer, title, and business and
residential addresses, of eaeh person who made or signed the document and to whom the document was addressed
or sent, the date of the document and a concise statement of the nature and subject matter of the document, the
information contained in the document and the time period and geographical area covered by the document; e.
When referring to an oral statement or communication, it means describe the statement or communication by
when ana where it made, identify all lUlU of the Matemem or communication lUlU all
actively participating in this litigation, there would be no need for class treatment as the net
effect of such "joinder" would be that all claims are pursued individually. However, the
named plaintiffs submit that the extraordinary demands for absent class member specific
discovery are overly broad, unduly burdensome, expensive and inappropriate at this stage of
the litigation. Typically, such information in a class action only becomes relevant when
common class issues have been resolved and absent class member specific damages are
addressed. A common practice to resolve the individual issues to which the improper
discovery is presumably directed is through a bifurcated trial plan - after certification - or a
proof-of-claim filing process. Information regarding the detailed facts , names, addresses ,
photographs, tax values and tax identification numbers of every boat, house, car and citizen in
Georgetown is not unreasonably available to anyone with resources, be it plaintiff or
defendant. To the extent such information is available, it would be obtained from a public
entity equally available to plaintiffs and defendants -- the tax assesssors office. However, there
could be no relevant or realistic basis for a defendant to make such extraordinary demands of a
plaintiff at the inception of litigation. There is no legitimate rationale for such a request.
Absent class member discovery should be prohibited at this time.
Generally, discovery in any form from absent class members is permissible only in
special circumstances and upon a clear showing of good cause. Id. Brennan v. Midwestern
United Life Insurance Co. , 450 F.2d 999 (7m Cir. 1971); Interprise Wallpaper Manufacturing
Co. v. Bodman, 85 F.R.D. 325 (S.D.N.Y. 1980); United States v. Trucking Employers, 72
F.R.D. 101 , 104 (D.D.C. 1976); Bisgeiger v. Fotomat Corp. , 62 F.R.D. 118. 119-20 (N.D.
thp. or C'.nmmllniC'.:ltinn
Ill. 1973) (Discovery from absent class members permitted only where absolutely necessary to
trial of case.)
One objective of Rule 23 is the avoidance of a multiplicity of actions. U.S. Parole
Comm'n v. Geraghty, 445 U.S. 388, 402-03 (1980) (Judicial economy and convenience are
two of the factors that justify class actions.) The satisfaction of this goal is hindered by
encouraging exclusion when absent class members are forced to participate in the discovery
process . If an absent class member is intimidated to the point that he/she withdraws and
pursuit of the individual claim is abandoned, another goad of Rule 23 (resolution of corrunon
claims) will be defeated. Wainright v. Kraftco Corp., 54 F.RD. 532, 534 (N.D. Ga. 1972).
A brief sampling of the defendant's discovery requests will convince even the most
neutral of observers that they are clearly abusive. For example, again referring to the
photographs defendant demands as to every affected house, automobile and boat within .5 of a
mile from GSC (See, attachment A, interrogatories 5-10) Defendant further requests the
name, address and "tax value" of each piece of property. This information is in the public
domain, and equally accessible to all parties. These requests clearly exceed the requisite
discovery at this stage of a putative class action by seeking information from absent class
members. The defendant has failed to demonstrate any need for such information.
Additional proof of the abusive nature of the discovery demands is illustrated by the
fact that after demanding such incredibly broad information, the defendant then proceeds to ask
the plaintiffs to break down the above-referenced information even further by requesting the
exact same information from every boat, car or house located within .5 of a mile to 1 mile
from GSC. (i. e., attachment A, interrogatory 5.) N ext, the defendant requests the same
information for any house car or boat located 1 mile to 2 miles from GSC. (Le., attachment
11
A, interrogatory 6.) Continuing with their efforts, the defendant next requests the same
information regarding any boat, car or house from 2 miles to 3 miles from GSc. (i.e.,
attachment A, interrogatory 7.) This nonsensical delineation is continued up to the point of 5
miles. (i.e., attaclnnent A, interrogatories 8,9,10.) If the defendant wishes to conduct
irrelevant geographical hair splitting, it should do so at its own expense.
For the reasons previously stated, this demand for information is improper at this time.
Plaintiffs are entitled to a protective order with regard to these excessively burdensome
requests.
d. The number of interrogatories served exceeds the permissible number of
interrogatories allowed for under the rules
The South Carolina Rules of Civil Procedure limit the number of interrogatories to be
"-'= served: The total number of general interrogatories to anyone party "shall not exceed fifty
questions including subparts, except by leave of court upon good cause shown." SCRCP
33(b)(8). To find further evidence of the overly burdensome nature of this discovery, one
need only count the actual number of questions. Although grouped into 27 interrogatories as
propounded, when subparts are counted, even in a conservative fashion, that number jumps to
over 100. Leave of court must be sought prior to the issuance of interrogatories in excess of
50, including subparts. No such request or good cause showing has been advanced, making
the discovery improper and excessive on its face. Often additional interrogatories are needed
in complex litigation, but this has not yet been addressed by the Court. The defendants should
be required to comply with the limitations imposed by the rules until such time as an orderly
manner of proceeding with discovery has been addressed by the court.
e. The discovery expressly and improperly seeks information protected by the
attorney-client and/or work product privileges.
The discovery sought infringes on applicable privileges. Communications regarding
representation or legal advice between an attorney and a client are privileged and not
discoverable. 'Insurance Co. of N. Amer. v. Union Carbide Corp., 35 F.R.D. 520 (D.Co.
1964) (Documents which are confidential, privileged communications between attorneys and
clients are immune from discovery.) The essential purpose of the attorney-client and work
product privilege is to protect confidential communications. In Re: Grand Jury Proceedings,
727 F.2d 1352, 1355 (4th Cir. 1984); Upjohn Co. v. United States, 449 U.S. 383, 101 S.Ct.
677 (1981). Without protection of this fundamental concept, the civil justice system could not
operate. The rules acknowledge this expressly, and restrict discovery from seeking privileged
information. SCRCP 26(b)(1). The following discovery seeks information which invades the
attorney client privilege or work product privilege.
Interrogatory 2 requests "in specific detail all conversations between YOU and actual or
potential plaintiffs." This information could not have even properly been asked. It directly
demands attorney-client communications.
Interrogatory 11 demands "[a]ll actions taken by you or your counsel to identify
potential class members" Again, this asks for pure work product protected materials.
Interrogatory 12 asks for in detail, "the proposed fee and expenses arrangement
between proposed class counsel and you." This calls for attorney client protected materials.
Although the fee agreements may become relevant at some time in the future, the manner of
expense allocation is not relevant either. The expenses are being advanced by the law firms
involved.
Interrogatory 13 is not directed to the proposed class representatives but solely toward
the lawyers involved. It demands basically the entire career history of counse1 representing the
class in this case. This is not only largely irrelevant, overly broad and unduly burdensome, it
may potentially create privilege and confidentiality problems for class counsel in terms of
divulging client confidences. Plaintiffs have no way of knowing how the defendant intends to
use this information. Unless there is some question regarding the competency of counsel
involved, this questions amounts to pure harassment.
Interrogatory 16 demands specifically information about meetings with counse1 and the
plaintiffs and targets attorney-client communications and raises work product issues. Counsel
would request to be relieved from answering any discovery which pertains to meetings between
them and their clients. To the extent that Interrogatory 16 or 17 could be construed to ask
questions about meetings with other than clients, it has been answered.
Request for Production 11 seeks "(a)ll documents concerning every denial of a request
for appointment as class counsel." Not only is this overly broad to the point of
incomprehension, if there were such instances, it would require plaintiffs counsel to open their
files to defense counsel. This is contrary to the rules of privilege in that work product is
implicated as well as reason.
f. The discovery propounded with respect to class counsel is improper, oppressive,
unnecessary and intended to harass and intimidate.
The defendant served extensive and highly intrusive interrogatories ostensibly aimed at
discovering information about plaintiffs' counsel. Plaintiffs do not take issue with the
propriety of examining the adequacy of representation in class action scenarios, but this
analysis typically applies with respect to the class representatives, not class counsel. See
SCRCP 23(a)4, 23(d)2, 23(d)3. As discussed above, discovery aimed at counsel is not only
overly burdensome, it may infringe on the attorney client privilege, and for no apparent
reason. For example, Interrogatory 21 is not only overly broad, it is irrelevant. Plaintiffs
have admitted that Plaintiffs' counsel are advancing the costs and expenses of this litigation.
There is nothing relevant, nor untoward, about this common practice. The only conceivable
intent is to create undue burden and potential prejudice. Similarly, Interrogatory 20 demands
detailed personal financial information from the plaintiffs/class representatives, essentially
asking them to create balance sheets for the defendant. This is irrelevant, overly broad and
unduly burdensome, and has the potential to create embarrassment and oppression. Therefore,
plaintiffs request they be relieved from unwarranted intrusion regarding their personal
finances.
While adequacy of representation is a consideration in class certification, this does not
make counsel a party to the action. The defendant is apparently of the view that by
representing the class, this opens up the law firms involved to discovery, their files become
"open books," and counsel submits themselves to harassment. Not only does this present
privilege problems, as discussed above, plaintiffs maintain this is improper and sets a
dangerous precedent. Not content with case names, docket numbers, captions, and
identification of parties, the defendants would perhaps next ask to review these files and have
plaintiffs hand over all their class related work product. These requests are intrusive and
unjustified. Interrogatories 13 , 14 and 15 are overly broad and harassing in the detail
demanded. Interrogatory 14 asks for the captions, docket numbers, names of courts, and
descriptions of claims for class and non-class actions involving toxic exposures that counsel has
handled. There are no time limits. This would potentially require plaintiffs' counsel to spend
vast resources reviewing all of their files to provide meaningless lists for the defense, resources
that are more properly advanced in pursuing the merits of this case. Class counsel should be
relieved of the expensive task of compiling irrelevant information demanded by the defense for
unknown purposes.
Moreover, plaintiffs submit the issue of counsels' adequacy is more properly one for
the Courts' determination. This issue is not the proper subject of detailed discovery
propounded on the class representatives. Discovery responses are signed under oath by the
named representatives, and counsel signs as to objections. It is simply not procedurally correct
nor reasonable for defendant's counsel to demand from the plaintiffs themselves the career
history of their lawyers.
Class counsel has informed defense counsel that they are aware of no case in which
they have been denied appointment as class counsel wherein any counsel were appointed.
Plaintiffs counsel is not of the view that this opens their files for discovery, however. The
discovery sought is improper and will only serve to waste resources and divert the issues.
g. The discovery contains contention-based requests which are per se improper
Much of the information sought is not basic, relevant information as the defendants will
undoubtedly maintain. In fact, some of the discovery are improper contention interrogatories
only answerable if at all at the close of merits discovery, after the parties have had the
opportunity to develop their cases. Contention interrogatories include questions that inquire
about positions, opinions, legal bases, or the application of law to fact. Demands to produce
'all documents that support your contention that .. . ' create the same issues despite how they
are couched. The rules incorporate the modern trend to increase efficiency and fairness by
providing that "such an interrogatory need not be answered until after designated discovery
has been completed or until a pretrial conference or other later time." SCRCP 33(d).
The rationale for this rule is simple and applicable herein. The plaintiffs cannot be
required to prove their case on the day it is filed, or in this instance prior to the discovery
period. Courts examining the issue have noted:
There is a substantial reason to believe that the early knee-jerk filing of sets of
contention interrogatories that systematically track all the allegations in an
opposing party's pleading is a serious form of discovery abuse. Such
comprehensive sets of contention interrogatories can be almost mindlessly
generated, can be used to impose great burdens on opponents, and can generate
a great deal of friction between parties and counsel. Moreover, at least in cases
where defendants presumably have access to most of the evidence about their
own behavior, it is not at all clear that forcing plaintiffs to answer these kinds of
questions, early in the pretrial period, is sufficient to justify the burden that
responding can entail.
In Re Convergent Technologies Security Litigation, 108 F.R.D. 328, 337-38 (D. Cal.
1985). Essentially, the discovery propounded fits the above description by asking plaintiffs to
come forward, as if ready for trial, on liability and damages . Counsel's mental impressions as
to what documents in their possession prove also is pure work product. This demand for such
information is simply impracticable and unjustifiable and should not be allowed. For example,
Interrogatory 25 demands in part that the plaintiffs "(d)escribe in specific detail the particular
manner in which GSC was allegedly negligent by failure to utilize controls, or by other acts or
omissions of GSC that have caused damage . . . including the dates of such acts or omissions .
. . and identif(ing) all documents reflecting, relating to, and/or concerning this response."
See, attachment A, interrogatory. 25. Not only is this information within the purview of the
defendants, it is improper and premature to make a request such as this. Similarly, requests
for production that demand production of all documents concerning "each and every alleged
18
contaminant or constituent" that have damaged plaintiffs (attachment A, RFP 22 ); all
documents concerning "(y)our contention that GSC was allegedly negligent . . . " (attachment
A, RFP 23); all documents regarding damages (attachment A, RFP 28); and all documents
concerning "injury or injuries" sustained (attachment A, RFP 27), are all improper for the
reasons stated above. The request that plaintiffs tum over all documents "that support your
contention that a class should be certified " (attachment A, RFP 15) is not only so over broad
as to require plaintiffs counsel to open their libraries and files to the defendant, it is improper
at the outset of this case.
Request for Production 25 is not really a request for production at all, it is an
interrogatory: "Describe in detail the particular manner in which GSC was aUegedly negligent
... " In addition to being a redundant and repetitive, it constitutes an unduly burdensome,
improper contention interrogatory irrespective of how the defendant has labeled it. If the
defendant want the plaintiffs to delineate every act which they maintain is actionable under
negligence, the defendant will have to give plaintiffs access to their files and corporate
employees first. As the defendant presumably understands , the appropriate time to turn over
all of the proof on such a claim is typically when exhibits are exchanged, not when the
complaint is filed. The only feasible rationale for this type of discovery demand is to inflict
undue burden, expense and oppression upon the plaintiffs.
IV. Conclusion
From the foregoing, it is submitted the discovery demanded in these three class actions
is improper. Perhaps there was no intentional effort to harass class counselor the named
representatives; however, the demands as made are clearly unreasonable and vexatious. The
plaintiffs respectfully request that the Court grant their motion for protective order for the good
cause shown herein. Therefore, the Court is requested to declare no further response to such
discovery is necessary and that the defendant shall not demand from plaintiffs or absent class
members discovery not related to common issues, class merits issues or class certification
issues until further order of the Court. The plaintiffs would also submit that the court should
require counsel for all parties to confer, to develop a discovery plan that makes sense and is
proper, and submit same to court. Alternatively, if the parties cannot agree, plaintiff submit a
discovery conference should be held to develop issues that will be relevant to the court's ruling
certification.
Respectfully submitted,
~ ~ ~ p P
1 awardBeIl
C. Carter Elliott, 1f.
Bell & Moore, PA
232 King Street
P.O. Box 2590
(843) 546-2408
October ~ , 1998
Georgetown, South Carolina

CERTIFICATE OF SERVICE
I hereby certify that I have this _ day of October, 1998, served a copy of the
foregoing Plaintiffs' pleading upon counsel of record, by placing same, postage prepaid,
in the United States Mail, addressed to:
October _ , 1998
Kevin A. Dunlap, Esquire
Parker, Poe, Adams & Bernstein, L.L.P.
101 West Saint John Street, Suite 203
Spartanburg, SC 29306
Jack M. Scoville, Jr., Esquire
Law Offices of Jack M. Scoville
P.O. Box 1250
Georgetown, SC 29442
Attorneys for Defendant
ST TE OF SOUTH CAROLINA
CO Y OF GEORGETOWN
Guy . Hutchins, Jr., T. Goudy Miller,
\\ at- H_ Withers, James King,
Dr. Eri Heiden, Dr. Pickens Moyd and
Char C. Elliot, Sr.,
Plaintiffs,
Geo Steel Corporation,
Defendant.
)
)
)
)
C.A. NO. 98-CP-22-4S0
PLAINTIFF'S
EXHIBIT
) GEORGETOVVNSTEEL
) C()RPORA TION'S RESPONSES TO THE
) PLAINTIFFS' FIRST SET OF REQUESTS
) FOR PRODUCTION
)
)
)
)
------------------------)
The defendant, Georgetown Steel Corporation ("GSC"), pursuant to Rules 26 and
34 of outh Carolina Rules of Civil Procedure, responds to the plaintiffs' first set of requests
to prod: ce as follows:
GENERAL OBJECTIONS
G C 0 ~ e c t s to the plaintiffs' first set of requests to produce to the extent they seek
disco ery of information or materials protected by the attorney-client privilege or materiats
prepared in anticipation of litigation or which constitute work product or mental impressions of
counseL GSC further objects to the requests to produce to the extent they are beyond the scope
of permissible discovery pursuant to the South Carolina Rules of Civil Procedure. GSC further
objects to the plaintiffs' arbitrary lO-year time frame within which the plaintiffs seek discovery.
In the spirit of cooperation, GSC will respond to the plaintiffs' initial discovery requests for
documents dated 10 years preceding the date the plaintiffs' discovery in the above-captioned
PPABClIl /161188 . 1
la . \i as served until the date the Burgess, et af. v. Georgetown Steel Corporation, No. 98-
~ (Court of Common Pleas, Georgetown County) lawsuit was filed but reserves the
o ~ e c t to such an overly broad and unduly burdensome time period in future discovery
requ . GSC further objects to the plaintiffs' requests to produce to the extent that the requests
seek documents or information that are public records. GSC cannot be expected to make an
exhausti. 'e search of all its files for documents or infonnation that are public records and
accessible 0 the plaintiffs. GSC will make some public records available but will not make a
detennina . on that all public records in its files will be produced in that they are public records
and accessible to the plaintiffs. In addition, the plaintiffs defme the term "facility" as
"defendan s plant located at 420 South Hazard Street, Georgetown, South Carolina 29440-
4725 . G C believes that the plaintiffs intended to define the term "facility" to include GSC's
steel-making facility located at 1219 Front Street in Georgetown rather than GSC' s
administration building at 420 South Hazard Street, and GSC will respond accordingly. Subject
to and without waiving the foregoing objections, GSC responds to the plaintiffs' first set of
. requests to produce as follows:
RESPONSES
REOUEST NO.1: Please provide copies of all complaints of any nature known to GSC made
by private citizens or businesses relating to the subject matter of air and/or water pollution and/or
property damage.
RESPONSE: GSC objects to request number 1 on the grounds that it is overly broad, unduly
burdensome, vague, and ambiguous. GSC specifically objects to the terms "complaints" and "air
and/or water pollution and/or property damage" as vague and ambiguous. GSC further objects
PP,a.a0I1/361388 . 1
2
on e grounds that it is overly broad and not reasonably calculated to lead to the discovery of
rele an admissible evidence to the extent that it seeks any information other than information
concerning GSC's air emissions. GSC further objects to the plaintiffs' arbitrary 1 O-year time
period. Subject to and without waiving the foregoing objections, GSC will produce documents
concerning air emissions at a time, date, and place mutually agreeable to counsel for the parties.
REO T NO.2: Please provide copies of all complaints of any nature known to GSC made
by any federal, state and/or local govenunental agency relating to the subject matter of air and/or
water pollution and/or property damage.
RESPO E: GSC objects to request number 2 on the grounds that it is overly broad, unduly
burdensome, vague, and ambiguous. GSC specifically objects to the terms "complaints" and "air
on the grounds that it is overly broad and not reasonably calculated to lead to the discovery of
relevant, admissible evidence to the extent that it seeks any information other than information
concerning GSC's air emissions. GSC further objects to the plaintiffs' arbitrary IO-year time
period. GSC further objects on the grounds that it seeks documents that are public records.
Subject to and without waiving the foregoing objections, GSC directs the plaintiffs to agency
files as documents concerning air emissions in those files are public records and to documents
concerning air emissions GSC will produce at a time, date, and place mutually agreeable to
counsel for the parties.
REOUEST NO.3: Please provide copies of all complaints of any nature known to GSC made
by any non-profit, charitable or public interest organization relating to the subject matter of air
and/or water pollution and/or property damage.
PPAB'CHl (l61388 . 1
3
burdensome, vague, and ambiguous. GSC specifically obj ects to the terms "complaints" and "air
andlor water pollution andlor property damage" as vague and ambiguous. GSC further objects
concerning GSC's air emissions. GSC further objects to the plaintiffs ' arbitrary] O-year time
SUbject to and without waiving the foregoing objections, GSC directs the plaintiffs to agency
REOUEST NO.4: Please provide copies of all reports and documents caused to be provided by
GSC to any federal, state andlor local governmental agency in response to any complaint filed by
private citizens or businesses against GSC relating to the matter of air andlor water pollution
and/or property damage.
burdensome, vague, and ambiguous. GSC specifically objects to the terms :'complaints" and "air
and/or water pollution andlor property damage" as vague and ambiguous. GSC further objects
concerning GSC's air emissions. GSC further objects to the plaintiffs' arbitrary 1 O-year time
PPAIIOIl / Huae . 1
4
Su - to and without waiving the foregoing objections, GSC directs the plaintiffs to agency
file documents concerning air emissions in those files are public records and to documents
REQUEST NO.5: Please provide copies of all reports and documentation provided by GSC to
any federal state and/or local governmental agency in response to any complaint made by any
federal state and/or local governmental agency against GSC relating to the matter of air and/or
wa er pollution and/or property damage.
burdensome, vague, and ambiguous. GSC specifically objects to the tenns "complaint" and "air
REOUEST NO.6: Please provide copies of all reports and documentation caused to be
provided by GSC to any federal , state and/or local governmental agency in response to any
fl'N) - CII1/J61 J08 . 1 5
complaint filed by any non-profit, charitable or public interest organization against GSC relating
to the atter of air and/or water pollution and/or property damage.
RESPO SE: GSC objects to request number 6 on the groW1ds that it is oyerly broad, unduly
burdensome, vague, and ambiguous. GSC specifically objects to the terms "complaint" and "air
rele an I admissible evidence to the extent that it seeks any information other than information
period GSC further objects on the grounds that it seeks documents that are public records.
Subjec 0 and without waiving the foregoing objections, GSC directs the plaintiffs to agency
files as documents concerning air emissions in those fIles are public records and to documents
counse for the parties.
REOUEST NO.7: Please provide copies of all letters, notices, and documentation of any
comm cations, including but not limited to, phone calls received by GSC from any private
citizens businesses, non-profit, charitable or public interest organizations relating to the matter
of air an or water pollution and/or property damage.
RESPO E: GSC objects to request number 7 on the groW1ds that it is overly broad, unduly
burdensome, vague, and ambiguous. GSC specifically objects to the terms "air and/or water
.. - *
pollution and/or property damage" as vague and ambiguous. GSC further objects on the groW1ds
that it is overly broad and not reasonably calculated to lead to the discovery of relevant,
admissible evidence to the extent that it seeks any information other than information concerning
PPAB-CH1 /l61118 . 1
6
GSC s air emissions. GSC further objects to the plaintiffs' arbitrary 1 O-year time period. GSC
furtheJ objects on the grounds that it seeks information subject to attorney-client privilege,
infonnation that contains work product, and information that is in anticipation of litigation. GSC
further objects on the grounds that it seeks documents that are public records. Subject to and
without waiving the foregoing objections, GSC directs the plaintiffs to agency files as documents
concerning air emissions in those files are public records and to documents concerning air
emissions GSC will produce at a time, date, and place mutually agreeable to counsel for the
parties.
REQUEST NO.8: Please provide copies of all letters, notices, inquiries and memoranda
recei ed by GSC from any federal, state and/or local governmental agency relating to the matter
of air and/or water pollution andlor property damage.
burdensome, vague, and ambiguous. GSC specifically objects to the terms "air andlor water
pollution andlor property damage" as vague and ambiguous. GSC further objects on the grounds
GSC's air emissions. GSC further objects to the plaintiffs' arbitrary 10-year time period. GSC
parties.
REOUEST NO.9: Please provide copies of all letters, notices, inquiries and
recei ' ed by GSC from any non-profit, charitable or public interest organizations relating to the
matter of air and/or water pollution and/or property damage.
BESPO SE: GSC objects to request number 9 on the grounds that it is overly broad, unduly
pollution and/or property damage" as vague and ambiguous. GSC further objects on the grounds
tha it is overly broad and not reasonably calculated to lead to the discovery of relevant,
adrnisSl e evi dence to the extent that it seeks any infonnation other than information concerning
GSC s air emissions. GSC further objects to the plaintiffs' arbitrary IO-year time period. GSC
further 0 'ects on the grounds that it seeks documents that are public records. Subject to and
without the foregoing objections, GSC directs the plaintiffs to agency files as documents
emiss' 0 ' GSC will produce at a time, date, and place mutually agreeable to counsel for the
parties.
REO '0. 10: Please provide copies of all letters, notices, memoranda and/or public
anTIoun forwarded by GSC to any private citizen relating to the matter of air andior water
perty damage or environmental affairs at GSC.
RESPO . E: GSC objects to request number 10 on the grounds that it is overly broad, unduly
burdenso e and ambiguous. GSC specifically objects to the terms "environmental
air and/or water pollution and/or property damage" as vague and ambiguous. GSC
further 0 o the grounds that it is overly broad and not reasonably calculated to lead to the
discovery of relevant, admissible evidence to the extent that it seeks any information other than
PPAB'CH1/l6UI ' . 1
8
..:
REO
Ple
ase provide copies of all letters, notices, inquiries and m e m ~ r a n d a
TNO.9;
recei 'ed by GSC from any non-profit, charitable or public interest organizations relating to the
matte of air and/or water pollution and/or property damage.
that it is 0 erly broad and not reasonably calculated to lead to the discovery of relevant,
GSC's air emissions. GSC further objects to the plaintiffs' arbitrary lO-year time period. GSC
parties.
REOUEST NO. 10: Please provide copies of all letters, notices, memoranda and/or public
announcements forwarded by GSC to any private citizen relating to the matter of air anelior water
pollution property damage or environmental affairs at GSC.
RESPO SE: GSC objects to request number lOon the grounds that it is overly broad, unduly
burdensome vague, and ambiguous. GSC specifically objects to the terms "environmental
affairs" and air and/or water pollution and/or property damage" as vague and ambiguous. GSC
further objects on the grounds that it is overly broad and not reasonably calculated to lead to the
Q
. ...,..,...." .
information concerning GSC' s air emissions. GSC further objects to the plaintiffs' arbitrary 10-
year time period. GSC further objects on the grounds that it seeks information subject to the
attome -client privilege, information that contains work product, and information that is in
anticipation of litigation. Subject to and without waiving the foregoing objections, GSC
responds that it will produce documents concerning air emissions at a time, date, and place
mutuall agreeable to counsel for the parties.
REQUEST NO. 11: Please provide copies of all letters, notices, memoranda, and/or public
announcements forwarded by GSC to any federal, state andlor local governmental agency
relating to the matter of air andlor water pollution andlor property damage.
RESPO . T E: GSC objects to request number lIon the grounds that it is overly broad, unduly
burdensome ague, and ambiguous. GSC specifically objects to the terms "air and/or water
that it is 0 edy broad and not reasonably calculated to lead to the discovery of relevant,
GSC's air emissions. GSC further objects to the plaintiffs' arbitrary I O-year time period. GSC
further objects on the grounds that it seeks documents that are public records. Subject to 'and
parties.
PP.lllOIl /3 61388 . 1
9
Please provide copies of all letters, notices, memoranda and/o: public
anno
forwarded by GSC to any non-profit charitable or public interest organizations
reI
to any matter of air and/or water pollution and/or property damage.
GSC objects to request number 12 on the grounds that it is overly broad, unduly
bun! me, vague, and ambiguous. GSC specifically objects to the terms "air and/or water
poll 'on and/or property damage" as vague and ambiguous. GSC further objects on the grounds
that i . 0 erly broad and not reasonably calculated to lead to the discovery of relevant,
adm. . Ie evidence to the extent that it seeks any information other than information concerning
GSC air emissions. GSC further objects to the plaintiffs' arbitrary lO-year time period. GSC
furthe 0 ' ects on the grounds that it seeks documents that are public records. Subject to and
without 'aiving the foregoing objections, GSC directs the plaintiffs to agency files as documents
concemin air emissions in those files are public records and to docwnents concerning air
parties.
REQUEST 0.13: Please provide copies of all memoranda, e-mails, letters, notes, meeting
agendas and/or meeting minutes of GSC that GSC distributed to any of its employees or
contractors relating to the matter of air and/or water pollution and/or property damage.
RESPO ,E: GSC objects to request nwnber 13 on the grounds that it is overly broad, unduly
G
GSC
furthe
r obiects to the plaintiffs' arbitrary 10-year time p ~ r i o d . GSC
. s air emissions. J
. h ds that it seeks information subject to the attorney-client privilege,
objects on t e groun
-"t
info
-on that contains work product, and information that is in anticipation of litigation.
and without waiving the foregoing objections, GSC responds that it will produce
doc concerning air emissions at a time, date, and place mutually agreeable to counsel for
the
REOL"EST NO. 14: Please provide copies of all manuals video tapes, seminar literature,
training manuals, handbooks, rule books, etc. used in GSC's nonnal cours.e of
b re ating to air andlor water pollution andlor property damage.
RESPO: 8 = GSC objects to request number 14 on the grounds that it is overly broad, unduly
burde e ague, and ambiguous. GSC specifically objects to the tenns "air and/or water
pou .
or property damage" as vague and ambiguous. GSC further objects on the grounds
broad and not reasonably calculated to lead to the discovery of relevant,
- ence to the extent that it seeks any information other than information concerning
GSC s air - ions. GSC further objects to the plaintiffs' arbitrary 1 O-year time period. GSC
further 0 ; on the grounds that it seeks information subject to the attorney-client privilege,
info contains work product, and information that is in anticipation of litigation.
Subject 0 without waiving the foregoing obj ections, GSC responds that it will produce
docume :ts concerning air emissions at a time, date, and place mutually agreeable to counsel for
the parties.
PPAB-CU/l 61388 . 1
11
Please provide copies of all documentation, inter- and
mC" ....... e-mails, notes, logs, manuals, meetings and reports relating to pollution, emissions,
nmeotal quality control at GSC.
b ague, and ambiguous. GSC specifically objects to the terms "pollution, emissions,
air . onmental quality control" as vague and ambiguous. GSC further objects on the
it is overly broad and not reasonably calculated to lead to the discovery of relevant,
a e 'dence to the extent that it seeks any information other than information concerning
G Cs air e ssions. GSC further objects to the plaintiffs' arbitrary la-year time period. GSC
furthe 0 . ec 00 the grounds that it seeks information subject to the attorney-client privilege,
info ario that contains work product, and information that is in anticipation of litigation.
Subjec 0 and without waiving the foregoing objections, GSC responds that it will produce
docume concerning air emissions at a time, date, and place mutually agreeable to counsel for
the parties.
REQUEST Q. 16: Please provide copies of all documentation relating to sudden accidental
releases of emissions at GSC.
RESPO SE: GSC objects to request number 16 on the grounds that it is overly broad, unduly
burdensome vague, and ambiguous. GSC specifically objects to the terms "sudden" ,
"accidental, and "releases" as vague and ambiguous. GSC further objects on the grounds that it
is overly broad and not reasonably calculated to lead to the discovery of relevant, admissible
evidence to the extent that it seeks any information concerning emissions other than GSC's air
emissions. GSC further objects to the plaintiffs' arbitrary IOyear time period. GSC further
12
ob' . on the grounds that it seeks infonnation subject to the attorney-client privilege,
info ' on that contains work product, and infonnation that is in anticipation of litigation,
.Subj 0 and without waiving the foregoing objections, GSC responds that it will produce
documents concerning air emissions at a time, date, and place mutually agreeable to counsel for
the parties.
REO T NO. 17: Please provide copies of all documentation forwarded to any private
citizen or business by GSC relating to sudden accidental releases of emissions of GSc.
RESPO E: GSC directs the plaintiffs to GSC's response to request number 16, including
GSC s objections to request number 16.
REQUEST NO. 18: Please provide copies of all documents forwarded to any federal, state
andlor local governmental agency by GSC relating to sudden accidental releases of emissions of
GSC,
burdensome vague, and ambiguous. GSC specifically objects to the tenns "sudden",
"accidental and "releases" as vague and ambiguous. GSC further objects on the grounds that it
is overly broad and not reasonably calculated to lead to the discovery of relevant, admissible
evidence to the extent that it seeks any infonnation concerning emissions other than GSC's air
emissions. GSC further objects to the plaintiffs' arbitrary IO-year time period. GSC further
objects on the grounds that it seeks documents that are public records. Subject to and without
waiving the foregoing objections, GSC directs the plaintiffs to agency files as documents
--_-:--=-----
. d lace mutually agreeable to counsel for the
-ons GSC will produce at a tIme, date, an P
REO TNO.19:
P
lease provide all documents forwarded to any non-profit, charitable or
. _ . t' by GSC relating to sudden accidental releases of emissions of GSC.
public ill. erest orgaruza lOns
RE$PO TSE: GSC objects to request number 19 on the grounds that it is overly broad, unduly
burde me, vague, and ambiguous. GSC specifically objects to the terms "sudden",
acci ental' , and "releases" as vague and ambiguous. GSC further objects on the grounds that it
road and not reasonably calculated to lead to the discovery of relevant, admissible
evide ce 0 the extent that it seeks any information concerning emissions other than GSC's air
emissio . GSC further objects to the plaintiffs' arbitrary 10-year time period. GSC further
objects 0 the grounds that it seeks documents that are public records. Subject to and without
wai g e foregoing objections, GSC directs the plaintiffs to agency files as documents
conce g air emissions in those files are public records and to documents concerning air
parties.
REQUEST NO. 20: Please provide copies of all documents received by GSC from any federal ,
state an or local governmental agency relating to warnings, fines, penalties andlor notices
imposed upon GSC relating to air and/or water quality, emissions, pollution andlor property
damage.
RESPQ SE: GSC objects to request number 20 on the grounds that it is overly broad, unduly
burdensome, vague, and ambiguous. GSC specifically objects to the terms "notices" and "air
and/or water quality, emissions, pollution and/or property damage" as vague and ambiguous.
PPAB-CIl /3613" . 1
14
GSC further objects on the grounds that it is overly broad and not reasonably calculated to lead
to the discovery of relevant, admissible evidence to the extent that it seeks any information other
than infonnation concerning GSC's air quality or air emissions. GSe further objects to the
plaintiffs arbitrary 10-year time period. GSC further objects on the grounds that it seeks
documents that are public records. Subject to and without waiving the foregoing objections,
GSC directs the plaintiffs to agency files as documents concerning air emissions in those files are
public records and to documents concerning air emissions GSe will produce at a time, date, and
place mutually agreeable to counsel for the parties.
. Please provide copies of all documents forwarded by GSC to any federal,
state an 10 local governmental agency in response to any warnings, fmes, penalties and/or
notices to G e relating to the matter of air and/or water pollution and/or property damage.
RESPO SE: GSe directs the plaintiffs to GSe's response to request number 20, including
GSC s o ections to request number 20.
REOUEST . ' 0.22: Please provide copies of any drafts, notes, and/or fmal drafts of press
releases g erated by GSe or on GSC's behalf relating to the matter of air and/or water quality,
emissio mion and/or property damage.
RESPO . E: GSe objects to request number 22 on the grounds that it is overly broad, unduly
burdensome ague, and ambiguous. GSe specifically objects to the terms "air and/or water
quality emissions, pollution and/or property damage" as vague and ambiguous. GSC further
objects on the grounds that it is overly broad and not reasonably calculated to lead to the
information concerning GSC's air quality or air emissions. GSe further oojects to the plaintiffs'
PPAB 0I1/3611U. l
15
a.l 1 O-year time period. GSC further objects on the grounds that it seeks documents which
-co tai.n information subject to the attorney-client privilege, infonnation which contains work
p
and infonuation that is in anticipation of litigation. Subject to and without waiving the
foregoing objections, GSC responds that it will produce final press releases, released for
publication by GSC, at a time, date, and place mutually agreeable to counsel for the parties.
REO T NO. 23: Please provide copies of all newspaper articles, periodicals, public
announcements and press releases released for publication by GSC or on GSC's behalf relating to
the rna er of air and/or water quality, emissions, pollution and/or property damage.
RESPO, E: GSC objects to request number 23 on the grounds that it is overly broad, unduly
burdensome, vague, and ambiguous. GSC specifically objects to the tenus "air and/or water
quality, emissions, pollution and/or property damage" as vague and ambiguous. GSC further
objects on the grounds that it is overly broad and not reasonably calculated to lead to the
discovery of relevant, admissible evidence to the extent that it seeks any information other than ,
information concerning GSC's air quality or air emissions. GSC further objects to the plaintiffs'
arbitrary 1 O-year time period. GSC further objects on the grounds that it seeks documents that
are public records. Subject to and without waiving the foregoing objections, GSC directs the
plaintiffs to local newspapers and periodicals as newspaper and periodical articles are public
documents. GSC further responds that it will produce press releases and public announcements
released to the public at a time, date, and place mutually agreeable to counsel for the parties.
REOUEST NO. 24:' Please provide copies of all interviews and/or announcements or speeches
of GSC relating to the matter of air andlor water quality, emissions, pollution andlor property
damage.
PPAlI - OU/ 361388 , l
16
bur ensome, vague, and ambiguous. GSC specifically objects to the terms "interviews" and "air
an or ater quality, emissions, pollution andlor property damage" as vague and ambiguous . .
than information concerning GS0: ' s air quality or air emissions. GSC further objects to the
plaintiffs arbitrary lO-year time period. GSC further objects on the grounds that it seeks
documents that are public records. GSC further objects on the grounds that it seeks documents
which contain information subject to the attorney-client privilege, information which contains
work product, and information that is in anticipation of litigation. Subject to and without
waiving the foregoing objections, GSC responds that it will produce documents concerning
GSC's air emissions at a time, place and date mutually agreeable to counsel for the parties.
REQUEST . Q. 25: Please provide copies of all documents, inter--and intra- office memoranda,
e-mails notes, logs, manuals, meetings and reports relating to clean-up of GSC's by-products
andlor GSCs emissions both inside and outside GSC) facility.
RESPQ. SE: GSC objects to request number 25 on the grounds that it is overly broad, unduly
burdensome vague, and ambiguous. GSC specifically objects to the terms "clean-up" and "by-
products as vague and ambiguous. GSC further objects on the grounds that it is overly broad
and not reasonably calculated to lead to the discovery of relevant, admissible evidence to the
extent that it seeks any information concerning information other than GSC's air emissions.
GSC further objects to the plaintiffs' arbitrary lO-year time period. Subject to and without
waiving the foregoing objections, GSC responds that it does not understand what the plaintiffs
, d t dlor GSC's emissions both inside and outside GSC's
mean by "clean-up of GSC s by-pro uc s an -
fa ili GSC further responds that it will produce documents concerning GSC's air emissions
a a
e,. date, and place mutually agreeable to counsel for the parties.
REQUEST NO. 26: Please provide copies of any and all documents mentioned in Plaintiffs'
First e of Interrogatories to Defendant Georgetown Steel Corporation.
RESrO 'SE: GSC objects to request number 26 on the grounds that it is overly broad, unduly
burdensome, vague, and ambiguous. GSC further objects to the plaintiffs' arbitrary lO-year time
period. GSC further objects on the grounds that it seeks documents that are public records. GSC
furthe 0 ects on the grounds that it seeks documents which contain information subject to the
attome '-client privilege, infonnation which contains work product, and information that is in
anticipa 'on oflitigation. GSC further objects on the grounds that it is overly broad and not
reasonabl calculated to lead to the discovery of relevant, admissible evidence to the extent that
it seeks an information other than information concerning GSC's air emissions. Subject (0 and
withou ~ v i n g the foregoing objections, GSC directs the plaintiffs to agency files as documents
emissions G C will produce at a time, date, and place mutually convenient to counsel for the
parties.
REQUEST Q.27: Please provide copies of any and all documents, including but not limited
to reports and/or memoranda, whether generated internally, by an engineering, consulting and/or
environmental firm or received from any governmental agency regarding particulate emissions,
toxic emissions or any other emissions from GSC.
1 Q
PONSE: GSC objects to request number 27 on the grounds that it is overly broad, unduly
burdensome, vague, and ambiguous. GSC further objects on the grounds that it is overly broad
extent that it seeks any information concerning emissions other than GSC's air emissions. GSC
further obj ects to the plaintiffs' arbitrary lO-year time period. GSC further objects on the
grounds that it seeks documents which contain information subj ect to the attorney-client
privilege, infonnation which contains work product, and infonnation that is in anticipation of
litigation. GSC further objects on the grounds that it seeks documents that are public records.
concerning air emissions GSC will produce at a time and date mutually convenient to counsel for
the parties.
REOUEST O. 28: Please provide copies of any and all data compiled by GSC or any
engineering finn hired or employed by GSC, or from any governmental agency regarding the
monitoring of emissions from GSc.
RESPO 'SE: GSC directs the plaintiffs to GSC's response to request number 27, includIng
GSC s objections to r e q u e ~ t number 27.
REQUEST O. 29: Please provide copies of any and all data regarding GSC's removal of
siding from certain buildings located at GSC. Included in this data, please provide a copy of all
outlines of these situations as well as the reports which may indicate the reason for the removal
of siding and/or whether or not this removal corresponded with a change in the level of emissions
PPAB'0I1/361388 .1
19
nom GSC. Additionally, please produce any documentation of any observations in relation to
emissions in relation to the removal of siding.
RESPONSE: GSC objects to request number 29 on the g ~ o u n d s that it is overly broad, unduly
and no reasonably calculated to lead to the discovery of relevant, admissible evidence to the
exten that it seeks any information concerning emissions other than GSC's air emissions. GSC
further objects to the plaintiffs' arbitrary IO-year time period. GSC further objects on the
gro d.s that it seeks docwnents which contain information subject to the attorney-client
privilege information which contains work product, and information that is in anticipation of
litigario Subj ect to and without waiving the foregoing objections, GSC responds that it will
prod ce documents concerning GSC's air emissions at a time, date, and place mutually agreeable
to counse for the parties.
REOUEST O. 30: Please provide copies of any and all documents regarding notifications to
DHEC or any other governmental agency involving fugitive dust and/or particulate emissions.
RESPO. $: GSC objects to request number 30 on the grounds that it is overly broad, unduly
bur ensome ague, and ambiguous. GSC specifically objects to the term "notifications" and
"fugiti 'e dust and/or particulate emissions" as vague and ambiguous. GSC further objects on the
grounds that it is overly broad and not reasonably calculated to lead to the discovery of relevant, .
GSCs air emissions. GSC further objects to the plaintiffs' arbitrary l'O-year time period. GSC
further objects on the grounds that it seeks documents that are public records. GSC further
objects on the grounds that request number 30 seeks documents which contain information
subject to the attorney-client privilege, information which contains work product, and
information that is in anticipation oflitigation. Subject to and without waiving the foregoing
objections, GSC directs the plaintiffs to agency files as documents concerning air emissions in
those files are public records and to documents concerning air emissions GSC will produce at a
time, date, and place mutually agreeable to counsel for the parties.
REOUEST NO. 31: Please provide copies of any and all documents regarding complaints,
inquiries and/or concerns from employees and/or other persons regarding dust and/or particulate
emissions from GSC.
burdensome, vague, and ambiguous. GSC specifically objects to the terms "complaints" and
"dust and/or particulate emissions from GSC" as vague and ambiguous. GSC further objects on
the grounds that it is overly broad and not reasonably calculated to lead to the discovery of
concerning GSC's air emissions. GSC further objects on the grounds that request number 31
seeks information subject to the attorney-client privilege, information that contains work product,
and information in anticipation of litigation. GSC further objects to the plaintiffs' arbitniry 10-
year time period. Subject to and without waiving the foregoing objections, GSC directs the
plaintiffs s response to request number 1, including GSC's objections to request number 1.
REOUEST NO. 32: Please provide copies of any and all documents containing a response from
GSC to complainants, inquiries or concerns mentioned in Request Number 31.
burdensome, vague, and ambiguous. GSC specifically objects to the term "complainants" as
PPABOIl/361388 .1
21
ague and ambiguous. GSC further objects on the grounds that it is overly broad and not
reasonably calculated to lead to the discovery of relevant, admissible evidence to the extent that
it seeks any infonnation other than infonnation concerning GSC' s air emissions. GSC further
objects on the grounds that request number 32 seeks information subject to the attorney-client
privpege, information that contains work product, and information in anticipation of litigation.
GSC further objects to the plaintiffs' arbitrary 10-year time period. Subject to and without
waiving the foregoing objections, GSC directs the plaintiffs to GSC's response to request
number 10, including GSC's objections to request number 10.
REOUEST NO. 33: Please provide copies of any and all documents drafted, released,
published and/or circulated by any public relations' employee andlor public relations' company
employed or otherwise retained by GSC that relate to environmental issues, improvements,
projects, developments andlor emissions at GSC. This request is to include but not be limited to
flyers, brochures, posters, billboard designs, pamphlets, radio andlor television announcements,
and any other solicitational andlor promotional document.
burdensome, vague, and ambiguous. GSC specifically objects to the terms "environmental
issues, improvements, projects, developments andlor emissions" as vague and ambiguous. GSC
further objects on the grounds that it is overly broad and not reasonably calculated to lead to the
information concerning GSC's air emissions. GSC further objects to the plaintiffs' arbitrary 10-
year time period. GSC further objects on the grounds that request number 33 seeks documents
which contain information subject to the attorney-client privilege, information which contains
PPAB-OU!3H J 88 . 1
22
work product, and information that is in anticipation of litigation. Subject to and without
waiving the foregoing objections, GSC will produce documents released to the public at a time,
date, and place mutually convenient to counsel for the parties.
REOUEST NO. 34: Please provide a mailing list and/or broadcasting area of all persons to
which each document in Request Number 33 was or may have been circulated.
extent that it seeks any information other than information concerning GSC's air emissions.
GSC further objects to the plaintiffs' arbitrary lO-year time period. Subject to and without
waiving the foregoing objections, GSC responds that it will produce a standard mailing list at a
time, date, and place mutually convenient to counsel for the parties. GSC also directs the
plaintiffs to GSC's response to request number 33, including GSC's objections to request
number 33.
REQUEST NO. 35: Please produce copies of all GSC's financial records, including but not
limited to net worth statements, annual reports, and/or profit and loss statements.
RESPONSE: GSC objects to request number 35 on the grounds that it is overly broad and
unduly burdensome. GSC further objects on the grounds that it is overly broad and not
it seeks any information other than GSC's 1998 annual report. GSC further objects to the
plaintiffs' arbitrary 1 O-year time period. Subject to and without waiving the foregoing
objections, GSC responds that it will produce its 1998 annual report.
PPAB-Clll!JU388 . 1 23
REOUEST NO. 36: Please provide copies of any and all documents regarding water
quality or pollution, including but not limited to complaints from any person relating to
emissions, smell, contamination and/or particulate matter generated from GSC's processes.
burdensome, vague, and ambiguous. - GSC specifically objects to the terms "emissions, smell,
contamination and/or particulate matter", "complaints", and "pollution" as vague and ambiguous.
than information concerning GSC's air quality or air emissions. GSC further objects to the
plaintiffs' arbitrary 1 O-year time period. GSC further objects on the grounds that it seeks
documents which contain information subject to the attorney-client privilege, information which
contains work product, and infonnation that is in anticipation of litigation. GSC further objects
on the grounds that it seeks documents that are public records. Subject to and without waiving
the foregoing objections, GSC directs the plaintiffs to agency files as documents concerning air
emissions in those files are public records and to documents concerning air emissions GSC will
produce at a time, date, and place mutually agreeable to counsel for the parties.
REOUEST NO. 37: Please provide copies of any GSC permits and/or permit applications and
other documents which relate to permits and/or permit applications to and from any
governmental agency.
PPAlI-CH1/3Ul88 . 1
24
extent that it seeks any information concerning permits or permit applications other than GSC's
air permits or air permit applications. GSC further objects to the plaintiffs' arbitrary lO-year
time period. GSC further objects on the grounds that it seeks information subject to the attorney-
client privilege information that contains work product, and information that is in anticipation of
litigation. GSC further objects on the grounds that it seeks documents that are public records.
REOUEST NO. 38: Please provide copies of any documents which pertain to citations,
violations, and/or [mes of any kind imposed upon GSC from any governmental agency relating
to air and/or water quality, emissions, pollution and/or property damage.
quality, emissions, pollution and/or property damage" as vague and ambiguous. GSC further
objects on the grounds that it is overly broad and not reasonably calculated to lead to the'
information concerning GSC's air quality or air emissions. GSC further objects to the plaintiffs'
arbitrary IO-year time period. GSC further objects on the grounds that it seeks information
subject to the attorney-client privilege information that contains work product, and information
that is in anticipation of litigation. GSC further objects on the grounds that it seeks documents
that are public records. Subject to and without waiving the foregoing objections, GSC directs the
PPAB-ClIl./lG1388 . 1. 25
. - air emissions in those files are public records
plaintiffs to agency files as documents concerrung
_ _ missions GSC will produce at a time, date, and place mutually
and to documents concerrung au e .
agreeable to counsel for the parties.
Please
pro
vide copies of documents relating to responses and/or fines paid
REQUEST NQ. 39:
S
e
tal agency for any of the violations, citations or fines listed in Request
by G C to any governm n
Number 38.
RESPONSE: GSC directs the plaintiffs to GSC's response to request number 38, including
GSC's objections to request number 38.
REQUEST NO. 40: Please provide copies of any and all emissions data compiled by or on
behalf of GSC at controlled sites_
burdensome, vague, and ambiguous. GSC specifically objects to the term "controlled sites" as
vague and ambiguous_ GSC further objects on the grounds that it is overly broad and not
it seeks any information other than information concerning GSC's air emissions. GSC further
objects to the plaintiffs' arbitrary 1 O-year time period. Subject to and without waiving the
foregoing objections, GSC responds that it does not understand request number 40. GSC further
responds that it will produce documents concerning air emissions at a time, place, and date
mutually agreeable to counsel for the parties_
REOUEST NQ. 41: Please provide copies of any and all documents which pertain to GSC's
plans for the future regarding particulate emissions, air pollution andlor air quality measures.
PPAll-CI!l/361J88.1 26
b 41 on the grounds that it is overly broad, unduly
RESPONSE: GSC objects to request num er
GS
C specifically objects to the tenns "plans for the future
burdensome, vague, and ambiguous.
regarding particulate emissions, air pollution andlor air quality measures" as vague and
ambiguous. GSC further objects on the grounds that it is overly broad and not reasonably
calculated to lead to the discovery of relevant, admissible evidence to the extent that it seeks any
information other than information concerning GSC' s air emissions. GSC further objects to the
plaintiffs arbitrary lO-year time period. GSC further objects on the grounds that it seeks
documents which contain infon,:nation subject to the attorney-client privilege, information which
contains work product, and information that is in anticipation of litigation. Subject to and
without waiving the foregoing objections, GSC responds that it will produce documents
concerning air emissions at a time, date, .and place mutually agreeable to counsel for the parties.
REOUEST NO. 42: Please provide copies of any documents between GSC and any other
industry or business in Georgetown County which in any manner relates to pollution or alleged
pollution of personal or real property ill Georgetown County.
burdensome ague, and ambiguous. GSC specifically objects to the terms "pollution or alleged
pollution of personal or real property" as vague and ambiguous. GSC further objects on the
grounds that it is overly broad and not reasonably calculated to lead to the discovery of relevant,
GSC's air' emissions. GSC further objects to the plaintiffs' arbitrary IO-year time period. GSC
further objects on the grounds that it seeks information subject to the attorney-client privilege,
information that contains work product, and information that is in anticipation of litigation.
PPAB-0I1/361388 . 1 27
Subject to and without waiving the foregoing objections, GSC will produce documents
concerning air emissions at a time, date, and place mutually agreeable to counsel for the parties.
GSC also refers the plaintiffs to GSC's answer in which GSC has denied liability.
REOUEST NO. 43: Please produce copies of all documents relative to any air modeling studies
performed by or on behalf of GSC.
burdensome, vague, and ambiguous. GSC further objects to the plaintiffs' arbitrary IO-year time
period. GSC further objects on the grounds that it seeks documents that are public records. GSC
further objects on the grounds that it seeks information subject to the attorney-client privilege,
information that contains work product, and information that is in anticipation of litigation.
fIles as documents concerning air emissions in those files are public records and to documents
REQUEST O. 44: Please produce copies of all environmental policies, directives and
procedures dictated or influenced by Georgetown Steel Industries.
RESPON : GSC directs the plaintiffs to GSC's response to interrogatory number 42 of the
plaintiffs first set of interrogatories to GSC, including GSC' s objections to interrogatory number
42.
REOUEST NO. 45: Please produce copies of all permits for air and/or water emissions and/or
solid waste disposal under which GSC has been operating.
PPABCU/JG1388 . 1 28
RESPONSE: GSC objects to request number 45 on the grounds that it is overly b r ~ a d , unduly
a n ~ not reasonably calculated to lead to the discovery of relevant, admissible evidence to the
extent that it seeks any infonnation other than information concerning GSC's air emissions.
GSC further objects to the plaintiffs' arbitrary 1 O-year time period. GSC further objects on the
grounds that it seeks documents that are public records. Subject to and without waiving the
foregoing objections, GSC directs the plaintiffs to agency files as documents concerning air
emissions in those files are public records and to GSC's current air permit, a copy of which will
be made available.
REOUEST NO. 46: Please produce the organizational chart for GSC's plant and executive
offices for the past five years.
RESPO SE: GSC objects to request number 46 on the grounds that it is overly broad and
unduly burdensome. GSC specifically objects to request number 46 as overly broad and unduly
burdensome as it asks for organizational charts for the entire GSC plant. GSC further objects to
the plaintiffs' arbitrary 5-year time period. Subject to and without waiving the foregoing
objections, GSC will produce organizational charts for GSC's executive offices at a time; date,
and place mutually agreeable to counsel for the parties.
REOUEST NO. 47: Please produce the organizational chart for Georgetown Steel Industries'
executive offices for the past five years.
RESPONSE: GSC objects to request number 47 on the grounds that it is overly broad and
unduly burdensome. GSC further objects to request number 47 to the extent it seeks information
concerning Georgetown Steel Industries as Georgetown Steel Industries is not a party to this
?Q
lawsuit. GSC further objects to the plaintiffs' arbitrary 5-year time period. Subject to ~ d
without waiving the foregoing objections, GSC responds that it is unaware of an entity called
Georgetown Steel Industries.
REOUEST NO. 48: Please provide copies of any and all studies of damages to neighborhoods
from GSC emissions.
RESPONSE: GSC objects to request number 48 on the grounds that it is vague and ambiguous.
GSC specifically objects to the terms "damages to neighborhoods from GSC emissions" as vague
and ambiguous. GSC further objects on the grounds that it is overly broad and not reasonably
calculated to lead to the discovery of relevant, admissible evidence to the extent that it seeks any
information concerning emissions other than GSC' s air emissions. GSC further objects to the
plaintiffs' arbitrary 10-year time period. GSC further objects on the grounds that request number
48 seeks information subject to the attorney-client privilege, information that contains work
product, and information in anticipation of litigation. GSC further objects to the extent that
request number 48 implies that GSC' s emissions cause alleged damages to neighborhoods.
Subject to and without waiving the foregoing objections, GSC responds that has no studies of the
affect of its air emissions on areas outside GSC. GSC also responds that it believes DHE"C has
investigated and conducted an analysis and GSC refers the plaintiffs to DHEC' s records. GSC
also refers the plaintiffs to GSC's answer in which GSC has denied liability.
REOUEST NO. 49: Please provide copies of any and all reports of any samplings performed in
surrounding neighborhoods of GSC.
RESPONSE: GSC directs the plaintiffs to GSC's response to request number 48, including
GSC' s objections to request number 48.
PPAB-C11l/361388 . 1
30
REOUEST NO. 50: Please provide copies of all documents relating to the painting of the
exterior of any resjdential dwellings or businesses, outdoor equipment or vehicles due to the
rust-colored staining which is the subject of this litigation.
RESPONSE: GSC objects to request number 50 on the grounds that it is vague, and ambiguous.
GSC specifically objects to the terms "rust-colored staining which is the subject of this
litigation" as vague and ambiguous. GSC further objects to the plaintiffs' arbitrary 10-year time
period. Subject to and without waiving the foregoing objections, GSC responds that it has no
such documents. GSC also refers the plaintiffs to GSC's answer in which GSC has denied
liability.
PPM-CHI/JUJU . 1
31
This 2nd day of August, 1999.
OFCO SEL:
Steven D. Weber
Attorneys for Defendant,
Georgetown Steel Corporation
PARKER, POE, ADAMS & BERNSTEIN L.L.P.
101 West S1. John Street, Suite 203
Spartanburg South Carolina 29306
(864) 591 - 030
OF CO _ - L:
LAW OFFICES OF JACK SCOVILLE
Georgeto outh Carolina 29442
(843) 546-1] 30
PPAB- 0I1/J6UU . 1
Jack . Scoville
Atto ey for Defendant,
G rgetown Steel Corporation
32
This is to certify that on this date I served copies of the foregoing Georgetown Steel
Corporation's Responses to Plaintiffs' First Set of Requests to Produce on the individual(s)
listed below by depositing a copy thereof in the United States mail, first class, postage prepaid,
and addressed as follows:
1. Edward Bell, III, Esq.
C. Carter Elliott, Jr., Esq.
BELL & MOORE, P.A.
232 King Street
P.O. Box 2590
Georgetown, South Carolina 29442-2590
Timothy E. Eble, Esq.
Ness, Motley, Loadholt, Richardson & Poole
151 Meeting Street
Charleston, South Carolina 29306
S t e v ~
PPAB-CIIl/361388 . 1
STATE OF SOUTH CAROLINA
COUNTY OF GEORGETOWN
Guy S. Hutchins, Jr., T. G o ~ d y Miller,
Walter H. Withers, James King,
Dr. Eric Heiden, Dr. Pickens Moyd and
Charles C. Elliot, Sr.,
Plaintiffs,
v.
Georgetown Steel Corporation,
Defendant.
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c.A. NO. 98-CP-22-4S0
DEFENDANT GEORGETOWN STEEL
CORPORATION'S 'RESPONSES
TO PLAINTIFFS' FIRST
SET OF INTERROGATORIES
The defendant, Georgetown Steel Corporation ("GSC"), pursuant to Rules 26 and 33 of
the South Carolina Rules of Civil Procedure, responds to the plaintiffs' first set of interrogatories
as follows:
GENERAL OBJECTIONS
GSC objects to the plaintiffs' first set of interrogatories to the extent they seek discovery
of information or materials protected by the attorney-client privilege or materials prepared in
anticipation of litigation or which constitute work product or mental impressions of counsel.
GSC further objects to the interrogatories to the extent they are beyond the scope of permissible
discovery pursuant to the South Carolina Rules of Civil Procedure. GSC further objects to the
plaintiffs' arbitrary 10-year time frame within which the plaintiffs seek discovery. In the spirit of
cooperation, GSC will respond to the plaintiffs' initial discovery requests for documents dated 10
PPAB-0I1/3613S6 . 1
years preceding the date the plaintiffs' discovery in the above-captioned lawsuit was served until
the date the Burgess, et af. v. Georgetown Steel Corporation, No. 98-CP-385 (Court of Common
Pleas, Georgetown County) lawsuit was filed but reserves the right to object to such an overly
broad and unduly burdensome time period in future discovery requests. GSC further objects to
the plaintiffs' interrogatories to the extent that the interrogatories seek documents or infomlation
that are public records. GSC cannot be expected to make an exhaustive search of all its files for
documents or information that ru:e public records and accessible to the plaintiffs. GSCwill make
some public records available but will not make a detennination that all public records in its files
will be produced in that they are public records and accessible to the plaintiffs. In addition, the
plaintiffs define the term "facility" as "defendant's plant located at 420 South Hazard Street,
Georgetown, South Carolina 29440-4725". GSC believes that the plaintiffs intended to define
the term "facility" to include GSC's steel-making facility located at 1219 Front Street in
Georgetown rather than GSC's administration building at 420 South Hazard Street, and GSC will
respond accordingly. Subject to and without waiving the foregoing objections, GSC responds to
the plaintiffs' first set of interrogatories as follows:
RESPONSES
1. Give the names and addresses of persons known to GSC or GSC's counsel to be
witnesses concerning the facts of this case and indicate whether or not written or recorded
statements have been taken from the witnesses and indicate who has possession of such
statements.
RESPO SE: GSC responds that John Moschgat, Bill Dobinski, Robert Bullard, and Don Daily
may be witnesses concerning the facts of this case at this time. No statements have been taken
PPABCH1/361356 .1
2
from these witnesses. GSC also directs the plaintiffs to the affidavits that will be produced in
response to the plaintiffs' requests to produce.
2. Set forth a list of photographs, plats, sketches or other prepared documents in
GSC's possession relating to the claim or defense in this case.
RESPONSE: GSC objects on the grounds that interrogatory number 2 seeks information
subject to the attorney-client privilege, information that contains work product, and information
in anticipation of litigation. Subject to and without waiving the foregoing objections, GSC
directs the plaintiffs to documents that GSC will produce in r ~ s p o n s e to the plaintiffs' requests to
produce.
3. Set forth the names and addresses of all insurance companies which have liability
insurance coverage relating to any claims set forth in the plaintiffs' complaint and set forth the
number or numbers of the policies involved and the amount or amounts of liability coverage
provided in each policy.
RESPO SE: GSC responds that its insurance carriers have not yet informed GSC as to whether
they concede that GSC has liability insurance coverage relating to any claims set forth in the
plaintiffs complaint at this time.
4.
List the names and addresses of any expert witnesses whom GSC proposes to use
as a witness at the trial of this case.
RESPONSE: GSC responds that it has not determined whom, if anyone, to call as an expert
witness in this case.
5. For each person known to GSC or GSC's counsel to be a witness concerning the
facts of this case, set forth either a summary sufficient to infonn the plaintiffs of the important
PPAlI - CH1/JUJ56 . 1
3

facts known to or observed by such witness, or provide a copy of any written or recorded
statements taken from such witnesses.
RESPONSE: GSC responds as follows:
John Moschgat -- John Moschgat is the Chief EngineerfManager of Environmental
Control at GSC. Mr. Moschgat has knowledge concerning GSC's operations.
Bill Dobinski -- Bill Dobinski preceded Mr. Moschgat as the Chief EngineerfManager of
Environmental Control at GSC. Mr. Dobinski has-knowledge concerning GSC's operations.
Robert Bullard __ Robert Bullard is the Vice President and General Manager of GSC. Mr.
Bullard has knowledge concerning GSC's operations.
Don Daily -- Don Daily preceded Mr. Bullard at GSC. Mr. Daily has knowledge
concerning GSC's operations.
GSC also directs the plaintiffs to the affidavits that GSC will produce in response to the
plaintiffs requests to produce.
6. Identify every person and every business entity presently or previously employed
by or under contract to GSC, who is or was engaged, part-time or full-time, in air pollution
and/or solid waste control activities regarding the facility.
RESPONSE: GSC objects to interrogatory number 6 on the grounds that it is overly broad,
unduly burdensome, vague, and ambiguous. GSC specifically objects to the terms "air pollution
and/or solid waste control activities" as vague and ambiguous. GSC further objects on the
grounds that it is overly broad and not reasonably calculated to lead to the discovery of relevant,
admissible evidence to the extent that it seeks information concerning GSC's solid waste control
activities. GSC further objects to the plaintiffs' arbitrary IO-year time period. Subject to and
PPAB-C111/361356.1
4
without waiving the foregoing objections, GSC responds that numerous employees .:rre or were
involved with air emissions control including Robert Bullard, Don Daily, John Moschgat, Bill
Dobinski, Terry Bone, Buddy Rogers, Mark Columbus, Ken Brown, Greg Walker, Dave Jeltes,
Ed Bakanic, Dave Smith, Aubrey Rogers, Gene Elliott, and Steve Rishel. GSC does not have
"under contract" a business entity engaged to control environmental activities.
7. Identify every person who is or was involved in supervising the persons listed in
response to Interrogatory 6.
RESPO E: GSC objects to interrogatory number 7 on the grounds that it is overly broad,
unduly burdensome, vague, and ambiguous. GSC specifically objects to the tenn "supervising"
as vague and ambiguous. GSC further objects to the plaintiffs' arbitrary IO-year time period.
to the discovery of relevant, admissible evidence to the extent that it seeks infonnation
concerning GSC's solid waste control activities. Subject to and without waiving the foregoing
objections, GSC responds that Robert Bullard, Don Daily, John Moschgat, and Bill Dobinski are
or were involved in supervising air emission control activities.
8.
Identify every person and every business entity presently or previously employed
by or under contract to GSC, who is or was engaged part-time or full t. . .. .
, - Ime, m emIsslOns testmg
regarding the facility.
unduly burdensome, vague, and ambiguous. GSC further objects on the grounds that it is overly
broad and is not reasonably calculated to lead to the discovery of relevant ad . bl .d
' mISSI e eVI ence to
the extent that it seeks information concerning emissions other than GSC' .. GSC
s aIr emISSlOns.
PPAB-OIl/3613S& . 1
5
. 'ff' b'trary lO-year time period. Subject to and without waiving the
further objects to the plamtl sarI
. h l ' fffs to GSC' s response to interrogatory number 6,
foregoing objections, GSC dIrects t e P am 1
. ber 6 GSC also responds that R TP
including GSC's objections to mterrogatory num .
. .' Inc Concord Environmental, Inc., TSA,
Environmental Associates, Inc., Tngon Engmeenng, .,
. I d PSI Inc. are or were involved with emission testing.
Inc., ATEC AssocIates, Inc., RMT, nc. , an ,
Identify every person who is involved in preparing, editing, filing, reviewing, or
9.
providing information which is included in documents relating to: any permit(s) for activities
1
... d t sting and include any individual
affecting the environment, air pollution contro actiV1ties, an e ,
who supervises any of these activities at GSe.
RESPO
: GSC objects to interrogatory number 9 on the grounds that it is overly broad and
unduly burdensome. GSC further objects to the terms "affecting the environment, air pollution
control activities, and testing" and "supervising" as vague and ambiguous. GSe further objects
relevant, admissible evidence to the extent it seeks information concerning environmental
permits other than air permits. GSC further objects to the plaintiffs' arbitrary IO-year time
period. Subject to and without waiving the foregoing objections, GSC directs the plaintiffs to
GSC's responses to interrogatory numbers 7 and 8, including asc's objections to interrogatory
numbers 7 and 8.
10. For each person or business entity listed in response to Interrogatories 10 and 11,
identify the employee or agent of GSC involved in such contact.
RESPONSE: GSC responds that no persons or business entities are asked for in response to
interrogatory numbers 10 and 11.
PPAB0I1/3613S6 . 1
6
11. Has GSC always been in full compliance with all of the provisions ofthe
facility's permit(s) and/or with ali federal, state, and local emission standards, limitations,
regulations, conditions, requirements, prohibitions, and orders issued pursuant to the Clean Air
Act?
RESPONSE: GSC objects to interrogatory number 11 as overly broad, unduly burdensome,
vague, and ambiguous. GSC further objects to the plaintiffs' arbitrary 10-year time period.
Subject to and without waiving the foregoing objections, GSC responds that as with any large
industrial company, GSC has been involved in instances from time to time where DHEC has
determined that GSC has temporarily not been in complete adherence with its air permits. OSC
directs the plaintiffs to the documents that GSC will produce in response to the plaintiffs'
requests to produce. GSC also directs the plaintiffs to DHEC's files which are public records.
12. If the answer to the preceding Interrogatory is "yes," state every fact that supports
your response, identify each person having such knowledge of any facts and identify every
document and/or tangible item of evidence that supports your response.
unduly burdensome, vague, and ambiguous. GSC further objects tt? the arbit .
, .'
year time period. GSC further objects on the grounds that interrogatory number 12 seeks
information subject to the attorney-client privilege, information that contains work product, and
information in anticipation of litigation. Subject to and without waiving the foregoing
objections, 'GSC directs the plaintiffs to GSC's response to interrogatory number 11, including
GSC's objections to interrogatory number 11.
PPAB-CH1/3613 5 6.1
7
13. If your answer to Interrogatory 13 is "no," identify all permit provisions, emission
standards, solid waste standards, limitations, regulations, conditions, requirements, prohibitions
and/or orders of which GSC is presently in violation, has been in violation or was given notice of
a violation.
vague, and ambiguous. GSC further objects on the grounds that it is overly broad and not
reasonably calculated to lead to the discovery of relevant, admissible evidence to the extent-that
it seeks information concerning GSC's solid waste activities and GSC emissions other than air
emissions. GSC further objects to the plaintiffs' arbitrary lO-year time period. Subject to and
without waiving the foregoing objections, GSC responds that interrogatory 13 does not ask for a
"yes" or' no" answer. GSC also directs the plaintiffs to GSC's response to interrogatory number
11, including GSC's objections to interrogatory number 11.
14. Please identify the dates of occurrence of each specific violation in Interrogatory
13 as well as the agency which issued the order or notice of violation.
RESPONSE: GSC directs the plaintiffs to GSC's response to interrogatory number 13,
including GSC's objections to interrogatory number 13.
15. Please identify any reports regarding GSC's emissions prepared for or by any
environmental agencies, including but not limited to the United States Environmental Protection
Agency and the South Carolina Department of Health and Environmental Control, the name of
the individual(s) preparing the reports, hislher relationship to you, including the location of all
files and records containing such reports.
PPAB- Clil/JU1S6 . 1 8
broad and is not reasonably calculated to lead to relevant, admissible evidence to the extent it
seeks information concerning emissions other than GSC's air emissions. GSC further objects to
the plaintiffs' arbitrary IO-year time period. Subject to and without waiving the foregoing
objections, GSC responds that any reports referred to in interrogatory number 15 are public
documents from DHEC and other governmental agencies that may be obtained from said
agencies. GSC also directs the plaintiffs to documents that GSC will produce in response to the
plaintiffs' requests to produce.
16. Prior to the date the complaint was filed in this action, what discussions or
meetings were held and what decisions were made regarding environmental management at
GSC, including but not limited to the control of emission levels?
RESPONSE: GSC objects to interrogatory number 16 on the ground that it is overly broad,
broad and is not reasonably calculated to lead to relevant, admissible evidence to the extent it
seeks information concerning emissions other than GSC's air emissions. GSC further objects to
the plaintiffs' arbitrary IO-year time period. Subject to and without waiving the foregoing
objections, GSC responds that it routinely has meetings concerning environmental issues. These
meetings involve discussions of environmental matters where decisions concerning those matters
are made. GSC cannot be expected to recount every "environmental management" meeting that
has occurred at GSC. GSC also refers the plaintiffs to the documents that it will produce in
response to the plaintiffs' requests to produce.
PPAB-OH/1611S6 . 1
9
17. Please identify all persons who were involved in discussions of meetings as
requested in Interrogatory 16 as well as the dates of meetings.
RESPONSE: GSC directs the plaintiffs to GSC's response to interrogatory number 16,
including GSC's objections to interrogatory number 16.
18. Has GSC ever investigated the potential for andlor extent of environmental impact
from GSC upon the surrounding community? If so, describe the nature of the investigation,
persons involved and the location of any files or records relating to such investigation.
RESPONSE: GSC objects to interrogatory number 18 on the grounds that it is vague and
ambiguous. GSC specifically objects on the grounds that the terms "environmental impact" are
vague and ambiguous. GSC further objects to the plaintiffs' arbitrary lO-year time period.
SUbject to and without waiving the foregoing objections, GSC responds that evaluations of its air
emissions have been conducted as a part of the DHEC permitting process. GSC also refers the
plaintiffs to the documents it will produce in response to the plaintiffs' request to produce.
19. What has GSC done to investigate, renovate, repair, modernize andlor improve
pollution control measures with respect to emissions at GSC since it began operation? Indicate
the results of such measures and the location of any files or records relating to any such .
investigation, renovation, repair, modernization or improvement as well as results of same.
unduly burdensome, vague, and ambiguous. GSC specifically objects to the term "pollution" as
vague and ambiguous. GSC further objects on the grounds that it is overly broad and is not
it seeks information other than GSC's air emissions. GSC further objects on the grounds that it
PPAII-CH1/l613SG . 1 10
seeks information concerning air emission control measures beyond the plaintiffs' defined
relevant time period. GSe further objects to the plaintiffs' arbitrary 1 O-year time period.
Subject to and without waiving the foregoing objections, Gse directs the plaintiffs to the
documents that GSe will produce in response to the plaintiffs' requests to produce.
20. List all industry, industrial hygiene, envirorunental andlor political lobbying
groups andlor trade associations to which GSe belongs or belonged from the date of
incorporation to present.
RESPO SE: GSC objects to interrogatory number 20 on the grounds that it is overly broad,
undul y burdensome, and not reasonably calculated to lead to admissible evidence to the extent
that it seeks information outside the plaintiffs' defined relevant time period. GSC further objects
to the plaintiffs' arbitrary lO-year time period. Subject to and without waiving the foregoing
objections, GSC responds that it belongs to the Steel Manufacturers Association, the American
Iron and Steel Institute, the South Carolina Chamber of Commerce, and the International Iron
and Steel Institute.
21. Identify all cleanups or other corrective actions undertaken at. GSe as a result of
any environmental violations with respect to the Clean Air Act.
vague, and ambiguous. GSC specifically objects to the terms "cleanups" and "corrective
actions" as vague and ambiguous. GSe further objects to the plaintiffs' arbitrary la-year time
period. Subject to and without waiving the foregoing objections, GSC responds that it has not
been required to undertake any "cleanups" or "corrective actions" under the Clean Air Act.
PPAB-ClIl/361356 . 1
11
22. Identify all complaints received by GSC relating to emissions GSC produces, and
for each such complaint, state (a) your response to each complaint; (b) the actions performed by
GSC in response to the complaint; (c) whether a resolution was ever reached; (d) whether any
compensation andlor restitution was paid to the complainant by GSC.
unduly burdensome, vague, and ambiguous. GSC specifically objects to the terms "complaint"
and "resolution" as vague and ambiguous. GSC further objects On the grounds that it is overly
broad and is not reasonably calculated to lead to the of relevant, admissible evidence to
the extent that it seeks information concerning emissions other than GSC's air emissions. GSC
further objects to the plaintiffs' arbitrary 1 O-year time period. Subject to and without waiving the
foregoing objections, GSC responds that such "complaints" are generally made by telephone and
directed to GSC's Human Resources Director, Mr. George White. Mr. White generally responds
verbally. GSC directs the plaintiffs to the documents that GSC will produce in response to the
plaintiffs' requests to produce. GSC also directs the plaintiffs to the papers in this lawsuit and
the papers in the lawsuits of Burgess. et aZ., v. Georgetown Steel Corporation, and Cunningham,
et al., v. Georgetown Steel Corporation.
23. Identify GSC's internal procedures for responding to complaints from residents,
environmental group, public interest group, and/or any governmental agency.
RESPONSE: GSC objects to interrogatory number 23 as overly broad, vague, and ambiguous.
GSC specifically objects to the terms "complaint" as vague and ambiguous. GSC further objects
on the grounds that it is overly broad and is not reasonably calculated to lead to the discovery of
relevant, admissible evidence to the extent that it seeks information other than information
PPAB- Cl!l /J613S6 . 1
12
concerning GSC's air emissions. GSC further objects to the plaintiffs' arbitrary lO-year time
period. Subject to and without waiving the foregoing objections, GSC responds that
"complaints" it receives generally are directed to Mr. George White. From time to time, Mr.
John Moschgat or Mr. Robert Bullard may become involved in responding to complaints.
24. Identify all persons involved in responding to pollution complaints from
envirorunental groups, public groups or any governmental agency for GSC or on GSC's behalf.
RESPONSE: GSC objects to interrogatory number 24 as overly broad, vague, and ambiguous.
GSC specifically objects to the terms "pollution complaints" as vague and ambiguous. GSC
further objects on the grounds that it is overly broad and is not reasonably calculated to lead to
the discovery of relevant, admissible evidence to the extent that it seeks information other than
information concerning GSC's air emissions. GSC fiuther objects to the plaintiffs' arbitrary 10-
year time period. Subject to and without waiving the foregoing objections, GSC directs the
plaintiffs to GSC's response to interrogatory number 23, including GSC's objections to
interrogatory number 23.
25. State whether GSC has a record retention and/or record destruction policy. If so,
describe each such policy.
RESPONSE: GSC responds that it has no general, plant-wide record retention or destruction
policy. GSC is required to retain certain documents by law. GSC retains such documents in
accordance with state and federal law.
26. State whether any internal documents regarding GSC's operations are kept on
microfilm, microfiches, in an archives or on any type of electronic database .. If so, please
identify the nature and location of any such documents.
PPASCH1 / 1GllS6 . 1
13
RESPONSE: GSC responds that it has various documents on microfilm, microfiche, and
electronic databases. GSC will produce documents responsive to this interrogatory by
responding to the plaintiffs' request to produce.
27. Has GSC ever been cited or fined by a federal , state, city or county agency in
connection with emissions stemming from GSC's operations? If so, please explain.
RESPO SE: GSC objects to interrogatory number 27 on the grounds that it is overly broad,
broad and is not reasonably calculated lead to the discovery of relevant, admissible evidence to
the extent that it seeks information concerning emissions other than GSC's air emissions. GSC
further objects to the plaintiffs' arbitrary lO-year time period. Subject to and without waiving the
foregoing objections, GSC directs the plaintiffs to DHEC's records which are public documents.
GSC also directs the plaintiffs to the documents that GSC will produce in response to the
plaintiffs' requests to produce.
28. When did GSC first receive notice that its emissions might be a contributing
factor to the problems which are the subject of this litigation?
RESPONSE: GSC to interrogatory number 28 on the ground that it is vague and
ambiguous. GSC further objects to the plaintiffs' arbitrary IO-year time period. GSC
specifically objects to the phrases "receive notice", "contributing factor", and "problems which
are the subject of this litigation" as vague and ambiguous. As a result, GSC is unable to
ascertain the intent or meaning of the interrogatory. GSC also refers the plaintiffs to its answer
in which GSC has denied liability.
PPAB 0I1! J61J56 . 1
14
29. Has GSC taken any actions to alleviate the problems described in Interrogatory
30? If so, what actions have been taken and what are the results of such actions?
ambiguous. GSC does not understand what "problems" to which the plaintiffs refer in
interrogatory nwnber 30. GSC also refers the plaintiffs to its answer in which GSC has denied
liability.
30. Has GSC conducted any independent analyses of the rust-colored staining that is
the subject of this litigation? If so, please summarize the nature of the analysis, the persons
involved, the dates of such analysis and the results of any such analyses.
ambiguous. GSC specifically objects to the terms "rust-colored staining" as vague and
ambiguous. GSC further objects to the plaintiffs' arbitrary 10-year time period. GSC further
objects on the grounds that interrogatory number 30 seeks information subject to the attomey-
client privilege, information that contains work product, and information in anticipation of
litigation. Subject to and without waiving the foregoing objections, GSC directs the plaintiffs to
GSC's response to interrogatory number 29, including GSC's objections to interrogatory number
29. GSC believes that DHEC has investigated and conducted an analysis and GSC refers the
plaintiffs to DHEC's records. GSC also refers the plaintiffs to its answer in which GSC has
denied liability.
31. Has GSC or any environmental agency identified the chemical components of
GSC's emissions and/or solid waste? If so, please list these components and their concentrations
and include any changes over time.
PPAB- Cl!1 / J 61356.1 15
RESPONSE: GSC objects to interrogatory 31 on the grounds that it is overly broad and not
reasonably calculated to lead to the discovery of relevant, admissible evidence to the extent it
seeks information on solid waste or emissions other thcin GSC's air emissions. GSC further
objects to the plaintiffs' arbitrary IO-year time period. Subject to and without waiving the
foregoing objections, GSC directs the plaintiffs to the documents that GSC will produce in
response to the plaintiffs' requests to produce. GSC also directs the plaintiffs to DHEC's files
which are publicly available.
32. Please identify any persons and/or business entities which have been or are
presently employed, contracted or retained by GSC who aided in or were responsible for the
handling of environmental permit applications. Please indicate whether these persons or
entities were employed, contracted or retained by DHEC or the EPA prior to or after working for
GSc.
broad and not reasonably calculated to lead to the discovery of relevant, admissible evidence to
the extent that it seeks information concerning permit applications other than GSC's air permits.
GSC further objects to the plaintiffs' arbitrary IO-year time period. Subject to and without
waiving the foregoing objections, GSC directs the plaintiffs to GSC's response to interrogatory
number 9, including GSC's objections to interrogatory number 9. In addition, GSC responds
that it hired RTP Environmental Associates, Inc. and GSC does not know ifRTP has done any
work for DHEC.
PPAB-CII1/J61J56 . 1 16
33. Please identify all persons and/or business entities who have been engaged,
consulted or retained by GSC to study pollution, solid waste management and/or
emissions from GSc.
unduly burdensome, vague, and ambiguous. GSC specifically objects to the term "pollution" as
vague and ambiguous. GSC further objects on the grounds that it is overly broad and not
o it seeks information concerning GSC's solid waste management or emissions other than air
emissions. GSC further objects to the plaintiffs' arbitrary IO-year time period. Subject to and
without waiving the foregoing objections, GSC directs the plaintiffs to the list ofGSC's air
consultants set forth in GSC's response to interrogatory number 8.
34. Please describe the purpose, implementation, use and results of the foamy slag
practice utilized at GSC.
ambiguous. GSC further objects to the plaintiffs' arbitrary I O-year time period. Subject to and
without waiving the foregoing objections, GSC responds that the foamy slag process is a
O
procedure by which GSC injects carbon into the slag during the melting process for the purpose
of increasing the thickness of the slag cover. The primary purpose of the foamy slag process is
to increase the efficiency of the steelmaking process.
35. Please identify the persons and/or business entities employed or retained by GSC
who assist in advertising, promotions and/or public relations, including any public relations
andlor advertising specialist that conveys information to GSC's employees or to the public which
PPAB-on/361J56 01
17
in any manner pertains to alleged pollution, emissions and/or environmental issues and/or
concerns regarding GSC.
RESPONSE: GSC objects to interrogatory number 35 as overly broad and not reasonably
calculated to lead to the discovery of relevant, admissible evidence to the extent that it seeks
information concerning "alleged pollution, emission, and/or environmental issues and/or
concerns" other than GSC's air emissions. GSC further objects on the grounds that interrogatory
number 35 seeks information subject to the attorney-client privilege, information that contains
work product, and information in anticipation of litigation. GSC further objects to the plaintiffs'
arbitrary IO-year time period. Subject to and without waiving the foregoing objections, GSC
responds that a flrm called Mystique Communications has been retained to assist with
communications concerning this matter.
36. List all wastes and by-products from the steel manufacturing process at GSC.
unduly burdensome, vague, and ambiguous. GSC speciflcally objects to the terms "wastes" as
vague and ambiguous. GSC further objects to the plaintiffs' arbitrary 10-year time period.
Subject to and without waiving the foregoing objections, GSC refers the plaintiffs to DHEC's
flIes which are publicly available. GSC also refers the plaintiffs to the documents GSC will
produce in response to the plaintiffs' request to produce. GSC also responds that the steelmaking
process results in the generation of slag, furnace dust, and rolling mill scale.
PPAD-CH1/361356 . 1 18
37. State with particularity the manner in which all wastes and of the
steel manufacturing process at GSC are contained and/or disposed. If any significant changes
have been made in regards to GSC' s containment or disposal of by-products, please list the
reason for the change.
unduly burdensome, vague, and ambiguous. GSC specifically objects to the terms "wastes" as
vague and ambiguous. GSC further objects to the plaintiffs' arbitrary lO-year time period.
Subject to and without waiving the foregoing objections, GSC refers the plaintiffs to the
documents GSC will produce in response to the plaintiffs' requests to produce and to the
documents at DHEC. GSC also responds that the steelmaking process results in the generation
of slag, furnace dust, and rolling mill scale. The slag is sold to, and shipped off-site by,
International Mill Service, Inc. for recycling and beneficial use. Furnace dust is collected in
GSC's baghouse and shipped off-site to Horsehead Resources, Inc. for recycling and beneficial
use. Rolling mill scale is sold to cement manufacturers and other steel producers for recycling
and beneficial use.
38. Has GSC ever used chloride and/or chlorine in any of its processes? If so; please
describe the process and the levels of chloride and/or chlorine used.
RESPONSE: GSC objects to the plaintiffs' arbitrary 1 O-year time period. Subject to and
without waiving the foregoing objections, GSC responds that it is unaware of the use chloride or
chlorine in its steelmaking process.
39. Please list all persons who presently work for or are retained by GSC who were
previously employed or retained by DHEC or the EPA within the last five years.
PPAB-CH1/361J56.1
19
RESPONSE: GSC objects to the time period set forth in interrogatory number 39 as overly
broad and unduly burdensome. Subject to and without waiving the foregoing objections, GSC
refers the plaintiffs to GSC's response to interrogatory number 32, including GSC's objections to
interrogatory number 32. GSC further responds that to its knowledge, none of its present
employees have worked for DHEC or EPA.
40. Please identify any communications of any nature whatsoever between GSC and
any other business or industry in Georgetown County which relate, directly or indirectly, to any
issue of emissions or pollution of any nature.
it seeks any information concerning "emissions or pollution of any nature" other than GSC's air
emissions. GSC further objects on the grounds that the interrogatory is unduly burdensome,
vague, and ambiguous. GSC further objects to the plaintiffs' arbitrary 10-year time period.
Subject to and without waiving the foregoing objections, GSC directs the plaintiffs to the
documents concerning air emissions .that GSC will produce in response to the plaintiffs' requests
to produce.
41. Describe any air modeling studies performed by or on behalf of GSc.
RESPONSE: GSC objects to the plaintiffs' arbitrary IO-year time period. GSC further objects
on the grounds that interrogatory number 41 seeks information subject to the attorney-client
privilege, information that contains work product, and information in anticipation of litigation.
Subject to and without waiving the foregoing objections, GSC responds that it will provide
20
PPAII-CH1/J6H56 . 1
GSC's air permit applications which include air modeling studies. GSC also directs the plaintiffs
to DHEC's records which are publicly available.
42. .-- Please identify all environmental policies, directives and procedures emanating
from, d i c ~ ~ d , or influenced by Georgetown Steel Industries. State the manner in which these
policies, directives and procedures are dictated or influenced by Georgetown Steel Industries.
vague, and ambiguous. GSC further objects to the plaintiffs' arbitrary IO-year time period. GSC
further objects to interrogatory number 42 to the extent it seeks information concerning
Georgetown Steel Industries as Georgetown Steel Industries is not a party to this lawsuit.
Subject to and without waiving the foregoing objections, GSC responds that it is unaware of any
entity called Georgetown Steel Industries.
43. Identify all permits for emissions, air and/or water emissions and/or solid waste
disposal under ~ GSC has been operating.
reasonably calculated to lead the discovery of admissible, relevant evidence to the extent the
interrogatory seeks permits other than GSC's air permits. GSC further objects to the plaintiffs'
arbitrary IO-year time period. Subject to and without waiving the foregoing objections, GSC
responds that it will produce GSC's current air permit. GSC also directs the plaintiffs to
DHEC's records as those public documents contain GSC's air permits.
44. Has GSC conducted any studies of surrounding neighborhoods in order to assess
the amount of damage caused by its emissions? If so, please list studies and/or reports
conducted.
PPAB-CHl/J61356 .1 21
vague and ambiguous. GSC specifically objects to the terms "amount of damage caused by its
emissions" as vague and ambiguous. GSC further objects to the extent that interrogatory number
44 implies that GSC's emissions cause allege damages to surrounding neighborhoods. GSC
further objects on the groUnds that it is overly broad and not reasonably calculated to lead to the
discovery of admissible, relevant evidence to the extent that the interrogatory seeks information
concerning emissions other than GSC' s air emissions. GSC further objects on the ~ o u n d s that
interrogatory number 44 seeks information subject to the attorney-client privilege, information
that contains work product, and information in anticipation oflitigation. Subject to and without
waiving the foregoing objections, GSC responds that it believes DHEC has investigated and
conducted an analysis and GSC refers the plaintiffs to DHEC's records. GSC refers the plaintiffs
to its answer in which it has denied liability.
PPAB- CH1 /3613 S6 . 1
22
This 2nd day of August, 1999
OF COUNSEL:
Steven D. Weber
Attorneys for Defendant,
PARKER, POE, ADAMS & BERNSTEIN L.L.P.
101 West St. John Street, Suite 203
Spartanburg, South Carolina 29306
(864) 591-2030
OF COUNSEL:
LAW OFFICES OF JACK SCOVILLE
(843) 546-1130
. Scoville
ey for Defendant,
This is to certify that on this date I served copies of the foregoing Georgetown Steel
Corporation's Responses to Plaintiffs' First Set of Interrogatories on the individual(s) listed
below by depositing a copy thereof in the United States mail, first class, postage prepaid, and
addressed as follows:
J. Edward ~ e l l , III, Esq.
C. Carter Elliott, Jr., Esq.
BELL & MOORE, P.A.
232 King Street
P.O. Box 2590
Georgetown, South Carolina 29442-2590
Timothy E. Eble, Esq.
Ness, Motley, Loadholt, Richardson & Poole
151 Meeting Street
Charleston, South Carolina 29306
PPAB"' Oil/161JS6 . 1
-=:::::::::::----
John and Mamie Cunningham,
Marian Rowe, Leonard Roach,
Wilbur and Shirley Carter,
Marilyn Burkhardt,
Bruce Chandler, C.M. Bush,
PaL!I_1. Skoko ~ n d Betty -
Stafford,
Plaintiffs
vs.
Georgetown Steel Corporation,)
Defendant.
)
)
)
)
)
)
)
)
)
)
)
)
}
)
)
)
)
)
}
)
DOCKET NO.: 98-CP-22-414
PLAINTIFF'S ANSWERS TO
INTERROGATORIES AND REQUEST
FOR PRODUCTION TO DEFENDANT
The plaintiffs, pursuant to Rules 26,33, and 34 of the South Carolina Rules of Civil
Procedure, requests that the defendant answer the following interrogatories in writing and
under oath and respond to the following requests for production in accordance with Rules
26, 33, and 34 of the South Carolina Rules of Civil Procedure.
1. List the name, address, telephone number, and social security number of each
individual that has been identified as an actual plaintiff and provide the same
information as to every potential member of the alleged class in this action.
RESPONSE:
Counsel for the Plaintiff will be forwarding under separate cover a proposed
questionnaire which will answer all of the individual questions propounded in the
individual interrogatories for each of the named Plaintiffs. To the extent that any of
these interrogatories request individual information regarding absent class
members, an objection is hereby made in that the Defendants are not allowed to
request this information from the Plaintiffs at this stage of the proceedings.
2. Identify by name, address and telephone number of each individual or business
entity that You or Your counsel contacted, attempted to contact, or plan to contact
regarding their possible role as a member in the alleged class in this action, identify
all documentation concerning these communications, and describe in specific detail
all conversations between You and actual or potent ial plaintiffs in this matter by
stating the date of each conversation, identifying who was present, and describing
what each person .said.
RESPONSE:
The Plaintiffs object to providing any information concerning any
communications between the Plaintiffs and the Plaintiff's attorneys as these
communications are work product and protected by the attorney client privilege.
The Plaintiffs further object to this question as there seems to be no valid basis
and/or relevance for the question. However, the undersigned did not contact anyone
who had not first made an inquiry into this matter.
3.
List the name, address, and telephone number of each individual or business entity
You or Your counsel contacted who indicated they were not interested in becoming
I
d identity all documents concerning communications
a part of the alleged c ass an
with those individuals or entities.
RESPONSE:
See the response to Number 2.
4. Identify each motor vehicle within .5 of a mile from GSC that You contend is a part
of this case and has been damaged by stating the owner's name(s), address, and
tax value of the motor vehicle, and provide a photograph of each such motor
vehicle.
RESPONSE:
The Plaintiffs object to this Interrogatory as it is seeking information which is
overly broad and unduly burdensome. Additionally, the information sought is as
readily available to the Defendant as it is to the Plaintiffs. Additionally, any vehicle,
water craft or real property in the public sight can be photographed by the
Defendant. Additionally, the properties damaged are sufficiently identified by the
class definition within the Complaint. The Plaintiffs would further show that absent
class member identification such as requested has never been required at this stage
of the discovery process. It is apparent the Defendants are requesting information
in such a way to create an undue and unnecessary burden on the Plaintiffs.
5. Identify each motor vehicle within .5 of a mile to one mile from GSC that You
contend is a part of this case and has been damaged by stating the owner's
I of the motor vehicle, and provide a photograph of
name(s) , address, and tax va ue
each such motor vehicle.
RESPONSE:
6.
See response to Number 4.
-
Identify each motor vehicle from one mile to two miles from GSC that You contend
is a part of this case and has been damaged by stating the owner's name(s) ,
address, and tax value of the motor vehicle, and provide a photograph of each such
motor vehicle,
RESPONSE:
7. Identify each motor vehicle from two miles to three miles from GSC that You
name(s) , address, and tax value of the motor vehicle, and provide a photograph of
RESPONSE:
8. Identify each motor vehicle from three miles to four miles from GSC that You
name(s) , address, and tax value of the motor vehicle, and provide a photograph of
RESPONSE:
9. Identify each motor vehicle from four miles to five miles from GSC that You contend
is a part of this case and has been damaged by stating the owner's name(s),
address and tax v a ~ . l e of the motor vehicle, and provide a photograph of each such
motor vehicle.
RESPONSE:
10. State the total number of named plaintiffs and potential members of the alleged
class within each of the following areas: (i) .5 of a mile from GSC, (ii) from .5 of a
mile to 1 mile, (ii i) from 1 mile to 2 miles, (iv) from 2 miles to 3 miles, (v) from 3
miles to 4 miles, and (vi) from 4 miles to 5 miles.
RESPONSE:
The Plaintiffs object to this Interrogatory as it requests information which is
overly broad and unduly burdensome. The names and addresses of the Class
representatives have been provided in Answer to Interrogatory Number 1. However,
the Plaintiffs would object to providing any information as to absent class members.
This information is as readily available to the Defendant as it is to the Plaintiffs.
Plaintiffs would refer the Defendants to any number of demographic
companies, which upon payment of a fee, will be glad to provide this information.
Further, the Horry County and/or the Georgetown County Board of Realtors as well
,
f Commerce may also have this information
as Georgetown county Chamber 0
bl
d may be able to provide assistance. However,
which is available to the pu IC, an
th
South Carolina Rules of Civil Procedure, is willing
if the Defendant, pursuant to e
. ff 11 be glad to undertake and gather this information.
to pay these fees, the Plamtl WI
11.
Describe in detail air actions taken by You or Your counsel to identify potential class
members for this action.
RESPONSE:
The Plaintiffs object to this interrogatory on the grounds that it is asking for
information which is work product which is protected.
12. Describe in detail the proposed fee and expense arrangement between proposed
class and counsel and You.
RESPONSE:
The Plaintiffs object to this Interrogatory on the grounds that it is requesting
information which is clearly irrelevant. Additionally, as to the individual class
representatives and all absent class members, all expenses, subject to
reimbursement and all fees paid to class counsel, must be approved by the court,
after notices given to the class representatives and the absent class members.
AdditionaIly, as to the named class representatives and all absent class members,
all expenses subject to reimbursement and all attorneys fees paid to class counsel
must be approved by the court after notice is given to the individual class
as Georgetown County Chamber of Commerce may also have this information
which is available to the public, and may be able to provide assistance. However,
if the Defendant, pursuant to the South Carolina Rules of Civil Procedure, is willing
to pay these fees, the Plaintiff will be glad to undertake and gather this information.
11 . Describe in detail air acti ons tak8n by You or Your counsel to identify potenti al cl ass
members for this act ion.
RESPONSE:
The Plaintiffs object to this interrogatory on the grounds that it is asking for
information which is work product which is protected.
12. Describe in detail the proposed fee and expense arrangement between proposed
class and counsel and You.
RESPONSE:
The Plaintiffs object to this Interrogatory on the grounds that it is requesting
information which is clearly irrelevant. Additionally, as to the individual class
representatives and all absent class members, all expenses, subject to
reimbursement and all fees paid to class counsel, must be approved by the court,
after notices given to the class representatives and the absent class members.
Additionally, as to the named class representatives and all absent class members,
all e..xpenses subject to reimbursement and all attorneys fees paid to class couns el
must be approved by the court after notice is given to the individual class
representatives and the absent class members who are then provided an opportunity
to respond.
13. With respect to proposed class counsel , list by case name, case number, and court
in which the case was filed every class action with which proposed class counsel
(the actual lawyers in this case, not their firms) has appeared, the parties which
proposed class counsel represented, and the result of the class action.
RESPONSE:
The Plaintiffs would object to this Interrogatory on the grounds that
Interrogatories are directed towards parties not their attorneys.
However, pursuant to Rule 23 of South Carolina Rules of Civil Procedure, the
undersigned certifies and represents, that he qualifies under Rule 23 as an attorney
who is experienced in complex litigation and that Timothy E. Eble qualifies under
Rule 23 as experienced in class action litigation. The Defendant can not if good faith
question the experience of attorneys Bell and Eble and whether they qualify under
Rule 23 in Class Action Litigation, and are reminded of the guidelines set forth in
Rule 11 of the South Carolina Rules of Civil Procedure.
14. Provide the captions, docket numbers, and name of courts for all actions involving
class action claims for alleged environmental contamination in which proposed
class counsel (the actual lawyers in the case, not their firms) have served as
counselor co-counsel and describe the nature of the alleged contamination and
provide the same information as to non-class actions.
RESPONSE:
Please see answer to number 13. Counsel for Plaintiff would not have signed
their names to pleadings unless they were experienced and qualified as required by
the Rules.
15. Has proposed class counsel (the actual lawyers in the case, not their firms) ever
been denied a request for appointment as class counsel and, if so, identify the case
in which the appointment as class counsel was denied and identify all documents
relating to any denial of a request for appointment as class counsel.
RESPONSE:
None of the attorneys representing the Plaintiffs have ever been denied
appointment as class counsel.
16. Describe all meetings in any way concerning this matter organized by counsel for
plaintiffs and/or by You (lithe Meetings") by stating how many people attended, each
person's name, home and work addresses, home and work phone numbers, and
social security numbers, the location, time and length of the Meetings, the manner
in which the Meetings were publicized, promoted, advertised, or announced, the
contact of any such publication, promotion, advertisement, or announcement and
identify all documents used to publicize, promote, or advertize the Meetings.
RESPONSE:
Plaintiffs counsel has not organized any meeting of the type described in this
Interrogatory. Any meetings which have been held involved individuals inquiring as
to their legal rights and potential remedies, or those individuals who may have
attended for purposes of a legal briefing, and the meetings were held for the
purpose of providing legal advise, and as such, the information is privileged
and/or protected by the attorney client privilege and is considered to be work
product. Therefore the time, place and duration of any meetings between Plaintiffs
and Plaintiffs' counsel are likewise protected.
17. How many people were contacted by counsel for plaintiffs and/or by You and
informed about the Meetings and, for each person so contacted, provide the
person's name, home and work addresses, home and work phone numbers, and
social security number and ident ify any documents used in connection with such
contact, including but not limited to letters, correspondence, phone messages, and
phone lists.
RESPONSE:
Counsel has not organized any meetings of the type described herein. Any
meetings which have been held involved individuals inquiring as to their legal rights
and potential remedies and were held for the purpose of providing legal advise.
Additionally, Plaintiffs' counsel is not aware of any communication with anyone who
was not our client about holding any such meetings. Therefore, the request involves
the attorney client privilege and is objectionable.
18. Identify each person You may call as an expert witness regarding class certification
in this matter, and with respect to each such person specify and identify the subject
matter about which the expert is expected to testify, the substance of the facts and
about whicn the expert is expected to testify, the grounds for eacll opinion
about which the expert is expected to testify, all documents prepared by the expert
in connection with this matter that will be offered into evidence or relied upon in
testimony, all relied upon by the expert in connection with this matter,
the qualifications of the expert, all documents published by the expert, and all other
actions (by docket number, court, and names of counsel for plaintiff( s) and
defendant(s) in which the expert has given testimony, either in deposition or at
trial) .
RESPONSE:
The Plaintiffs have not determined and/or completed an entire list as to who
they will call as an expert to testify as to class certification issues. This
Interrogatory will be supplemented as these experts are identified.
19. Identify all persons having knowledge of facts supporting or otherwise concerning
Your allegation that a elass should be certified in this action, and, as to each such
person, describe in detail the facts known or observed by such person, state
whether any written or recorded statement was taken from such person relating in
any way to class certification, and state whether You will rely upon the person as
a witness concerning the class certification issue.
RESPONSE:
The Plaintiffs would object to this Interrogatory on the grounds that it is
requesting information which is overly bread and unduly burdensome. Additionally,
given the Defendant's definition of "person" this question is so overly broad is to
be unanswerable. However, in the spirit of cooperation, any "person" identified in
the documents pertaining to the subject case, potentially have knowledge of facts
concerning class certification. Further any person within that geographical area,
identified in the class definition of the Plaintiff's Complaint, potentially have
knowledge of facts concerning class certification. Further, any person and any
governmental agency which has inspected the Georgetown Steel premises
potentially has knowledge, concerning class certification issues. However, the
named Plaintiffs are certainly knowledgeable about the issues involved in the area
of damage from the "mill dust". At the present time, and at this stage in the
proceeding, the Plaintiffs have not named their witnesses on the issue of class
certification. Once these individuals have been named and identified this
,
interrogatory will be supplemented.
20. For purposes of determining how and whether You will be able to bear the
expenses of this litigation, identify and specify (iO the current income of each named
plaintiff, (ii) the value of each asset of each named plaintiff, and (iii) the amount or
value of each liability of each named plaintiff, and identify all documents concerning
Your response.
RESPONSE:
For purposes of determining how the cost of litigation will be handled, the
information sought is in as much as Plaintiffs' counsel will be advancing
all cost.
21 . If any source for the payment of the expenses of this action is available other than
the income; assets and liabilities You were asked to identify in response to the
preceding interrogatory, identify such source and explain the amount, nature, and
conditions on funding available from each such source, and identify all documents
concerning each such source.
RESPONSE:
22. For each named plaintiff, specify the nature, if any, and street address where motor
vehicles are kept that are owned or held by such individual in the areas You have
set forth in Your complaint in defending the proposed class, the date(s) on which
such individual acquired such interest(s) and the amount of any purchase price, the
date(s) on which any such individual divested or sold such interest(s) and the
amount of any sales price, whether any measurable quantities of alleged
contamination allegedly originating from GSC in the air have been detected above
the motor vehicles owned by such Individual (and, if so, identify the appraisal) and
all uses of the motor vehicles held by such individual.
Response:
23.
Please see response to number 1.
For each alleged class member who is not a named plaintiff, specify the nature and
street address of the interest, if any, in real property owned or held by such
individual in the areas You have set forth in Your complaint in defining the class,
the date(s) on which such individual acquired such interest (s) and the amount of
any purchased price, the dates(s) on which any such individual sold such interest(s)
and the amount of any sales price, whether any measurable quantities of alleged
contamination allegedly originating from GSC in the air have been detected above
the real property held by such individual (and, if so, identify all documents
concerning and reflecting such detection), whether the real property held by such
individual or entity has been appraised at any time during the ten year period prior
to the filing of this lawsuit (and, if so, identify the appraisal), and all uses (i.e.,
residence, business, lease, etc.) of the real property held by such individual or
entity.
RESPONSE:
The Plaintiffs object to the information requested in this Interrogatory as it
asks for information from absent class members. Further, the Plaintiff would object
to this Interrogatory on the grounds that it requests information which is overly
broad and unduly burdensome. Information for absent class members can not be
obtained at this stage of the proceedings.
24. Identify specifically by name each and every alleged contaminant or chemical
constituent and the amount which You allege has caused damage to each and
every motor vehicle uf the named and purported class members.
RESPONSE:
The Plaintiffs can not identify every contaminate which may have resulted in
the damage to their property, i.e., real estate, water craft or motor vehicle. However,
the Defendants are referred to the DHEC reports, which describe in detail their
investigation and conclusions in regarding the contaminates involved. However, as
discovery proceeds and expert analysis is completed, this interrogatory will be
updated.
25. Describe in specific detail the particular manner in which GSC was allegedly
negligent by failure to utilize controls, or by other alleged acts or omissions of GSC
that have caused damage to each and every motor vehicle of the named and
purported class members, including the date(s) of such acts or omissions, and
identify all documents reflecting, relating to, and/or concerning this response.
RESPONSE:
GSC has failed to confine its plants omissions to a level, concentration and/or
geographical dispersement in order to prevent the damages described in the
Complaint.
Additionally, the Defendants are referred to the various DHEC
documents which describe the omissions and the materials that GSC has allowed
to be released on to the Plaintiffs property. As discovery proceeds, this
interrogatory will be updated.
26. Identify each alleged member of the purported Class who has had an environmental
consultant or other person evaluate the environmental conditions of his/her motor
vehicle, describe in detail the results of every such evaluation, identify every such
consultant -or other person, and identify all documents concerning every such
evaluation.
RESPONSE:
Various class members have complained to DHEC and other governmental
agencies about the damage caused to their property from the emissions of GSC.
The Defendants are referred to the documents from DHEC who investigated the
matter. The Plaintiffs are not aware of absent class member who may have
consulted with DHEC in connection with any damage to their property caused by
emissions from GSC. However, as discovery progresses and this information
becomes available, this interrogatory will be supplemented.
27. With respect to each and every injury allegedly sustained by You, state the amount
of damages each plaintiff or potential class member seeks to recover from GSC for
the alleged injury, describe in detail how the amount of damages relates to or was
calculated from the injury allegedly suffered by a plaintiff or potential class member,
and identify all documents concerning those damages.
RESPONSE:
Please refer to the answer of interrogatory number 1.
REQUEST FOR PRODUCTION OF DOCUMENTS
1. All documents which You identified, concerning, or to which You referred in
responding to the foregoing interrogatories.
RESPONSE:
Plaintiffs are in possession of numerous documents received from DHEC and
other governmental agencies. It is believed that the Defendant has copies of these
documents. If the Defendant would like copies of the Plaintiffs' copies, or would like
to inspect the documents without requesting copies, please inform Plaintiffs'
. ' b . detail how the amount of damages relates to or was
the alleged InJury, descn e In
th
. . ry allegedly suffered by a plaintiff or potential class member,
calculated from e InJu
and identify all documents concerning those damages.
RESPONSE:
Please refer to the answer of interrogatory number 1.
REQUEST FOR PRODUCTION OF DOCUMENTS
1. All documents which You identified, concerning, or to which You referred in
responding to the foregoing interrogatories.
RESPONSE:
Plaintiffs are in possession of numerous documents received from DHEC and
other governmental agencies. It is believed that the Defendant has copies of these
documents. If the Defendant would like copies of the Plaintiffs' copies, or would like
to inspect the documents without requesting copies, please inform Plaintiffs'
counsel.
2. All documents concerning the identity or location of potential class members.
RESPONSE:
The class is identified by geographical area. This information is readily
available to the Defendants. The Plaintiffs will rely upon real estate records to
identify the class members when the Court directs the Plaintiffs to do so. At the
current time, Plaintiffs do not have any documents in response to this inquiry.
3. All documents concerning attempts by the named plaintiffs, counsel, or anyone else
to locate or identify potential class members.
RESPONSE:
Plaintiffs have no documents in response to this request.
4. All documents concerning individuals or entities who elected not to be part of the
proposed class.
RESPONSE:
5.
Plaintiffs have none.
A photograph of each motor vehicle within .5 of a mile from GSC that You contend
is a part of the alleged class and has been damaged.
RESPONSE:
The Plaintiffs counsel is not aware of any photographs taken of the subject
property. However, if Plaintiffs counsel becomes aware of such ph t h th
o 0srap s ey
will be provided for inspection and copying. At the present time, Plaintiffs have
none.
6. A photograph of each motor vehicle from .5 of a mile to one mile from GSC that You
contend is a part of the alleged class and has been damaged.
RESPONSE:
7. A photograph of each motor vehicle from one mile to two miles from GSC that You
RESPONSE:
8. A photograph of each motor vehicle from two miles to three miles from GSC that
You contend is a part of the alleged class and has been damaged.
RESPONSE:
9. A photograph of each motor vehicle from three miles to four miles from GSC that
You contend is a part of the alleged class and has been damaged.
RESPONSE:
10. A photograph of each motor vehicle from four miles to five miles from GSC that You
RESPONSE:
11 . All documents concerning every denial of a request for appointment as class
counsel.
RESPONSE:
None.
12. All documents, including retainer letters or agreements, relating to the proposed fee
and expense arrangement between proposed class counsel and the proposed class
representatives.
RESPONSE:
All fee agreements between the named Plaintiffs are protected by the attorney
client relationship and are not discoverable at this time.
13. All documents that were utilized, distributed, or referred to during the Meetings,
including, but not limited to, any sign-in sheets, agencies, minutes, schedules,
hand-outs, exhibits, documents, papers, handwritten or typed notes, memos,
messages, transcripts, or letters.
RESPONSE:
The only materials which may be in response to this request are fee
agreements and client information sheets which are protected by attorney client and
work product privilege.
14. A" documents in any way concerning the Meetings.
RESPONSE:
See response to number 13.
15. All documents You allege support Your contention that a class should be certified
in this case.
RESPONSE:
Please see response to number 1.
16. A" documents You intend to offer as exhibits at a hearing concerning Your request
for a class to be certified in this case,
RESPONSE:
Please see answer to number 1. However, as further documents become
available and are identified for this purpose, they will be produced.
17.
All documents used or consulted by You in defending the proposed class.
RESPONSE:
Plaintiffs do not understand this request, and therefore can not respond to
this inquiry. However, Plaintiffs' counsel is not aware of any such documents.
18. With respect to each named plaintiff, produce all records of purchase, sale, lease,
and other acquisition, divestiture, or use of motor vehicles in the areas You have
set forth in Your complaint in defining the proposed class, all documents relating
to Your contention that such individuals or entities have suffered diminution of their
motor vehicle's value, all documents relating to Your contention that such .
individuals or entities have suffered interference with use and enjoyment of their
motor vehicle, all W-2 forms, 1099 forms, and state and federal tax returns for all
tax years since and including 1990, all offers to purchase or sell motor vehicles in
the areas You have set forth in Your complaint in defining the proposed class, and
all documents concerning loans or leases involving the motor vehicles.
RESPONSE:
RESPONSE:
Please see answer to number 1. However, as further documents become
available and are identified for this purpose, they will be produced.
17. All documents used or consulted by You in defending the proposed class.
RESPONSE:
Plaintiffs dO" not understand this request, and therefore can not respond to
this inquiry. However, Plaintiffs' counsel is not aware of any such documents.
18. With respect to each named plaintiff, produce all records of purchase, sale, lease,
and other acquisition, divestiture, or use of motor vehicles in the areas You have
set forth in Your complaint in defining the proposed class, all documents relating
to Your contention that such individuals or entities have suffered diminution of their
motor vehicle's value, all documents relating to Your contention that such .
individuals or entities have suffered interference with use and enjoyment of their
motor vehicle, all W-2 forms, 1099 forms, and state and federal tax returns for all
tax years since and including 1990, all offers to purchase or sell motor vehicles in
the areas You have set forth in Your complaint in defining the proposed class, and
all documents concerning loans or leases invdlving the motor vehicles.
RESPONSE:
Please see answer to number 1. All requested information in this and all other
request for production will be provided by each individual Plaintiff. As stated, the
questionnaire will be provided to opposing counsel for approval prior to being
distributed. Plaintiffs object to furnishing of W-2 forms, 1099 forms and State and
Federal Income Tax Returns as being not relevant to this issue. However, if the
Defendant will explain the relevance of the tax information and for what purpose it
is to be used the Plaintiffs will revisit this request. ,
19. With respect to each alleged member of the proposed class, produce all records of
purchase, sale, lease, and other acquisition, divestiture, or use of motor vehicles
in the areas you have set forth in Your complaint in defining the proposed class, all
documents relating to Your contention that such individuals or entities have
suffered diminution of motor vehicle's value, all documents relating to Your
contention that such individuals or entities have suffered interference with use and
enjoyment of their motor vehicles, all W-2 forms, 1099 forms, and state and federal
tax returns for all tax years since and including 1990, all offers to purchase or sell
motor vehicles in the areas You have set forth in Your complaint in defining the
proposed class, and all documents concerning loans or leases involving the motor
vehicles.
RESPONSE:
Defendants are not entitled to information such as requested involving absent
class members and therefore this request is objectionable.
20. All documents concerning: (i) the amount of income of each named plaintiff; (ii) the
value of each asset of each named plaintiff, and (iii) the amount of each liability of
each named plaintiff.
RESPONSE:
Plaintiffs are not fronting costs of litigation and therefore this information is
not relevant and/or material to any issue and therefore this request is objectionable.
21. All documents concerning: (i) the current income of each source of payment for the
expenses in this matter if there is such a source other than the named plaintiffs, (ii)
the value of each asset of each such source, and (iii) the amount of each liability
of each such source.
RESPONSE:
Plaintiffs are not fronting costs of litigation, therefore, this information is not
relevant and/or material to any issue and therefore, this request is objectionable.
22. All documents concerning each and every alleged contaminant or constituent and
the amount which You allege has caused damage to each and every motor vehicle
of the named and purported class members.
RESPONSE:
Plaintiffs have no documents relating to this inquiry except those that are
public documents from DHEC and other governmental agencies. They may be
obtained from DHEC or other governmental agencies, or at the Defendant's expense,
Plaintiff will copy and forward all to the Defendant. Plaintiffs contend that damage
to their property is cause,? by the legal and illegal emissions created by Georgetown
Steel Corporation. Therefore, all of these documents may relate to this inquiry.
23. All documents concerning Your contention that GSC was allegedly negligent by
failure to use controls, or by other alleged acts or omissions of GSC that have
caused damage to each and every motor vehicle of the named and purported class
members.
RESPONSE:
Please see answer to 22. The governmental documents referred to above
indicate that Georgetown Steel Corporation in its public statements has not been
completely candid. There are literally numerous infractions
24. All environmental consultant, other expert evaluations or evaluations by any person
concerning the environmental conditions on every motor vehicle in the proposed
class and all documents concerning those evaluations.
RESPONSE:
Plaintiffs have none at this time.
25. All statements and/or affidavits.
RESPONSE:
None known at this time except DHEC file materials (see answer to 22.)
26. All documents relating to or concerning the injury or injuries allegedly sustained by
any plaintiff-or potential class member.
RESPONSE:
None at this time.
27. All documents relating to or concerning the calculation of damages with respect to
any named plaintiff or potential class member.
RESPONSE:
28.
Please see answer to interrogatory number 1.
All documents prepared by or relied upon by the expert(s) You may rely upon
concerning Your request that a class be certified.
RESPONSE:
None at this time.
29. All publications concerning class certification issues by the expert(s) You rely upon
concerning Your request that a class be certified.
RESPONSE:
None at this time.
30. All deposition or trial transcripts concerning testimony by Your expert(s) involving
class certification issues.
RESPONSE:
Experts have not been identified at this time.
31 . The file(s) of all expert(s) You may rely upon concerning Your request that a class
be certified.
RESPONSE:
None at this time.
32. Except for privileged documents, all correspondence between and among anyone
or more of the following persons or entities (1) counsel for plaintiff; (2)
representatives and employees of the State of South Carolina (including members
of the General Assembly) ; (3) GSC; (4) anyone or more of the named plaintiffs; (5)
anyone or more appraisers; (6) any media or press representative or employee; (7)
any representative or employee of the South Carolina Department of Health and
Environmental Control ; (8) You.
RESPONSE:
1. Plaintiffs counsel has not written to any member of the South Carolina
General Assembly, Georgetown Steel Corporation, or to a real estate property
appraiser. However, Plaintiffs counsel has written to Plaintiffs, one letter to the
media which was published in Georgetown Times on July 8, 1998, and several
Freedom of Information Letters to DHEC and other governmental agencies. Copies
of letters to the media and DHEC are attached.
2. Plaintiffs are unaware of any correspondence from the General Assembly
to the other groups. However, General Assembly members may have written letters
to DHEC.
3. Georgetown Steel Corporation has written numerous letters and
Georgetown Steel Corporation will be requested to furnish all letters in Plaintiffs
forthcoming discovery requests.
4. The named Plaintiffs will answer this inquiry on their questionnaires.
5. None known at this time.
6.
Plaintiffs are not aware of any communication from the media to any
group.
Plaintiffs are aware that the media may have been in contact with
Government agencies.
7. Plaintiffs are not in possession of any correspondence from DHEC to any
group except that w h i c ~ is included in Freedom of Information responses to
Plaintiffs inquiries.
33. All documents reflecting, summarizing, pertaining to, and concerning the alleged
damages tile named plaintiffs seek in this action (i) on their own behalf, and (ii) on
the behalf of the alleged Class members.
RESPONSE:
None at this time, ho.wever, the questionnaire may respond to this inquiry.
Please see answer to interrogatory number 1.
34. All photographs concerning this matter.
RESPONSE:
If Plaintiffs have photographs, they will be furnished with answers to the
questionnaire. Please see answer to interrogatory number 1.
35.
All videotapes concerning this matter.
RESPONSE:
If Plaintiffs have videos, the tapes will be furnished or copied with answers to
the questionnaire. Please see answer to interrogatory number 1.
36. All audio-recordings concerning this matter.
RESPONSE:
None known at this time. However, Plaintiffs counsel is looking into whether
public hearings have been recorded.
Thi s Zql day of September, 1998.
Bell & Moore, P A.
( i f ~ a ~ ~
23 Ing Street
Post office Box 2590
(843) 546-2408
Case 01-30319 Doc 1
Filed 02/07/01 Entered 02/07/01 10:19:00
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Desc Page 1
-
-
I
'"",.
(Ome_ I Form 1) (9/97)
- HI - -_ .. -
UNITED STATES BANKRUPTCY COURT VOLUNTARY
WESTERN DISTRICT OF NORTH CAROLINA PETITION
Name of Debtor (if individual, enter Last, First, Middle): Name of Joint Debtor (Spouse) (Last, First, Middle):
GS Industries, Inc.
All Other Names used by the Debtor in the last 6 years (include married, All Other Names used by the Joint Debtor in the last 6 years (include
maiden, and trade names): married, maiden, and tradc names):
Soc. Sec.lTax LD. No. (if more than one, state all): Soc. Sec.!Tax LD. No. (if more than one, state all):
56-1941048
Street Address of Debtor ("10. & Street, City, State & Zip Code): Street Address of Joint Debtor (No. & Street, city, State & Zip Code):
1901 Roxborough Road, Suite 200
Charlotte, North Carolina 28211
County of Residence or of the COU"ty of Residence or of the
Principal Place of Business: Prin.;ipal Place of Business:
Mecklenburg County, North Carolina
Mailing Address of Debtor Mail.ing Address of Joint Debtor
(if different from street address):
(if different from street address):
Location of Principal Assets of Business Debtor
(if different from street address above):
Information Regarding the Debtor (Check the Applicable Boxes)
Venue (Check any applicable box)
Debtor has been domiciled or has had a residence, principal place of business, or principal assets in this District for 180 days immediately
preceding the date of this petition or for a longer part of such 180 days than in any other District.
o There is a bankruptcy case concerning debtor's affiliate, general partner, or partnership pending in this District.
Type of Debtor (Check all boxes that apply) Chapter or Section of Bankruptcy Code Under Which the Petition is Filed
0
Individual(s)
0
Railroad (Check one box)
Corporation
0
Stockbroker
0
Chapter 7

Chapter 11 o Chapter J3
o Partnership o Commodity Broker o Chapter9
0
Chapter 12
o Other
0
Sec. 304 - Case ancillary to foreign proceeding
Nature of Debts (Check onc box) Filing Fee (Check one box)
o ConsumerlNon-Business

Business

Full filing Fee attached
o Filing Fee to be paid in installments (Applicable to individuals only)
Chapter II Small Business (Check all boxes that apply)
Must attach signed application for the court's consideration
o Debtor is a small business as defined in II U.s.c. 101
certifying that the debtor is unable to pay fee except in
o Debtor is and elects to be considered a small busmess under 11
installments. Rule l006(b). See Official Form No.3.
U.S.c.
1126(c)(Optional)
Statistical/Administrative Information (Estimates only) THIS SPACE IS FOR

Debtor estimates that funds will be available for distribution to unsecured creditors
COURT USE ONLY
o Debtor estimates that, after any exempt property is excluded and administrative expenses
Ie:;. :::iEc
paid, there will be no funds available for distribution to unsecured creditors. " ..
-"'I'
""'
r
S Estimated Number of Creditors I-IS 16-49 50-99 100-199 200-999 I,OOO-aver
1

f"
0 0 0 0 0
! t-
Estimated Assets '"
-r.
lon
SO to $50,001 to SIOO,OOI to $500,001 to SI,OOO,OOI to SIO.0('0,001 to $50,000,001 to More tban
CD
S50,OOO S100,000 $500,000 SI,OOO,OOO $10 million $50 million $100 million $100 million -
1
---.I
0 0 0 0 I25J 0
Estimated Debts
:;:::,
','
SO to $50,001 to $100,001 to $500,001 to SI,OOO,OOI to SIO,OOO,OOI toS50,000,001 to More fllan
\0
$50,000 $100,000 $500,000 $1,000,000 $10 million $50 million $100 million

0 0 0 0 0 D 0
-:1
0\

;;0
c-; --1
NYl 2049513vl
01-303196)
Case 01-30319 Doc 1 Filed 02/07/01 Entered 02/07/01 10:19:00 Desc
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CERTIFICATE OF RESOLUTION
I, Mark G. Essig, Chainnan, President and Chief Executive Officer ofGS
Industries, Inc., a Delaware corporation (the "Corporation") hereby certify that at a special
meeting of the Board of Directors of the Corporation duly called and held on February 7, 2001,
the following resolutions were duly adopted in accordance with the requirements ofthe
Delaware General Corporation Law and that said resolutions have not been modified or
rescinded, and are still in full force and effect on the date hereof:
Page 3
RESOLVED, that in the judgment of the Board of Directors, it is desirable and in
the best interests of the Corporation, its creditors, stockholders, employees, and other
interested parties that a petition be filed by the Corporation seeking relief under the
provisions of chapter 11 of title 11, United States Code (the "Code");
RESOLVED, that Mark G. Essig, Chainnan, President and Chief Executive
Officer, and Luis E. Leon, Executive Vice President and Chief Financial Officer (each,
an "Authorized Officer" and together, the "Authorized Officers") are, and each of them
is, hereby authorized and empowered on behalf of, and in the name of, the Corporation to
execute and verify or certify a petition under chapter 11 of the Code and to cause the
same to be filed in the United States Bankruptcy Court for the Western District of North
Carolina at such time as said officer executing the same shall detennine and in such fonn
or fonns as such officer may approve;
RESOLVED, that each ofthe Authorized Officers be, and each of them is, hereby
authorized on behalf of, and in the name of, the Corporation to execute any and all plans
of reorganization under chapter 11 of the Code, including any and all modifications,
supplements, and amendments thereto, and to cause the same to be filed in the United
States Bankruptcy Court for the Western District of North Carolina at such time as said
officer executing the same shall detennine;
RESOLVED, that the finn of Sidley & Austin, 875 Third Avenue, New York,
New York 10022, be, and hereby is, emploYf!d as attorneys for the Corporation in
connection with the prosecution ofthe Corporation's case under chapter 11 of the Code;
RESOLVED, that the finn of Parker, Poe, Adams & Bernstein L.L.P., Three First
Union Center, 401 South Tryon Street, Charlotte, North Carolina 28202, be, and hereby
is, employed as North Carolina attorneys for the Corporation in connection with the
prosecution of the Corporation's case under chapter 11 ofthe Code;
RESOLVED, that each of the Authorized Officers be, and each of them hereby is,
authorized to execute and file any and all petitions, schedules, motions, lists, applications,
pleadings, and other papers, and to take any and all such other and further actions which
the Authorized Officers or the Corporation's legal counsel may deem necessary or
appropriate to file the voluntary petition for relief under chapter 11, and to take and
NYI 2049392vl
of 26
A
Page 4
perfonn any and all further acts and deeds which they deem necessary, proper and
desirable in connection with the chapter 11 case, with a view to the successful
prosecution of such case, including, without limitation, seeking authority to borrow, and
borrowing, in principal amount of up to $100 million under a financing facility with The
CIT GrouplBusiness Credit, Inc. and granting liens and other security therefore;
RESOLVED, that each of the Authorized Officers be, and each ofthem hereby is,
authorized to employ and retain legal counsel., financial advisors, accountants and other
professionals, to advise the Corporation in cOlmection with its case under chapter 11 of
the Code;
RESOLVED, that the execution, delivery and perfonnance by the Corporation of
the proposed Credit Agreement (the "Credit Agreement") to be entered into by the
Corporation, GS Technologies Corporation, a Delaware corporation, GS Technologies
Operating Co., Inc., a Delaware corporation, Georgetown Steel Corporation, a Delaware
corporation, ME International, Inc., a Michiglll corporation, ME-West Castings, Inc., an
Arizona corporation (collectively, the "Borrowers'), the financial institutions from time to
time party thereto (collectively, the "Lenders"), and THE CIT GROUP/BUSINESS
CREDIT, INC., as agent for the Lenders (the "Agent"), setting forth the tenns and
conditions upon which the Lenders will provide loans to the Borrowers in an aggregate
principal amount not exceeding $100.0 million, be, and the same hereby is, authorized
and approved, that the Corporation enter into the Credit Agreement, consummate the
transactions contemplated thereby and perfonm the tenns thereof, and that any of the
Authorized Officers of the Corporation be, and each of them hereby is, authorized and
directed on behalf of the Corporation to execute and deliver to the Agent, on behalf of
and in the name of the Corporation, the Credit Agreement, with such changes as may be
approved by the Authorized Officer executing the Credit Agreement and such other
documents as may be contemplated therein, such Authorized Officer's execution thereof
to be conclusive evidence of such approval.
RESOLVED, that the Authorized Officers of the Corporation be, and each of
them hereby is, authorized and directed on behalf of the Corporation to take such actions
and to make, sign, execute, acknowledge and deliver (and record in a relevant office of
the county clerk, if necessary) any and all such agreements listed above (including
exhibits thereto), including any and all affidavits, orders, directions, certificates, requests,
receipt, financing statements or other instruments as may be reasonably be required to
give effect to these Resolutions, and to execute and deliver such agreements (including
exhibits thereto) and related documents, and to fully perfonn the tenns and provisions
thereof;
RESOLVED, that the Authorized Officers of the Corporation be, and each of
them hereby is, authorized and directed on behalf of the Corporation to take such actions
and to make, sign, execute, acknowledge and deliver all such additional documents,
agreements and certificates as may reasonably be required to give effect to the
consummation of the transactions contemplated by these Resolutions and any chapter 11
plan of reorganization, and to execute and deliver such documents, agreements and
certificates, and to fully perfonn the tenns ard provisions thereof; and
\,\y I 2049392v 1
Case 01-30319 Doc 1 Filed 02107/01 E n t E ~ r e d 02107/01 10:19:00 Desc Page 5
of 26
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--.
RESOLVED, that to the extent that any of the actions authorized by any of these
Resolutions have been taken by the Authorize:d Officers of the Corporation on its behalf,
such actions are hereby ratified and confirmed in their entirety.
IN WITNESS WHEREOF, I have hereunto set my hand this 7!!! day of
February, 2001.
NY I 2049392v I
~
Mark G. Essig
~ -----;7
Chairman, President and Chief Executive
Officer of GS Industries, Inc.
Case 01 -30319 Doc 1 Fi led 02/07/01 E ntmed 02/07/01 1 0: 19 :00 Desc Page 6
of 26
-
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE WESTERN DISTRICT OF NORTH CAROLINA
CHARLOTTE D[VISION
In re: Chapter 11
GS Industries, Inc.
.1
)
)
)
)
Case No. 01-30319 (GRH)
Debtor. Jointly Administered
LIST OF AFFILIATED DEBTORS
Name Filing Date District Judge Case No.
GS Technologies Corporation Feb. 7,2001 W ~ s t e r n District Hodges 01-30320
of North Carolina
GS Technologies Operating Co., Feb. 7,2001 Western District Hodges 01-30321
Inc. of North Carolina
Georgetown Steel Corporation Feb. 7,2001 Western District Hodges 01-30322
of North Carolina
ME International, Inc. Feb. 7,200] Western District Hodges 01-30317
of North Carolina
ME-West Castings, Inc. Feb. 7,2001 Western District Hodges 01-30318
of North Carolina
509632.1
Case 01-30319 Doc 1
Filed 02/07/01 Entmed 02/07/01 10:19:00 Desc
of 26
Page 7
-
LIST OF CREDITORS HOLDING 20 LARGEST UNSECURED CLAIMS
In re GS Industries, Inc.
UNITED STATES BANKRUPTCY COURT
WESTERN DISTRICT OF NORTH CAROLINA
Debtor Case No.
Chapter ~ 1 _ 1 ~ _
Following is the list of the debtor's creditors holding the 20 largest unsecured claims. The list is prepared
in accordance with the Fed. R. Bankr. P. 1007(d) for filing in this chapter II case. The list does not include (1)
persons who come within the definition of "insider" set forth in II U.S.C. 101, or (2) secured creditors unless
the value of the collateral is such that the unsecured deficiency places the creditor among the holders of the 20
largest unsecured claims.
(1) (2) (3) (4) (5)
Name of creditor and Name, telephone number and Nature of claim Indicate if claim Amount of claim [if
complete mailing complete mailing address. (trade debt. is contingent. secured also state
address including zip including zip code. of bank loan. gov- unliquidated. value of security]
code employee. agent. or department ernment contract. di.lputedor
of creditor familiar with claim etc.) subject to setoff
who may be contacted
American Express Rick Routhier trade debt $54,658.66
20022 North 31
st
Ave. 888-800-8564
Phoenix, AZ 85027 20022 North 31
st
Ave.
Phoenix, AZ 85027
Buck Consultants Mathieu Lussier trade debt $29,754
200 Berwyn Park 610-651-8504
Suite 110 200 Berwyn Park
Berwyn, PA 19312 Suite 110
Berwyn, PA 19312
Jenkins Coffee Service Attn: Accounts Receivable trade debt $209.75
Box 5321 800-458-2633
Knoxville, TN 37928 Box 5321
Knoxville, TN 37928
EDS Corporation Paul Gibson trade debt $8,360
4800 Six Forks Rd 919-784-8346
Raleigh, NC 27609 4800 Six Forks Rd
Raleigh, NC 27609
Brickfield Burchette Peter Brickfield trade debt $5,000
Ritts & Stone, PC 202-342-0800
Suite 800 West Suite 800 West
1025 Thomas Jefferson 1025 Thomas Jefferson St.,
St.,NW NW
Washington, DC 20007 Washington, DC 20007
509645.1
NYI 2050999vl
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Case 01-30319 Doc 1
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Page 8
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MCI W orldcom Erik Hartwing trade debt $2,256.33
Conferencing 704-343-6104
500 Second Ave. SE 500 Second Ave. SE
POBox 3160 PO Box 3160
Cedar Rapids, IA 52401 Cedar Rapids, IA 52401
AT&T Kevin Watson trade debt $3,269.27
10101 David Taylor Dr. 704-510-5673
Charlotte, NC 28262 10101 David Taylor Dr.
Charlotte, NC 28262
Bell South Tracey Herny trade debt $1,872.71
358 Meeting Street 888-290-8611
Charleston, SC 29423 358 Meeting Street
Charleston, SC 29423
Steuben Attn: Accounts Receivable trade debt 1,086.25
One Steuben Way 800-424-4240
Coming, NY 14831 One Steuben Way
Coming, NY 14831
CD Capital Attn: Accounts Receivable trade debt $862.55
Account Processing 800-736-0220
Center Account Processing Center
1055 Westlakes Dr. 1055 Westlakes Dr.
Berwyn, PA 19312 Berwyn, PA 19312
Boise Cascade Office Attn: Accounts Receivable trade debt $857.52
Products 800-472-6473
P.O. Box 10175 P.O. Box 10175
Atlanta, GA 30392 Atlanta, GA 30392
Dr. James B. Edwards, Dr. James B. Edwards trade debt $669.78
DMD 843-792-4275
Medical University of Medical University of SC
SC 171 Ashley Ave.
171 Ashley Ave. Charleston, SC 29425
Charleston, SC 29425
Wiley, Rein & Fielding Charles Owen Verrill J r. trade: debt $669.05
1776 K Street, NW 202-719-7323
Washington, DC 20006 177 6 K Street, NW
Washington, DC 20006
Aspen Publishers Inc. Attn: Accounts Receivable trade debt $398.66
7201 McKinney Circle 800-234-1660
Fredrick, MD 21704 7201 McKinney Circle
Fredrick, MD 21704
Executive Car Service Jerome Allan Moe trade debt $247.20
536 Rountree Road 704-552-2623
Charlotte, NC 28217 536 Rountree Road
Charlotte. NC 28217
Pepsi Cola Bottling Co. Attn: Accounts Receivable trade debt $223.33
2820 South Blvd. 704-523-6761
Charlotte, NC 28224 2820 South Blvd.
Charlotte, NC 28224
2
NYJ 2050999vJ
of 26
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Page 9
West Group Michael E. Wilens
800-328-4880
trade debt $145.90
610 Opperman Dr.
Eagan, MN 55123
Fedex
2650 Thousand Oaks
Blvd.
Memphis, TN 38118
6 I 0 Opperman Dr.
. Eagan, MN 55123
Dan White
800-448-9961
2650 Thousand Oaks Blvd.
Memphis, TN 38118
Date: ;;;</7/0 I
I
NYI 2050999vl
GS Industries, Inc.
Debtor
trade debt $71.93
3
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of 26
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DECLARATION UNDER PENALTY OF PERJURY
ON BEHALF OF A CORPORATION OR P ARTNERSmp
I, Mark G. Essig, Chairman, President and Chief Executive Officer ofGS Industries, Inc., a Delaware
corporation (the "Corporation") named as the debtor in this case, declare under penalty of perjury that I have read
the foregoing Voluntary Petition and Related Documents, and that it is true and correct to the best of my
information and belief.
Date '2 /7 /0 I
~ ,
509645.1
NY 1 2050999vl
Signature ~ 7'
M IJ-;e K (,. 5S/ ~
(Print Name and Title)
Case 01-30319 Doc 1
Filed 02/07/01 Entered 02/07/01 10:19:00 Desc
of 26
-
-,
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE WESTERN DISTRICT OF NORTH CAROLINA
In re:
GS INDUSTRIES, INC.
Tax I.D. No. 56-1941048,
CHARLOTTE DIVISION
,
)
) Chapter 11
Case No, 01-30319
Debtor.
LIST OF CREDITORS IN LIEU OF MATRIX
Page 11
I, Mark G. Essig, Chainnan, President and Chief Executive Officer ofGS Industries, Inc.,
hereby certify that the attached list of creditors of GS Industries, Inc, is clerically accurate.
Dated: February 7,2001.
~ ~
Mark G ..... Essig
-----
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VENDOR NAME ADDRESS 1
A. S. PRATT & SONS P. O. BOX 95880
AM CAROLINAS 1975-K MAGWOOD ROAD
AM MACHINERY & EQUIPMENT CORP 7401 MORGAN AVENUE
ACCOUNTANTS EXECUTIVE SEARCH _ P. O. BOX 337
ACCREDITED FIRE & SAFETY EQUIPMENT 3219 WlNDBLUFF DRIVE
ACERCO, SA AV. LOS ROSALES NRO. 245
ACTION AWARDS 4805 S. BLVD.
ACTION DElIVERY SERVICE P. O. BOX 11995
ADDISON, KElLI G. 1739 WANDERING WAY DR.
ADT SECURITY SERVICES P. O. B0)("371967M
ADVANCED WIRE TECHNOLOGY P. O. BOX 1029
AETNA U.S. HEAL THCARE AETNA-MIDDLETOWN
AFCO P. O. BOX B440
AIRBORNE EXPRESS P. O. BOX 91001
ALEXANDER CHILDREN'S CENTER 6220 THERMAl ROAD
AL-GABANDI, ABDULLAH KUWAIT FOREIGN TRADING CO.
AlLAN F. DOW& ASSOCIATES, INC. 520 POST OAK BLVD.
AlLIANZ INSURANCE COMPANY P. O. BOX n82
ALLTEl P. O. BOX BOiS
ALLTEl CAROUNA. INC. P.o. BOX 8017
AlL TEL MOBILE COMMUNICATIONS P. O. BOX 8024-
AlTA lANGUAGE SERVICES, INC. 3355 LENOX ROAD
AM. SOC. OF CORP. SECRETARIES 521 FIFTH AVENUE
AMBASSADOR CONSTRUCTION CO. 4444 2. 89TH ST.
AMELIA ISLAND PLANTATION P. O. BOX 3000
AMERICAN APPRAISAL ASSOCIATS BIN 391
AMERICAN EXPRESS COMPANY SUITE 0001
AMERICAN IRON & STEEL 848 HIGH STREET
AMERICAN IRON & STEEL INST 110117THST, NW
AMERICAN IRON REDUCTION 7300 LA HWY 3214
AMERICAN MANAGEMENT ASSOC. P. O. BOX 4725
S!:C!JP.!TV
AMERICAN METAL MARKET
AMERICAN METAL MARKET
AMERICAN PHOTOCOPY EQUIPMENT
AMERICAN TELECONFERENCING
AMERICAN WIRE PRODUCERS ASSOC.
AMOCO OIL COMPANY
ANDERSON & ASSOCIATES
ANDERSON, GERALD L
ANGELA HEALTHCARE
AON RISK SERVICES
AON TRADE CREDIT. INC.
ARBORETUM URGENT CARE
ARENT, FOX, KINTNER, PLOTKIN &
ARTHUR ANDERSEN & CO.
ARTHUR ANDERSEN LLP
ARTHUR'S
ARTIS & ASSOCIATES, INC.
ASME DATA PROCESSING DIVISION
ASPEN PUBLISHERS, INC
ASSOC. OF IRON & STEEL ENGINEERS
AT&T
AT&T
AT&T
GROUP PREM!UM AC-COUNT]Nr::
JESS ESPINOSA
P. O. BOX 15127
9349 CHINA GROVE ROAD
POBOX 78-5450
DEPARTMENT 3023
112 SOUTH TRYON
4519 PARVIEW DR
14100 NEWBURGH RO
POBOX 7247-7389
2 WORLD TRADE CENTER
7810 PROVIDENCE RD.
WASHINGTON SQUARE
2300 GUINESS TOWER
POBOX 905682
4400 SHARON ROAD
CROWNPOINT EXEC. DR
BOX 29359, GPO
ACCOUNTS RECEIVABLE OEOT
3 GATEWAY CENTER
POBOX 914500
POBOX 9001309
PO BOX 78355
GS INDUSTRIES, INC. MASTER CREDITOR UST
ADDRESS 2 ADDRESS 3
SANTA ANITA
P. O. BOX 905204
P. O. BOX 5665
SUITE 680
SUITE 510
SUITE 1300
P () AOX 19032
825 SEVENTH AVENUE 7TH FLOOR
98TH FLOOR
SUITE 102
1050 CONNECTICUT AVENUE,
1055 WEST HASTINGS STREET
POBOX911
SUITE 1900
CITY
CHICAGO
CHARLESTON
CLEVElAND
NEWARK
CHARLOTTE
LIMA 43
CHARlOTTE
CHARLOTTE
CHARLOTTE
PITTSBURGH
RANCHO CUCAMONG
CHARLOTTE
KANSAS CITY
SEATTlE
CHARLOTTE
KUWAIT
HOUSTON
BURBANK
LITTLEROCK
LITTLE ROCK
LITTlE-ROCK
ATlANTA
NEW YORK
PRAIRIE VILLAGE
AMELIA ISlAND
MILWAUKEE
CHICAGO
CHESTERTOWN
WASHINGTON
CONVENT
BUFFALO
GREEN BAY
NEW YORK
NORTH HOLLYWOOD
PINEVILLE
KANSAS CITY
WASHINGTON
DES MOINES
CHARLOTTE
CHARlOTTE
,
LIVONIA
PHILADELPHIA
NEW YORK
CHARLOTTE
WASHINGTON
VANCOUVER
CHARLOTTE
CHARLOTTE
CHARlOnE
NEW YORK
FREDERICK
PITTSBURGH
ORLANDO
lOUISVILLE
PHOENIX
Pa!l'"
STATEIPROV ZIP COUNTRY
IL 60694-5880
sc 29414
OH 44127
NJ 07101"'()337
NC 282n
PERU
NC 28217
NC 28220
- NC 28226
PA 15250
CA 91730
NC 28290-5204
MO 64114
WA 98111
NC 28222
0
ARABIAN GULF
TX n027
CA 91510-7782
AR 72203-8015
AR
AR
GA 30326
NY 10175
KS 66207-2240
FL 32035-1307
WI 53288-0391
IL 60679-0001
MD 21620
DC 20036
LA 70723-020B
NY 14240-4725
WI 64307-9032
NY 10019
CA 91615-9645
NC 28134
MO 54187-5450
OC 20042-3023
IA 50359
NC 28284
NC 28226
MI 48154-5010
PA 19170-7389
NY 10048
NC 28226
DC 20036-5339
Be 6E 2J2 CANADA
NC 28290-5682
NC 28211
NC 28227
NY 10087-9359
MD 21705-0911
PA 15222-1004
FL 32891-4500
KY 40290-1309
A2 85062-8355
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VENDOR NAME
AT&T
AT&T
AT&T
AT&T
AT&T EASYUNK SERVICES
AT&T INFORMATION SYSTEMS
AT&T WIRELESS SERVICES
ATLANTA BREAD COMPANY
ATlAS
AUDIQWORKS
AUST. DEIDRE P.
AVIS
BADGER CONSULTING. INC.
8AIN CAPITAL FUND IV, L.P.
BAtN CAPITAl FUND lV-B. LP.
BAIN CAPITAL PARTNERS IV. LP.
BALLOU & STEINBERG
BANK OF AMERICA
BANK OF AMERICA ILLINOIS AS TRUSTEE
BANKER, JAMES
BAR GREEN. INC
BARBARA BUNN SPECIALTIES
BARKLEY, JACK. TRUSTEE FOR THE
eARTHeD INTERNATIONAL. tNC.
BATES DESIGN
BATH. HAROLD T.
SCI PROPERTY CO, NO. 10
BCIP ASSOCIATES
SCIPTRUST ASSOCIATES, L.P,
BECHTEL CORPORATION
BECK IMPORTS OF THE CAROLINAS
BEDDOWS & COMPANY. LTD.
BEll SOUTH
BELL, SEL lZER. PARK & GIBSON
BENEFITS & COMPENSATION SOL
BENNETT CARDIAC CENTER. PA
BERLITZ lANGUAGE CENTERS
BEST IMPRESSIONS. INC,
BEST SOFTWARE. INC.
BETSY CARVER PERSONNEL. INC.
BLEIMANN. KARL
BLUE CROSS & BLUE SHIELD OF SOUTH
BMW FINANCIAL SERVICES
BNA
BOEHM. KURTZ & LOWRY
BOISE CASCADE OFFICE PRODUCTS
BONITZ CONTRACTING COMPANY
BOOM, RICHARD E.
BOWNE INTERNET SOLUTIONS
BOWNE OF ATLANTA. INC,
BOYD, REGINA
BRICKFIELD. BURCHETIE & RITTS
BROUDY PRINTING, INC
BROWN, KENNETH
BUCK CONSULTANTS, INC
ADDRESS'
PO BOX 8103
POBOX 78522
POBOX 9001307
POBOX 9001310
CS DRAWER 100659
POBOX70066
POBOX 650628
4400 SHARON ROAD
POBOX 1637
4030..6 OLD PINEVILLE RD
9045 PAYTON RANDOLPH DR,
7876 COLLEcnONS CENTER OR
86 SAUNDERS LN,
C/O BAIN CAPITAL. INC.
C/O BAIN CAPITAL. INC.
TWO COPLEY PLACE
1011 N. FRASER ST.
100STRYON
C/O KIRKlAND & ELLIS
619 MCCLURE RD
5950 FAIRVIEW ROAD
10701 AHNGING MOSS TRAIL
C/O BENJAMIN C. HUSEL TON
POBOX 8538-169
1470 BEN SAWYER BLVO.
11N-ROSEMARY AVE,
ClO THE HARRIS GROUP
C/O BAIN CAPITAl. INC.
C/O BAIN CAPITAl. INC.
P. O. BOX 100217
5141 E.INDEPENDENCE BLVD,
4 SMITHFIELD ST
PO BOX 33009
P a DRAWER 34009
SUBSCRIPTION DEPARTMENT
36 LATROBE DRIVE
5821 FAIRVIEW RD.
440 S, INDEPENDENCE'BLVD.
PO BOX 17428
1515 MOCKINGBIRD LANE
8201 EAGLES POINT CT.
POBOX6000
POBOX 9001065
PO BOX 64543
2110 CBLD CENTER
POBOX 10175
645 ROSEWOOD DRIVE
106 RIVER WOOD DRIVE
330 HAMILTON ROW
POBOX 101691
1901 G VILLAGE BROOK DR.
1025 THOMAS JEFFERSON ST _.NW
PO BOX 5248
808 SPRUCE STREET
PO BOX 93341
GS INDUSTRIES, INC. MASTER CREDITOR UST Page 2
ADDRESS 2 ADDRESS 3 CITY STATEIPROV ZIP COUNTRY
FOX VALLEY IL 6059l>-8103
PHOENIX AX 85062-8522
LOUISVIllE KY 4029G-13<l7
LOUISVIllE KY 4 0 ~ 1 3 1 0
I
ATlANTA GA 303s.wJ659
i
CHARLOTTE NC 28294-0066
DALlAS TX 7526$0()62B
CHARLOTTE NC 28211
WHITE PLAINS NY 10602
CHARlOTTE NC 28217
CHARLOTTE NC 282n
CHICAGO IL 60693
RIDGEFIELD CT 068n
ATTN: PAUL B. EDGERLEY TWU CUt'LE.Y PLACE BOSTON MA 021":5
ATIN: PAUL B. EDGERLEY TWO COPlEY PLACE BOSTON MA 02116
I
BOSTON MA 02116
GEORGETOWN SC 29440-2848
CHARlOTTE NC 28202
200 EAST RANDOLPH DRIVE CHICAGO IL 60601
LEBANON OH 45036
SUITE 218 CHARlOTTE NC 28210
CHARlOTTE NC 28227
30 OYSTER REEF DRIVE HILTON HEAD SC 29926
PHILADELPHIA PA 19171..(1169
SUITE 9 Mr. PLEASANT SC 29464
ANDREWS SC 29510-2627
POBOX 651528 CHARlOTTE NC 2ft26S.1528
ATTN: PAUL B. EOGERLEY TWO COPLEY PLACE BOSTON MA 02116
ATIN: PAUL B. EOGERlEY lWO COPLEY PLACE BOSTON MA 02116
PASADENA CA 91189
CHARLOTTE NC 28212
PITTSBURGH PA 152222213
CHARlOTTE NC 28243
CHARLOTTE NC 28234
POBOX615 HOLMES PA 19043-0615
CHARLOTTE NC 28211
CHARlOTTE NC 28200
cHARlOnE NC 28204
BAlTIMORE MD 2129&9108
SUITE 1020 CHARLOTTE NC 2B209
CHARLOnE NC 282n
COLUMBIA- SC- 29260 -
COLUMBUS OH 4327HJ780
BALTIMORE MD 21264-4543
36 E. SEVENTH ST. CINCINNATI OH 45202
ATlANTA GA 30392-1705
POBOX 82 COLUMBIA SC 29202..()O82
FORT MilL SC 29715
BJRMINGHAM MI 48009
ATLANTA GA 30392-1691
CHARLOTTE NC 28210
SUITE 800 WEST WASHINGTON DC 20007
221 AUBURN ST. PITISBURGH PA 15206
GEORGETOWN SC 29440-4322
CHICAGO IL 60673-3341
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VENDOR NAME
BUDD VAN LINES
BUDGET CHEM--DRY
BUlLARD, ROBERT L.
BURNS, STEVEN R
BURNSWORTH, JOHN E.
BURR, KAREN
BUSINESS COMMUNICATIONS. INC
BUSINESS INSURANCE
BUSINESS LICENSE DIVISION
BUSINESS WIRE
BUSINESSWEEK
BUSTER DESIGN GROUP
DCA ii'tl'-
CADMUS
CAl QINGSHUANG
CALIFORNIA FRANCHISE TAX BOARD
CAUFORNIA SECRETARY OF STATE
CAREY OF CINCINNAl1
CARMEL COUNTRY CLUB
CAROLINA BUSINESS INTERIORS
CAROLtNA PANTHERS
CAROLINAS STADIUM CORP
CASEY EQUIPMENT CORPORATION
CAVIN'S, INC.
CCH INCORPORATED
CD CAPITAl
CENTER FOR CREATIVE LEADERSHIP
GENTER FOR MANAGEMENT RESEARCH
CENTRAL PIEDMONT COMMUNITY
CHADBOURNE & PARKE
CHM4PION SAFE & LOCK SERVICE
CHARLOTTE
CHARLOTTE ARRANGEMENTS
CHARLOTTE CHAMBER
CHARlOTTE copy DATA,INC
CHARLOTTE COUNTRY CLUB
CHARlOTTE HORNETS
CHARLOTTE OFFICE PRODUCTS
CHARLOnE PAPER COMPANY
CHARLOTTE WORLD AFFAIRS COUNSll
CHARTER FLIGHT, INC.
CHASE AUTO FI NANCE
CHEF'S CATERING
CHICAGO AREA COUNCIL
CHOICEPOINT. INC.
CHRYSLER FINANCIAL
CITY -COUNTY TAX COLLECTOR
CLARK, WILSON
CLEANWAY L.S., INC.
CLIMATE COND OF CHARLOTIE. INC.
COCA-COi.A BOTTLING COMPANY
COLLIERS PINKARD
COLONlAL-FLORAl FACINATIONS
COLWELL, OSCAR
COME AWAY PLANTATION
ADDRESS 1
POBOX 18451
10833 MONROE ROAD
6239 SETON HOUSE LANE
214 EDITH DR
24674 MIBTY LAKE DRIVE
15711 NORTH STONE DR
7902 THORNDIKE RO
SUBSCRIBER SERVICES
CITY-COUNTY TAX COLLECTOR
44 MONTGOMERY STREET
PO BOX 644
n29 MADISON AVENUE
039V E. CRt::5CENI PK'JVy".
POBOX 751896
ANSHAN MINING CO
POBOX 942857
POBOX 944230
5707 CARTHAGE AVENUE
4735 CARMEL ROAD
4020 YANCY RD.
PO 80XS5699
PO BOX 65699
POBOX 371659
PO BOX 31848
POBOX4307
PO BOX 41601
POBOX 26300
55 WILLIAM STREET
ADMINISTRATIve SERVICES
30 ROCKEFELLER PLAZA
3242 SELWYN AVE.
POBOX2140
130-0 N. MCDOWELL ST.
POBOX 32765
4404-A STUART ANDREW BLVD.
2465 MECKLENBURG AVENUE
3308 OAK LAKE BLVD.
500-E CLANTON RD.
POBOX 16464
322 HAWTHORNE LN.
POBOX 19363
POBOX15594
1730 MATTHEWS TOWNSHIP PKWY.
BOY SCOUTS OF AMERICA
POBOX116
PAYMENT PROCESSING CENTER
POBOX 32247
HONGKONG BANK OF CANADA BLDG.
POBOX6
POBOX 668788
POBOX 151257
330 S. TRYON STREET
725 FRONT ST.
5858-A 1 MONROE ROAD
3739 N. ELAM CHURCH RD.
ADDRESS 2 AODRESS3 C1TY
NEWARK
MATTHEWS
CHARLOTTE
MIDDLETOWN
PONTE VEDRA BEACH
HUNTERSVILLE
GREENSBORO
DEPARTMENT 77940 DETROIT
PO BOX 31577 CHARLOTTE
SAN FRANCISCO
HIGHTSTOVVN
KANSAS CITY
SuiTt: tkJO GREENWOOD VILLAGE
CHARLOTTE
NO. 39, 219 RD ANSHAN, LIAONING
SACRAMENTO
SACRAMENTO
CINCINNATI
CHARLOTTE
CHARLOTTE
CHARLOTTE
CHARlOTTE
PITTSBURGH
RALEIGH
CAROL STREAM
PHILADELPHIA
GREENSBORO
SUITE 210 WELLESLEY
SOUTH CAMPUS POBOX35009 CHARLOTTE
NEW YORK
CHARLOTTE
MARION
CHARLOTTE
CHARLOTTE
CHARLOTTE
CHARlOTTE
SUITE B CHARLOTTE
CHARLOTTE
CHARLOTTE
SUITE 100 CHARLOTTE

WILMINGTON
MATTHEWS
1218 W. ADAMS STREET CHICAGO
GRIMES HILL ROAD WILLIAMSVILLE
POBOX 3208 MILWAUKEE
CHARLOTTE
8JlO.885 W. GEORGIA ST. VANCOUVER
WESTHAMPTON BEACH
CHARLOTTE
CHARLOTTE
SUITE 301 CHARLOTTE
GEORGETOWN
CHARLOTTE
NORWOOD
STATEIPROV
NJ
NC
NC
OH
FL
NC
NC
MI
NC
CA
NJ
Me
CO
NC
CHINA
CA
CA
OH
NC
NC
NC
NC
PA
NC
IL
PA
NC
MA
NC
NY
NC
OH
NC
NC
NC
NC
NC
NC
NC
NC

DE
NC
IL
VT
WI
NC
BC
NY
NC
NC
NC
SC
NC
GA
ZIP
07191
28105
28277
45042
32082
28078
27409
482n-0940
28231-1577
94104
08520
64114
80111-2800
28275-1896
94257-0531
942 ..... 2300
45212-1051
28226-1899
28217
28265-0699
28265-0699
15251
276221848
60197-4307
191011601
27438-6300
0241i2
28235-5009
10112
28209
43306
28204
28232
28217
28205
28208
28217
28208
28204
26219
19886-1304
28105-4658
606072802
05362
53201-3208
28232-2247
C3Hl CANADA
11978
28266
28275-1257
28202
29440-3625
28212
30821
Page 3
cOUNTRY
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VENDOR NAME
COMMERCE BANK, NA 339
COMMERCE CLEARING HOUSE, INC.
COMMUNICATION BRIEFINGS
COMSHARE INC.
CONCHA, MARIO
CONCORD TROPHY CENTER
CONSULATE GENERAL-PERU
CONSULTANTS UNLIMITED
CONTRACT INTERIORS, INC.
CORPORATE EXPRESIONS GROUP
CORPORATE RELOCATION MGT., INC.
COUNTRY PINES FLORIST
CRAB-TREI=.. A.I\INE
CRABTREE, KENT
CREATRIX, INC,
CREDIT RESEARCH FOUNDATION
CROSS, W1LUAM B.
CROW WING TRANSPORT. INC.
GRU INTERNATIONAL
CRU INTERNATONAL, L TO.
CSC
CT CORPORATION SYSTEM
CURTIS. MAlLETPREVOST, COLT &
CUSHMAN, RICHARD
CUSHMAN. ROBERT
CUSHMAN. ROBERT AND JANINA BENOIT
CUSTOM BINDERY & SPECiAlTIES
CUSTOM BOOK BINDERY, INC.
CYBERNETICS
D. E. SHANKS, MD. PA
DATA-A-SYST COMPUTER SERVICES
DAY.TIMERS, INC.
DELAWARE SECRETARY OF STATE
DEWXE BUSINESS FORMS
DEPT. OF INDUSTRIAL RELATIONS
DESIGN/JOE SONDERMAN. INC.
DESTINY COMPUTERS
DHL WORlDWIDE EXPRESS
DIAL FOUR DELIVERY
DIAMOND CHEVROlET-GEO. INC.
DIAMOND GRAPHICS
DIAMOND SPRINGS WATER, INC.
DIGITAL ANALOGUE COMM. SYS. INC.
DIGITEL CORPORATION
DILLION, TIMOTHY J.
DON RICHARD ASSOCIATS
DONNA JERNIGAN PHOTOGRAPHY INC.
DOS SANTOS, DEBORAH M.
DOUGHERTY. RALPH H. PA
DOWDlE, GLENDA F.
DR. DETAIL
DUGAN. JR.. GOERGE B.
DUGAN. RUTHIE
DUKE POWER COMPANY
DUN & BRADSTREET
AODRESS1
1000 WALNUT BB17-8
POBOX 4766
POBOX
33191 TREASURY CENTER
2660 PEACHTREE ROAD, NW
14 CHURCH ST. S.
1700 MASSACHUSETTS AVENUE NW
POBOX 363
POBOX 411105
402 CENTRAL AVE.
6000 ROCKS IDE WOODS BLVD.
1275 FALlS RD.
RJ:;!INTON PL
3949 BRINTON PLACE
270100M HUTCHINSON-MCDONAlD RD
8815 CENTRE PARK DR
12025 DELMAHOY DRIVE
n40 OLD CENTRAL AVE. NE
7474 GREENWAY CENTER DR
31 MOUNT PlEASANT
POBOX 13397
POBoX4349
101 PARK AVENUE
900 BlANTON
64 YORKSHIRE DRIVE
C/O ROBERT A. CUSHMAN
1316 S. TRYON ST.
9 SHERIDAN AVENUE
POBOX 752066
3626 LA TlROBE DR
4200 SOUTH BLVD.
ACCOUNTING DEPARTMENT
DIVISION OF CORPORATIONS
POBOX64500
ACCOUNTING-TIC FUND 096.01
1209 KENILWORTH AVENUE
3480 INVESTMENT BLVD.
PO BOX 78016
PO BOX 32444
8201 SOUTH BOULEVARD
4957 DAYSPRING DR.
POBOX 667887
4827 PARK RD.
2600 SCHOOL DR.
6016 BRATTON PLACE
2650 ONE FIRST UNION CENTER
2519AINSDALE RD
7604 RATHlIN COURT
1515 MOCKINGBIRD LANE
8320 RUSTWOOD PLACE
POBOX 473664
436 PINEWOOD
407 WALNUT AVE
422 S CHURCH ST.
POBOX 75542
GS INDUSTRIES. INC. MASTER CREDITOR LIST
Page 4
KANSAS CITY MO 64106
CHICAGO IL 6068Q.4766
AlEXANDRIA VA 22313-9930
SUITE35A ATLANTA GA 30305-3673
CONCORD NC 28025
WASHINGTON DC 20036
OSAGE BEACH MO 65065
CHARlOTTE NC 28241
KANNAPOUS NC 28081
CLEVELAND OH 44131
ROCKHILL SC 29730
CHARlOTTE NC 28226
CHARLOnE NC 28226
CHARLOTTE NC 28269
COLUMBIA MD 21045-2158
CHARLOTIE NC 28277
FRIDLEY MN 55432
SUITE 820 GREENBELT MD 20770-3504
LONDON WC1XOAD ENGLAND
PHILADELPHIA PA
CAROL STREAM IL 60197-4349
NEWYORK NY 10178-0061
RICHMOND VA 23221
WEXFORD PLANATATION HILTON HEAD SC 29928
64 YORKSHIRE DRIVE WEXFORD PLANTATION HILTON HEAD SC 29928
PO BOX 37308 CHARlOTTE NC 28237-7308
CLIFTON NJ 07011
CHARlOTTE NC 2827&2066
SUITE A CHARLOTTE NC 28209-2635
PO BOX 27001 LEHIGH VALLEY PA 18002-7001
MNB. DEPT. 74072 BALTIMORE MD 21274-4072
ST. PAUL MN 55164-0500
POBOX 420603 SAN FRANCISCO CA 94142-0603
PO BOX 35146 CHARLOTTE NC 28235-5146
HAYWARD CA 94545
PHOENIX 1>2 85062-8016
CHARlOTTE NC 282322444
CHARlOTTE NC 28273
CHARLOTIE NC 28227
CHARLOTTE NC 282fS6..788i-
SUITE 100 CHARLOTTE NC 282Q9.3274
Al1.ANTA GA
CHARLOTTE NC 282n
301 SOUTH COLLEGE STREET CHARLOTTE NC 28202
CHARlOTTE NC 28226
CHARlOTTE NC 28270
CHARlOTTE NC 282n
CHARLOTTE NC 282473664
GEORGETOWN SC 29440
GEORGETOWN SC 29440
CHARLOTTE NC 28242.0001
CHICAGO tL 60675--5542
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VENOQRNAME
DUN & BRADSTREET INFO SERVICES
DURBIN AND ASSOCIATES, INC.
DUSIL. KAROL S.
DXI,INC.
E&S SECURITY & LOCK SMITH
E&Y CAPITAL ADVISORS LLC
EARTHLINK. INC.
EDS CORPORATION
EDWARDS, DAVID C.
EDWARDS. DMD. JAMES B.
EEOC
EHMKElCINCINNA TI MOVERS, INC.
ADDRESS 1
PO BOX 92542
PO BOX 85
ClO MOLY.(;OP CANADA
p OBQX 23617
PO BOX 11906
SUITE 2BOO
POBOX 7645
PO BOX 14947
n12 N. DERBY RD.
100 VENNING ST
5500 CENTRAL AVENUE
9770 INTER OCEAN OR
SU:::CA."4cr: . ~ ~ .. GLOaM 5Hj 5. fiFTH STREET
ELLlOTI', JACK POBOX 274
EMPLOYMENT SECURITY COMMISSION OF POBOX 26504
EQUALNET POBOX 641379
EROLE. GARRElT W 138 CHEROKEE ROAD #2
ERNST & YOUNG LLP BANK OF AMERICA-GHIC 96907
ESIS. INC. POBOX 65()0..1060
ESSIE'S DELI & CATERING. INC 1509 EBENEZER RD.
ESSIG. MARK G. 2441 LEMON TREE LANE
EULER ACt 5500 EXECUTIVE CENTER DR.
EUSTIS ENGINEERING CO . INC. 3011 28TH STREET
EXECUTIVE CAR SERVICES POBOX 4123
exECUTlVE COACH SERVICE 1100 JETPORT RD.
EXECUTIVE ENTERPRISES POBOX 530683
EXECunVE JET CHARTER SER INC. HINGHAM CORPORATE CENTER
EXECUTRA1N ENTERPRISES. INC. POBOX 100158
EXXONIGECC POBOX 9710
FAIRFIELD GlADE COMMUNITY CH. 521 SNEAO DR
FASTFRAME 4724-K SHARON RD.
FCIB-NACM CORPORATION WOODBRIDGE CORP. PLAZA
FEDERAl. EXPRESS CORPORATION POBOX 1140
FEDEX PO BOX 1140
FENNEBRESQUE. CLARK, SWINDELL & 100 N. TRYON ST.
FETTERMAN, HALSELL 1500 PUGET SOUND PLAZA
FIDELIlY INSTITUTIONAL OPS CO POBOX 73307
FIDELIlY LEASING. INC. POBOX 8500-9805
FIEHLER & ASSOCIATS, INC. 7376 WETHERINGTON
FINANCIAL EXECUTIVES INSTITUTE POBOX 10408
FINANCiAl STRATEGIES CON. GRP. 3650 Mr. DIABLO BLVD.
FINANCIAL TIMES ENERGY POBOX 9188
FINE INTERIORS DESIGN 2910 SELWYN AVENUE
FINOVA CAPITAL CORPORATION 95 ROUTE 17 SOlJTH
FIRE EQUIPMENT SALES. INC. POBOX 9382
FIRETHORNE COUNTRY CLUB 1108 FlRETHORNE CLUB OR.
FIRST COMMUNITY INSURANCE CO. POBOX 31607
FIRST NATIONAL BANK OF CHICAGO SUITE 0236
FIRST UNION BANK OF NC CAPITAL MANAGEMENT GROUP
FIRST UNION NATIONAL BANK DEFINED CONTRIBUTION SERVICES
FIRST UNION NATIONAL BANK P a BOX 60304
FIRST UNION NATIONAL BANK VEHICLE LEASING DEPT.
F1RSTAR POBOX 742560
FLEET NATIONAL BANK CORP. TRUST ADMIN. CT OP 0238
FLINT, DENNIS F ONE SARAZEN STREET
GS.INDUSTRlES.INC. MASTER CREDITOR LIST Page 5-
HAMILTON OH 45012
8425 EAST TRANS CANADA KAMLOOP$ B.C CANADA V2C8B7
PITTSBURGH PA 15222-6617
ROCKHILL sc 29731
600 PEACHTREE ST. ATLANTA GA 303Q8.2215
ATLANTA GA 30357..()645
ST. LOUIS MO 63150-4941
PEORIA IL 61615
MOUNT PLEASANT sc 29464
CHARLOTTE NC 28212
CINCINNATI OH 51387
MCCLENNY FL 32063
I
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ANDREWS sc 2951().()274
RALEIGH NC 27611-6504
DETROIT MI 48264-1379
CHARLOTTE NC 28207
PO BOX 96907 CHICAGO IL 60693
PHILADELPHIA PA 1917&-1060
ROCKHILL sc 20732
CHARLOTTE NC 28211
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SUITE 231 CHARLOTTE NC 28212
METAIRIE LA 70002
CHARLOTTE NC 28226
MYRTLE BEACH sc 29577
ATLANTA GA 3(l363-0683
72 SHARP ST. A-8 HINGHAM MA 02043
ATlANTA GA 30384-0758 I
MACON GA 31297"9710
CROSVllLE TN 38558
CHARLOTTE NC 28210
485-A ROUTE 1 S SUITE 100 ISELIN NJ 08B3Q.3009
OEPT.A MEMPHIS TN 38101-1140
MEMPHIS TN 38101-1140
SUITE 2900 CHARLOTTE NC 28202-4011
1325 FOURTH AVE. SEATTLE WA 96101-2509
PHIlADELPHIA PA 19178-9805
WEST CHESTER OH 45<l69
NEWARK NJ 07193-0408
SUITE 210_ LAFAYETTL CA_ 9454!!. _
ARLINGTON VA =19-9900
#112 CHARLOTTE NC 28209
PARAMUS NJ 07653
CHARLOTTE NC 28299
WAXHAW NC 28173
TAMPA FL 33631-3607
PO BOX 20089
CHARLOnE NC 28202"(){)27
1525 w. W. T. HARRIS BLVO. 3C5 CHARLOTTE NC 28288-1176
PO BOX 96002 CHARlOnE NC 2829&0002
CINCINNATI OH 45274--2560
777MAINST HARTFORD CT 06115
SARA TOGA SPRINGS NY 12860
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VENOORNAME
FLOREZ. JUAN G.
FLORIDA WIRE AND CABLE CO. INC.
FORBES
FORBES TEMPORARY STAFFING
FORD MOTOR CREDIT COMPANY
FORTUNE
FRANCHISE TAX BOARD
FRANKLIN COVEY CO
FRANKLIN'S SOUTHPARK
FUNS VEHICLE LEASING DEPT.
G. WILLIAM MILLER CO., INC.
GADSBY HANNAH. LLF
GALVA-COR !NC
GATEWOOD
GENERAL BINDING CORPORATION
GENERAL ELECTRIC CAPITAL
CORPORATION
GEO CAprrAL CORPORATION'
GEORGETOWN STEEL CORPORATION
GEORGETOWN TIMES
GIDE LOYRETTE NOUEL
GILLESPIE. NANCY M.
GIRTON. JAMES F.
GLOBE CORPORATE STAY INT'L
GLOBEICORPORATE STAY INTL.
GMAC
GOLDMAN. SACHS & CO.
GOLLER. GEORGE A
GOODRICH, RIQUELME & ASOCIADQS
GOODWIN, PROCTER & HOAR
GOULD-KREUTZER ASSOCIATES, INC.
GRAEBEl COMPANIES
GRAEBEL NORTH CAROLINA MOVERS
GRAEBElJDENVER MOVERS, INC
GRAEBELIKANSAS CITY MOVERS INC
GREAT PLAINS SOFTWARE
GST STEEL COMPANY
GTE NORTH
GUARANTEED PERSONNEL SERVICES
HAAS, JAMES D., AND DANIEL J. HAAS.
HAAS. JAMES E.
HAAS. JAMES E.
HAAS. ROBERT J . DANIEL J. HAAS. AND
HALF. ROBERT
HALLBROOK FARMS HOMES ASSO.
HALLBROOK REALTY
HAMPTON INN GEORGETOWN
HARCOURT BRACE
HARE & CO . (NOMINEE HOLDER FOR THE
HAROLD HINSON PHOTOGRAPHY
HARRISON. MICHAEL
HART PAINTING COMPANY INC.
HARVARD BUSINESS REVIEW
HAYNES LOGISTICS CONSULTING
HAYNES, STEVEN
. ADDRESS 1
8251 GOLD RIDGE DRIVE
825 N LANE AVE
POBOX 5469
6401 CARMEL ROAD
POBOX 105332
POBOX61420
STATE OF CALIFORNIA
POBOX31456
6631 MORRISON BLVD.
POBOX 96020
1215 19TH STREET. NW
225 FRANKLIN ST.
SOUL. OUEST
P o BOX 7822
POBOX 71361
COMMERCIAL FINANCE
600 COLLEGE ST.
420 SOUTH HAZARD ST
POBOXG
SWISS BANK TOWER
3333 LAKE WYLIE DRIVE
6536 HARNESSWOOD CT.
5400 R WEST wr. HARRIS BLVD.
POBOX631987
POBOX30788
POBOX9080
11443 FOXHAVEN DRIVE
PASEO DE LA REFORMA 265
EXCHANGE PLACE
125 CAMBRIDGE PARK DR
PO BOX 8002
2901 STEWART CREEK BLVD.
401 S. AIRPORT BLVD.
9755 COMMERCE PKWY.
POBOX9739
7000 ROBERTS ST.
POBOX 920041
5970 FAIRVIEW RD
C/O JAMES E. HAAS
158 HIGHLAND DRIVE
POBOX95
C/O JAMES E. HAAS
FilE 73484
PO BOX 7206
2000 W. 111TH ST ..
420 MARINA DR
POBOX 620075
C/O STACEY LOGAN, ASSOCIATE
PO BOX 671
1124 S. MINT ST
41Q9.B STUART ANDREW BLVD.
SUBSCRIPTION SERVICE DEPT.
7295 WETHERSFIELD DR
7295 WETHERSFIELD OR.
GS.INDUSTRJES, INC. MASTER CREDITOR LIST Page 6
cHARLOTTE NC 28209
JACKSONVILLE FL 32254
HARLAN IA 51593-4969
SUITE 107 CHARLOnE NC 28226
ATLANTA GA 30J4S.5332
TAMPA FL 33661
POBOX 942657 SACRAMENTO CA 94257-0511
SALT LAKE CITY UT 84131..()456
CHARLOTTE NC 28211
CHARLOTTE MC 28296-0020
WASHINGTON DC 20036
BOSTON MA 0211002811
QUEBEC G2K 2..IT CAN_A.DA
I
CHARLonE NC 28241
10 SOUTH LASALLE ST.-
ATTN: BRAD SEAMAN SUITE 2700 CHICAGO IL 60603
surre 1300 CHARLOTTE NC 28202
GEORGETOWN SC 29440
GEORGETOWN SC 29442
10 E. 50TH ST. NY 10022
ROCKHILL SC 29732
MASON OH 45040
CHARLOTTE NC 28269
CINCINNATI OH 45263-1987
CHARLOTTE NC 28230
GPO NEWYORK NY 10887-9080
CHARLOTTE NC 282n
06500 MEXICO OF MEXICO
BOSTON MA 02109-2881
CAMBRIDGE MA 02140
WAUSAU WI 54402-8002
CHARLOTTE NC 28216
AURORA CO 80017
LENEXA KS 66219
FARGO ND 58109
KANSASCrrY MO 64125
DALLAS TX 75392-0041
158 HIGHLAND DRIVE JAMESTOWN RI 02835
JAMESTOWtl
RI _ 02835 _
JAMESTOWN RI 02835
158 HIGHLAND DRIVE JAMESTOWN RI 02835
POBQX6000 SAN FRANCISCO CA 94160-3484
LEAWOOD KS 66207
LEAWOOD KS 66211
GEORGETOWN SC 29440
J.P. MORGAN INVESTMENT
ORLANOO FL 32862-0075
522 FIFTH AVENUE NY 10036
CONCORD NC 28026-0671
SUOIDA CHARLOTTE NC 28203
CHARLOTTE NC 28217
POBOX52622 BOULDER CO 803212622
WEST CHESTER OH 45069
WEST CHESTER OH 45069
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VENDOR NAME
HEIDRICK & STRUGGLES. INC.
HENLEY PAPER COMPANY
HERBST, JOHN A
HERlZ SYSTEM INC.
HIGHPOINT AMERICA, INC
HILTON INN
HODGE'S ELECTRIC SERVICE, INC.
HOFFMAN, WILSON
HOL1..EY,RAY
HOLZWORTH. RICHARD C.
HORAK. ROBIN R.
HOTEL & TRAVEL INDEX
............ -... ----.. -. .. ...
nvol'VU.J DI"'iV,> C. ... C .... \.AI IN .....
HUBERT, UNDA-MARIE
HUSELTON, BENJAMIN C
HUSEL TON. KAAREN S.
HUTSON, MICHAEL
ICC PUBLISHING, INC.
IKON OFFICE SOLUTIONS
ILLINOIS CENTRAL
ILLINOIS SECRETARY OF STATE
INAC CORPORATION
INOUCTOHEA T
INFOVISION, INC.
INGRAM'S
INSIGHT
INSTITUTIONAl INVESTOR. INC.
INSURANCE CO. OF NORTH AMERICA
INTERNAL REVENUE SERVCE CENTER
INTERNAL REVENUE SERVICE
INTERNATIONAL BUSINESS DIRECT. EDe
INTERNATIONAL COPPER STUDY GR.
INTERNATIONAL MANAGERS LIMITED'"
ADDRESS 1
POBOX92227
P 0 DRAWER 820
P. O. BOX 2568
POBOX 25485
4945 NORTHPARK
6200 QUARRY LN.
POBOX 1937
1312 ENFIELD CT.
3S53 SHARON AMITY RD.
1310 SOCTLANO AVENUE
7911 FAIRMEADOWS DRIVE
POBOX7655
? 0 eox 240052
10801 WHITFIELD RIDGE DRIVE
30 OYSTER REEF DRIVE
CJO BENJAMIN C. HUSELTON
PRESIDENT
156 5TH AVENue
POBOX 100238
455 NORTH CITY FRONT PlAZA
JESSE WHITE, SEC. OF STATE
1601 CHESTNUT ST.
32251 N. AVIS DR.
723 S. SHARON AMITY ROAD
306 E. 12TH STREET
POBOX 78825
488 MADISON AVE.
POBOX 1524
POBOX509
RUA ALMIRANTEBARROSO
P.O.BOX309
(a) Franoesco M. Balbi
(b) John M. Banollhel
(e) VlcIcr A. carrion
(d) Gonzalo Gald",
(e) Roger A. Gaot
IRI 85 WOODlAND ST.
IRON AGE POBOX 7695
IRON MOUNTAIN POBOx 65017
IVAN ALLEN COMPANY POBOX 1712
J. A. HERBST & ASSOCIATES, LLC POBOX 2568
J. P. MORGAN & CO.. INC. 227 W. MONROE ST.
JASSY LIMO SERVICE 7937 SHADY OAK TR
JAYCEE lEADER POBOX 560703
JE.AN.MICHEL 312 N. POLK ST.
JENKINS COFFEE SERVICES. INC POBOX 5321
JENNY CARROLL SPANISH BUSINESS SRVC362 TALL OAKS TRAIL
JOHN H. RUMBARGER, P.E .. INC. POBOX 691
JOHN LONGFELLOW & ASSOCIATES 537 ELDERBERRY SE
JOHNSON & HIGGINS CAROLINAS pOBOX 905226
JOHNSON. GEORGE T. 9716 N COMMONS EAST DRIVE
JOSSEY-BASS, INC. 350 SANSOME ST.
KANSAS CITY BUSINESS JOURNAL 1101 WALNUT ST.
GS INDUSTRIES, INC, MASTER CREDITOR LIST
ADDRESS 2 ADDRESS 3 CITY
CHICAGO
GREENSBORO
KEALAl<EKUA
OKLAHOMA CITY
COLORDAO SPRINGS
INDEPENDENCE
DARLINGTON
BRIOGEFIELO
STE 101 CHARLOTTE
CHARLOTTE
CHARLOTTE
RIVERTON
CHAALO""i""TE
CHARLOTTE
HILTON HEAD
30 OYSTER REEF DRIVE HILTON HEAD
JOHN HUTSON COMPANY 3900 WINDWOOD CIR. CHARLOTTE
NEW YORK
COLUMBIA
CHICAGO
DEPT. OF BUSINESS SERVICES SPRINGFIELD
TL18D PHILADELPHIA
MADISON HEIGHTS
CHARLOTTE
10TH FLOOR KANSASCrTY
PHOENIX
NEW YORK
RICHMOND
MEMPHIS
ATLANTA
WESTHAVEN
38-6ANDAR 1000-013 LISBON
ATTN: PRESIDENT GEORGETOWN
cio GSI Lucchini SpA Dlvale della Resistenza 57025 Piombino
Has NieVes 3313 Dpto. 901 Vo1acura Santiago
co MoIy-Cop Chile S.A. Awa. Pedro de Vakiivia 0168 Providencia, Santiago
226 San Botje Norte lima
c10 GST Europe, Ltd. Intertrac House 104 High S1reet, Tring
PO BOX S010 HARTFORD
RIVERTON
CHARLOTtE.
ATLANTA
KEALAKEKUA
CHICAGO
#25 CHARLOTTE
CHARlOTTE
PINEVILLE
KNOXVILLE
FORTMIU
123 POPLAR AVE. WAYNE
DEMOTTE
CHARLOTTE
CHARLOTTE
SAN FRANCISCO
SUITE 800 KANSAS CITY
Page 7
IL 60675-4590
NC 27402...()820
HI 96750-2568
OK 7312!Hl485
CO 80918
OH 44131
SC 29532
PA 15017
NC 28205
NC 28207
NC 28269
NJ 08077--8955
j"C 20224
NC 282n
SC 29926
SC 29926
NC 28226
NY 10010
SC 29202-3238
IL 60611..55()4
IL 62759
PA 19103
MI
NC 28211
MO 64106--2424
A2 85062-8825
NY 10022
IN 47375-1524
TN 37501-0006
GA 39901
CT 06516
PORTUGAl
GRAND CAYMAN ISLANOSW. INDIES
llaly
Chile
Chile
Peru PE41
Hertfordshire England
CT 06102-5010
NJ O6On-7695
NC_ 28265-0017_
GA 303011712
HI 9675()-.2568
IL 60606
NC 28210
NC 28256
NC 28134
TN 37928
SC 29715
PA 19087
IN 46310
NC 28290--5226
NC 282n
CA 94104
MO 64106-2122
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216101
VENDOR NAME ADDRESS 1
KEATING. MUETHING & KLEKAMP 1800 PROVIDENT TOWER
KEFFER JEEP..cHRVSLER 8110 E.INDEPENDENCE BLVD.
KENNECOTT UTAH COPPER CORPORATrON:lO RAYMOND J. ETCHEVERRY
KEYSTONE LEARNING SYSTEMS CORP. 2241 LARSEN PARKWAY
KIRKLAND & ELLtS 2CO EAST RANDOLPH DRIVE
KITSON, DOUG 4520 RICHMOND HLL DR.
KLAIBER, DAVID P. 1901 STEEL RD.
K-LATH 13470 PHILADELPHIA AVE
KLETT ROONEY LIEBER & SC>IORLIN 40TH FLOOR
KOCH,PETER KAlSER-WiLHEILM-STRASSE 12
KOKJER KIRCHER BOWMAN & JOHNSON 2414 COMMERCE TOWER
KORNIFERRY INTERNATIONAL DEPT. DEPT. CH10226
KPMG PFAT MAf1JWIGK. TWO FJRST U!'!:DN C E ~ . r r : : R
KYOCERA MITA AMERICA, INC. POBOX 740423
LA BIBLIOTHEQUE 1901 ROXBOROUGH RD.
LANCTO, MARK 678 CARNER DR
LANDSTAR IN'NAY, INC. 135 S. LASALLE
LANGUAGE MASTERS, INC. 29777 TELEGRAPH ROAD
LANIER WORLDWIDE, INC. POBOX 105533
LANOLQGY 6150 RICHMOND AVE.
LAPHAMJIAILLER ASSOCIATES 34 ESSEX STREET
LASERPRlNT SERVICE, INC. 224 WESTINGHOUSE
LATHROP S GAGE 2345 GRAND BLVD.
LATIN AMERICAN INFORM6.TION 159W. 53RO STREET
LEAK. J. COUNCILL 4237 TOTIENHAM ROAD
LEGGETT & PLATT INCORPORATED ATTN, FELIX E. WRIGHT
LEMLE & KELLEHER 601 PAYDRAS STREET
LEON, LUIS E. 7016 TURNING POINT lANE
LEXUS FINANCIAL SERVICES POBOX 17187
LIFE INS. CO. OF NORTH AMERICA PO BOX 85()().5()4.5
L1NOAJ. GILUNOV & ASO . INC. 221) BASSWOOD LN.
LINGUA INTERNATIONAL PO BOX 15646
LITCHFIELD BEACH & GOLF RESORT P 0 DRAWER 320
LOCKER ASSOCIATES, INC. 225 BROADWAY
LOCKTON POBOX 419263
LOCKWOOD GREENE PO BOX 60287
LUTZ, KARL E. KIRKLAND & ELLIS
LUZZI. RICHARD D. 14281 NOLEN LANE
LYON & LYON THIRTY-FOURTH FLOOR
MAC PAPERS POBOX 601004
MACDONALD, MONA 6640 W1LKlNS AVE.
MACTHRIFT OFFICE FURNITURE PO BOX 49009
MAKOUS, STACIE 8100 slDRAS COURT
MANCHESTER, INC. 2BALA PLAZA
MANUFACTURERS AllIANCE, INC. 1525 WILSON BLVD.
MARCO ISLAND YACHT CLUB DRAWER 697 .
MARQUIS WHO'S WHO 121 CHANLON ROAD
MASET,RICK 1708 NANTUCKETT LANE
MASSACHUSETTS MUTUAL LIFE INC. 1295 STATE STREET
MATTHEW BENDER & CO .. INC. POBOX22030
McAVOY, MARY BETH 138224( QUEENS HARBOR ROAD
McCOY, HALINA CREVELING 920 LOUISIANA
MCGLADREY & PULLEN 1 MORROCROFT CENTRE
Mel WORLOCOM CONFERENCING PO BOX 70129
MCMAHAN, EDWARD M 917 WESTERN AMERICA CIR.
GS INDUSTRIES, INC. MASTER CREDITOR UST Page 8
1 E. FOURTH ST. CINCINNATI OH 45202
CHARLOTTE Ne 28227
PARSONS BEHLE & LATIMER P.O. BOX 4589B SAlT LAKE CITY UT 84145-0898
PROVO UT 84606
CHICAGO IL 60601
MURRELLS INLET SC 2S576
ASHLAND KY 41102
FONTANA CA 92335
1 OXFORD CENTRE PITTSBURG PA 15219-2088
76530 BADEN-BADEN GERMANY
911 MAIN STREET KANSAS CITY MO 64105-2088
PALATINE IL 60055-0228
SU:tt2W\l CHARLurl!: NC 28202
SUIlE 200 CHARLOTTE NC 28211
PENSACOLA FL 32506
DEPT. 1272 CHICAGO IL 60674-1272
SUITE 1670 SOUTHFIELD MI 48034
SUI11,204 HOUSTON TX nOS7
ANDOVER MA 01810
SUITE 2_ KANSAS CITY MO 641()8..2612
NEWYDRK NY 10019-6050
CHARLOTTE NC 28226
NO. 1 LEGGETT ROAD CARTHAGE MO 64836
21ST FLOOR NEW ORLEANS LA 7013(}-6Q97
CHARLOTTE NC 28277
BALTIMORE MD 21297..0511
PHILADELPHIA PA 19178-5045
MORElAND HILLS OH 44022
PITTSBURG PA 15244
PAWLEYS ISLAND SC 29585
SUITE 2525 NEW YORK NY 10007
KANSAS CITY MO 64193-1330
CHARLOTTE NC 28260
200 EAST RANDOLPH DRIVE CHICAGO IL 60601
CHARLOTTE NC 28277
611 WEST SIXTH STREET LOS ANGELES CA 90017
CHARLOTTE NC 2826().1004
PITTSBURG PA 15217
-
GREENSBORO NC 27419
CHARLOTTE NC 28270
SUITE 801 BALACYNWYD PA 19004
SUITE 900 ARliNGTON VA 22209-2411
POBOX 11407 BIRMINGHAM AL '5246
NEW PROVIDENCE NJ 07974
SUITE 2CO CHARLOTTE NC 28270
SPRINGFIELD MA 011113000
ALBANY NY 12201-2030
CHARLOTTE NC 28278
LA.WRENCE KS 66044
6805 MARRESON BLVD. CHARLOTTE NC 28211-9711
SUITE 400 MOBILE AL 36609
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VENOORNAME
MCMILLAN SINCH
MCNAIR LAW FIRM, PA
MECKLENBURG MEDICAL GROUP
MELGAR & ORTIZ CONS.JURIDICOS
MER PERSONNEL SERVICES. INC.
MERCEDES-BENZ CREDIT CoRP
MERIMS. MICHAEL
METAL BULLETIN. INC.
METROGRAPHICS
MICRON COMM. COMPlJTER SYS. INC.
MICRON GOV. COMPUTER SYSTEMS
MICRON LEASING
MICRON LEASING
MICROSOFT MA.GAZINE
M1CROWQRLDS
MJDREX DIRECT PRODUCTION CORP.
MII..LENNJUM TECHNOlOGY CORP
MILLER & ASSOCIATES INT'L
MILLER MCNEISH & BREEDLOVE PA
MILLER SERVICES. INC.
MIllER. G. WILLIAM
MILLER. JAMES E.
MILLER. JAMES H.
MILLWRIGHT SERVICE OF FLORENCE
MISSOURI CHAMBER OF COMMERCE
MISSOURI DEPT. OF REVENUE
MITCHELL KEARNEY PHOTOGRAPHY
MN DEPARTMENT OF REVENUE
MN SECRETARY OF STATE
MNP CORPORATION
MOLY..cOP CANADA
MOORE
MOORE & VAN ALLEN, PLLC
MOORE NORTH AMERICA. INC.
MOREHEAD ASSOCIATES. INC.
MORGAN GUARANTY TRUST CO.
MORRIS. WILLIAM P.
MQRRI5-SHEA BRIDGE CO . INC.
MULHAUSER, RoNALD S.
MURPHY. ANTHONY W.
N. MEeK. FAMILY PRACTICE GROUP
NAllE CLINIC
NAT. ASSN. OF MANUFACTURERS
NATIONAL CAR RENTAL SYSTEM. INC
NATIONAL INFO. DATA CENTER
NC DEPT of REVENUE
Ne DEPT OF REVENUE
NC DIVISION OF MOTOR VEHICLES
NC SECRETARY OF STATE
NC WORLD TRADE ASSOCIATION
NEAL. PATRICIA T.
"'ELSON INFORMATON. INC.
NENNI. REBECCA B. AND HER
NETCOM oN-lINE COMMUNICATIONS
NETWORK SOLUTIONS. INC.
ADDRESS 1
SOUTH TOWER
NATIONSBANK TOWER
335 RANDOLPH RD.
VITO ALESSIO ROBLES 240
6525 MoRRISoN BLVD.
PoBOX 100152
PoBOX 836
220 5TH AVENUE
1119 CLEMENT AVE.
PO BOX 94172
PoBoX 94170
LEASE ADMINISTRATION CENTER
POBOX605
POBOX 1161
125 CAMBRIDGE PARK DR
2100 CHARloTTE PLAZA
15890 SW CARDtNAL LOOP
POBOX 471933
301 s. MCDOWELL ST.
100 E. PARK AVE.
1215 19TH STREET. NW
32 SKIPPER LANE
2148 ROLSTON DR
POBOX727
PoBOX 149
seCRETARY OF STATE
515W. 4TH STREET
MAIL STATION 1250
100 STATE OFFICE BlDG.
ATIN: LORI MAZUR
8425 E. TRANS CANADA HWY
PO BOX 6147
PO BOX 65045
POBOXB1.7
5200 PARK RD.
CORPORATE ACCOUNTS RECEIVABLE
2 OLD NURSERY LAND
1820 1ST AVE.. SOUTH
18916 RIVER WIND LANE
102 RIVER WOOD DRIVE
407 GILEAD RO.
1918 RANDOLPH RD.
1331 PENNSYLVANIA AVE., NW
PO BOX 200
PO BOX 96523
WlTHHOLOING SECTION
POBOX 25000
1100 NEW BERN AVENUE
ANNUAL REPORT SECTION
4425 RANDOLPH RD.
710 SHARVIEW CR
1 GATEWAY PlAZA
C/O REBECCA B. NENNI
DEPT. LA 21323
POBOX 17305
GS INDUSTRIES, INC. MASTER CREDITOR LIST
ADDRESS 2 ADDRESS 3
SUITE 3800 ROYAL BANK PlAZA
PO BOX 11390
SUITE 100
COL FLORIDA SUR. CP 01030
SUITE 107
10TH FLOOR
POBOX
SUITE 100
PO BOX 36407
FRANCHISE TAX DIVISioN POBOX 136s
100 CONSTITUTION AVE.
44225 UTICA RD.
POBOX3040
SUITE 213
23 WALL STREET
SUITEL
PO BOX 681
POBOX29504
DEPT 1
PO BOX 29525
SUITE 304
PoBoX 591
1104 COUNTRY CLUB DRIVE
CITY
TORONTo
COLUMBIA
CHARLoTTE
MEXICO
CHARLOnE
ATLANTA
PINEVILLE
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CHICAGO
CHICAGO
PITTSBURG
MOBERLY
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CAMBRIDGE
CHARLOTTE
BEAVERTON
CHARLoTTE
CHARLoTTE
CHARLOTTE
WASHINGTON
SALEM
CHARLOTTE
FLORENCE
JEFFERSON CITY
JEFFERSON CITY
CHARlOTTE
ST. PAUL
ST. PAUL
UTICA
KAMLOOPS
CAROL STREAM
CHARLOTTE
CAROL STREAM
CHARLOTTE
NEW YORK
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MINNEAPOLIS
WASHINGTON
RALEIGH
RALEIGH
RALEIGH
RALEIGH
CHARLOTTE
CHARLOTTE
PORT CHESTER
NEWBERN
PASADENA
BAlTIMORE
Page 9
ON 5J 2J7 CANADA
SC 29211
NC 28211
OF MEXICO
NC 28211
GA 3038<Hl152.
NC 28134
NY 10001
NC 28205-3401
IL B0690
IL 0000&0690
PA 15250-7992
1.10 65270
IL tKK06-il:)fu
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NC 00002-8244
OR 97007
NC 28247
NC 28204
NC 2823
DC 2003
NC 29676
NC 28207
SC 29502
MO 000<J6.5102
MO 65102M1366
NC 28202
MN 55145-1250
MN 55155-1299
MI 48317
Be C 667 CANADA
IL 60197-6147
NC 28265-0045
IL 60197--6147
NC
NY 10260-0023
FL 32063
AL 3521(}-1533
NC 2803
SC 29715
NC 28070
NC 00002-8207--
DC
MN 55440-0280
DC 20090-6523
NC 27626
NC 27640
NC 27697"()OO1
NC 27626-0525
NC 28211
NC 28217
NY 10573
NC 28562
CA 91185-1323
MO 212970525
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VENDOR NAME
NEW HORIZONS
NEWPORT MARRIOTT
NEWSWEEK
NEWSlCPRESS
NODES, HENRY A
NORMAN AUDIOVISUAL
NORTH AMER. CO. FOR UFE/HEAL TH
NORTH AMERICAN VAN LINES
NORTH LIGHT PHOTOGRAPHY
OAG BUSINESS TRAVEL PlANNERS
OAG N AMERICAN EDITION
OAG POCKET FLIGHT GUIDE NA
OAG ..;nE CDiTfON
OERTEL. JOHN N.
OFFICE DEPOT
OFFICE DEPOT CREDIT PLAN
OFFICE FURNITURE USA
OFFICE TEAM
OFFICIAL AIRLINE GUIDES
OGLETREE, DEAKINS.NASH. SMOAK &
O'HAGAN, SMITH & AMUNDSEN, LLC
O'HARE HILTON
OLSTEN STAFFING SERVICES. INC.
O'MALLEY, JOHN J.
OMNI ARCHITECTURE
ORIGlIA, G. JERRY
ORION FINANCIAlS
PA. ASSO. OF CREDIT MANAGEMENT
PA. DEPT. OF REVENUE
PAINE WEBBER, INC.
PAN AMERICAN LIFE INS. co.
PAN AMERICAN LIFE INS. CO.
PANORAMlC VISIONS, INC.
PARKER, POE ADAMS & BERNSTEIN
PARKER. POE ADAMS & BERNSTEIN
PARKER, POE ADAMS & BERNSTEIN
PASSPORT SERVICES
PAUL B. WILLIAMS, INC.
PAUL R. STEWART. P .E.
PAWLEY'S PLANTATlON
PAYNE, SMAUEL N. P.E.
PENN MUTUAl liFE INSURANCE CO.
PENSION BENEFIT GUARANTY CORP.
PENTAGON FREIGHT SERVICES, INC.
PEPPER HAMILTON LLP
PEPSI COL BOTTLING CO.
PERFORMANCE SYSTEMS CORP.
PETERSEN, LORRETTA J.
PHILLIPS 66 COMPANY
PIEDMONT BUSINESS EQUIPMENT
PINPOINT CAREER CONSULTANTS
PITNEY BOWES CREDIT CORP
PITNEY BOWES INC
PlAZA APPLIANCE SERVICE co.
PNC BANK TREASURY MANAGEMENT
ADDRESS 1
9140 ARROWPOINT BLVD
25 AMERICA'S CUP AVE.
POBOX 424
1212 ANGIER AVE
339 EGRET CIRCLE
912 CENTRAL AVE.
221 SOUTH RIVERSIDE PLAZA
P a BOX 75641
510 KELFORO LN.
POBOX 55666
PO BOX 56741
POBQX56742
P060X575io
118 SOUTH 5TH STREET
22 OLD GERMAN TOWN ROAD
POBOX 182378
1128 FREELAND LN.
POBOX 6248
P a BOX 710412
POBOX 101660
150 N. MICHIGAN AVE
PO BOX 92681
DEPT AT. 49923
MANAGING DIRECTOR
INDEPENDENCE CENTER
1615 VIA ROMERO LANE
POBOX 1157
3737 LIBRARY RD.
DEPT. 280425
RE: WORLD STEEL DYNAMICS
GROUP PREMIUM ACCOUNTING
2200 PARKlAKE ORIVE,NE
2465-J23 CENTERVillE RD
POBOX 1509
THREE FIRST UNION CENTER
101 w. ST. JOHN ST.
NATIONAL PASSPORT CENTER
1035 WINSTON ST.
1400 PAR CAUSEWAY
70 TANGLEWOOD DR.
6017 CORSTONE DR
INDEPENDENCE SQUARE
POBOX 64880
PO BOX 67167
ACCOUNTING DEPT.
2820 S. BLVD
2925 LBJ FREEWAY
13633 QUIXlEY lANE
CREDIT CARD CENTER
SUITE 101
POBOX 1403
PO BOX B5460
pO BOX 856390
9744 IDLEWilD RD
KEARNEY, D. MAll STOP F5F012062
GS. INDUSTRIES, INC. MASTER CREDITOR LIST Page 10
ADDRESS 2 ADDRESS 3 CITY STATEIPROY ZIP COUNTRY
SUITE 220 CHARLOTTE NC 00002-8273
NEWPORT RI 02840
LIVINGSTON NJ 07039-9947
DURHAM NC 27701
GEORGETOWN SC 29440
CHARLOTTlE NC 28204
CHICAGO IL 60606
CHARLOTTlE NC 28275
CHARLOTTE NC 28270
BOULDER CO
BOULDER CO 80231--6741
NORTH AMERICAN EDITION BOULDER CO 80231-{i742
BOULDER CO 80322-7518
STillWATER MN 55082
DELRAY BEACH FL 33445
COLUMBUS OH 43218-2378
CHARLOTTlE NC 28217
CAROL SIREAM IL 60197--6248
CHICAGO IL 60694
SUITE 3300 CHICAGO IL 60601
CHICAGO IL 6067!;-2681
ATLANTA GA 311929923
AUDAX VENTURES 101 HUNTINGTON AVENUE BOSTON MA 02199
CHARLOTTlE NC 28246
ALAMO CA 94507
BURLINGTON CT 06013
PITTSBURG PA 1523+2285
HARRISBURG PA 17128-2285
1285 AVENUE OF Tlfl;: AMERICAS NEWYORJ( NY 10019
PO BOX 62673 NEW ORLEANS LA 70162
SUITE 140 ATLANTA GA 30345
HERNDON VA 20171
COLUMBIA SC 282021509
401 S. TRYON ST. SUITE 3000 CHARLOTTE NC 28202
SPARTANBURG SC 29306
PO BOX 371971 PITTSBURG PA 15250-7971
GREENSBORO NC 27405
ALLENTOWN PA 18106
PAWLEY'S ISLAND SC 29585
CHARLOTTE NC 28227
PHILADEPHIA PA 19172
HOUSTON TX 77267-1767
3000 lWO LOGAN SQ. PHILADELPHIA PA 19103-2799
SUITE 201 DALLAS TX 75234-7614
CHARLOTTE NC 28273
BARTLESVilLE OK 74189-4159
5237 AlBERMARLE RD. CHARLOTTE NC 28212
KERNERSVILLE NC 27235
LOUISVILLE KY 40285-5460
LOUISVILLE KY 40285-6390
CHARlOnE NC 28227
PHILADEPHIA PA 19110
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VENDOR NAME
POSITIVE IMAGES OF CHARLOTTE
POSITIVE SYSTEMS, INC.
POSPISIL. TOBIN
POSTAGE BY PHONE SYSTEM
PRACTITIONERS PUBLISHING CO.
PREMIER TECHNOLOGY GROUP. LLC
PRENTICE HALL
PRESBYTERIAN COMPANY CARE
PRESBYTERIAN HEALTHCARE ASSO.
PRESENTATION TASK FORCE. INC.
PRICEWATERHOUSECOOPERS LLP
PRICEWATERHOUSECOOPERS LLP
PRINCIPAL MU11JAL UFE INS. CO.
PRO GOlD OISCOUNT
PURCHASE POWER
PURSER & ASSOCIATES. INC.
QUAIL HOLLOW COUNTRY CLUB
QUEEN CITY COMPUTER PRESS. INC.
QUEENS COLLEGE CAREER
QUEST SOFTWARE
QUICK INTeRNET
RANOOLPH STREET PARTNERS
RAPIDFORMS. INC.
RAY & BERNDTSON. INC.
RAYBURN, MOOM& SMITH, PA
REIMAX INTERNATIONAL RELOC SER
REED ORGANIZATION
REGELBRUOOE. ROGER R
REILLY. DANIELJ.
RESORTS OF PINEHURST. INC.
RIA GROUP
RICOH CORPORATION
RISK & INSURANCE MGMT SOC.
RIVERVIEW Pl.ANATATION, INC.
RIVIERA FINANCE
ROBBINS. TAWANDA A.
ROSE LIMOUSINE. LTD.
ROSSI. HENRY J.
ROXBOROUGH UMllED PARTNERSHIP
ROXBOROUGH UMITED PARTNERSHIP
RUBBER & PLASTICS NEWS
RUIZ. URQUIZA Y CIA, S.C.
RUNCIMAN FAMILY TRUST, DEED OF
RUSSELL. LINDA
RYCKMAN. GERALD R.
S.D. MYERS
SAE
SAFECO LIFE INSURANCE CO.
SAG CONFERENCE 1996
SALEM A. AL AHMED AL SABAH
SALES & MARKETING MANAGEMENT
SALOMON SMITH BARNEY, INC.
SAMSUNG AMERICA. INC.
SANZENBACHER. CHARLES W.
SAZTEC INTERNATIONAL. INC.
ADDRESS 1
1916 SPRINGDALE AVE.
9S08 JOU. WILLE RD.
1007 BALDWIN LANE
PO BOX 7900071
PO BOX 71687
29OO-E S. 1-85 SERVICE RD.
REMITTANCE PROCESSING CENTER
PO BOX 33549
PO BOX 34307
C/O NEWVISION TlECHNOLOGIES
PO BOX 65640
PO BOX 7247-7868
6701 E. INDEPENDENCE BLVD.
PO BOX 85042
117LYNDHURSTCIR.
PO BOX 240224
4945 KENDRIOGE DR
PLACEMENT MANUAL FUND
PO BOX 51739
PMB394
C/O KIRKlAND & ELLIS
ACCOUNTS RECEIVABLE OEPT,
DRAWER NO. 980028
TlHE ARRILLON
8390 E. CRESCENT PtMAY
1111 SOUTIH BLVD.

5993 NATOMA ROAD
PO BOX 890215
PO BOX 6159
PO BOX 13750
PO BOX 19449
11991 RIVERVIEW RD.
PO BOX 200253
8701 HlJNTIAiND CT.
3703 WEONAAVE.
18260 CANTERBURY LN.
PO BOX 631073
C/O COLLIERS PINKARD
SUBSCRIBER SERVICES
AV DE LAS AMERICAS 1685-10
C/O JAMES RUNCIMAN
2927 PARK RD.
2517 W. 81ST STREET
PO BOX 931012-N
PO BOX 79572
GROUP ADMINISTRATION - PAR
PO BOX 18039
PO BOX 634
POBOX 10667
7 WORLD TRADE CENTER
C/O JAFFE & ASHER LLP
PO BOX 3109
PO BOX 412532
GS,INDUSTRIES. INC. MASTER CREDITOR UST Page 11
ADDRESS 2 AD0RESS3 CITY STATlfJPROV ZIP COUNTRY
CHARLOTTE NC 28203
SUITE 301 AUSTIN TX 78759
WAXHAW NC 28173
ST.LOUIS MO 63179-0071
CHARLOTTE NC 28208
POBOX 11074 DES MOINES IA 50336-1074
38 AURIGA DR UNIT,,3 NEPEAN ON2E8A5 CANADA
PHILADELPHIA PA 1917().7868
IA 50392-3860
CHARLOTTE NC 28212
LOUISVILLE KV 40285-5042
WEXFORD PA 15090-8870
CHARLOTTE NC 28224
CINCINNATI OH 45242
401 HAWTIHORNE LN. STE.l10142 CHARLOTTE NC 282042311
LOS ANGELES CA 90051_
1927 HARBOR BLVD. STE.A COSTA MESA CA 92627-7601
200 EAST RANOOLPH DRIVE CHICAGO IL 60601
301 GROVE RD. THOROFARE NJ 08086
FORT WORTH TX 76198
SUITE 1200 227 WEST TRADE STREET CHARLOTTE NC 28202
SUITE 600 GREENWOOD VILLAGE CO 80111
OAKPARK IL 60302
CHARLOTTE NC 28211
CLOVER SC 29710
CAROL STREAM UK 60197-6159
NEWARK NJ 07188-0750
NEWARK NJ 07195
CAMILLA GA 31730
CALLAS TX
CHARLOTTE NC 28227
CHARLOTTE NC 28209
STILLWELL KS 66086-9269
BALTIMORE MD 21:/63-1073
SUITE 301 330 S. TRYON ST. CHARLOTTE NC 28202-1916
DEPT. 77\140 DETROIT _ MI_
PISA. COL. PROVIDENCIA 44639 GUAOAIAIARA JAL
1445 VICTORIA ROAD, HOVEA WESTERN AUSTRALIA 06071
CHARLOTTE NC 28209
DAVENPORT IA 52806
CLEVELAND OH 44193-0343
BALTIMORE MD 2127!Hl572
POSTAL OUTLET
SEATTLE WA 98124
DELTA. BC L2M4CANAOA
WAT KUWAIT
RIVERTON NJ 08076
NEW YORK NY 10048
600 TlHIRD AVENUE - 9TH FLOOR NEW YORK NY 10022
CHARLOTTE NC 28210
KANSASCITV MO 64141
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SCHOENING. JAMES N.
SCHREIBMAN, SARA
SCULLY _GEMENT SERVICES
SEA ISLAND PHOTOGRAPHY
SEASCOPE SYSTEMS, INC.
SECRETARY OF STATE
SECRETARY OF STATE
SECRETARYQF STATE
SELECTFORM, INC.
SHAW, MICHAEL R
SHELCO. INC.
SHELLEY, DAVID O.
SHIi3PiNG uiGEST
SHOOK. HARDY & BACON. lLP
SIDLEY & AUSTIN
SIGMA CONSULTANTS, LLC.
SLACK. KATHLEEN CUSHMAN
SLAYTON INTERNATIONAL. INC
SMITH ~ LYONS
SMITH BARNEY. INC.
saCRA TES. JOHN J.
SOFlWARE SPECTRUM
SOUTH PARK SUITE HOTEL
SOUTHTRUST BANK OF ALABAM NA
SOUTHWESTERN BEll TELEPHONE
SPEC GROUP HOLDINGS. INC.
SPECIAL 1Y TECHNICAL PUBUSHERS
$PILLARS CONTRACT INTERIORS
SPIRIT TRUCKING COMPANY
SPRINGS LEASING CORPORATION
SPRINT
SPRrNTPCS
ST. XAVIER COMMUNITY
STANDARD & POOR'S
STATE OF MICHIGAN CORP. & SEC.
STATE OF UTAH
STATE STREET BANK & mUST co.
STATE STREET BANK & TRUST CO
STATE STREET GLOBAL ADVISORS
STEEL MANUFACTURERS ASSOC.
STEEL SERVICE CENTER INSTITUTE
STEUBEN
STEWART SMKELVEY STIRLING SCALES
STUTZ. JACK
SULLIVAN & CROMWELL
SUMA MECHANICAL CONTRACTORS
SUMITOMO CORPORATION
SUMITOMO CORPORATION OF AMERICA
SUN BELT OFFICE SUPPLIES
SUN GLASS & DOOR, INC.
SUPERINTENDENT OF DOCUMENTS
SUPERINTENDENT OF DOCUMENTS
SUPERIOR ACURA
SWERDLOW& FLORENCE
SWITZER, DON J,
GS INDUSTRIES. INC. MASTER CREDITOR UST
ADDRESS 1 ADDRE$S2 ADDRESS 3 CITY
1 DEVILLE CIR WILLIAMSVILLE
9106 SANDPIPER DR CHARlOTTE
PO BOX 2921 CAMARILLO
PO BOX 31025 SEA ISLAND
103 RUGGLES AVE. NEWPORT
PO BOX 1366 JEFFERSON CITY
180 STATE OFFICE BLDG. 100 CONSTITUTION AVE ST. PAUL.
DELAWARE DIVISION OF CORPORATIONS 7833 WALKER DR SUITE 201 GREENBELT
BOX 3045 FREEPORT
8514 TATEBROOKLANE HUNTERSVILLE
1 MORROCROFT CENTRE 6805 MORRISON BLVD. SUITE 100 CHARLOTTE
5800 CARY RIDGE DRIVE CHARLOTIE
PO BOC 1179 RIVERTON
1 KANSAS CITY PL 1200 MAIN ST. KANSAS CITY
875 THIRD AVENUE NEW YORK
8900 E. PINNACLE PEAK RD. SUITE 205 SCOTTSDALE
9631 GASLIGHT PLACE RICHMOND
181 W. MADISON STREET SUITE 4510 CHICAGO
SUITE 5800 SCOTIA PLAZA 40 KING STREET WEST TORONTO. ON
SEVEN WORLD TRADE CENTER NEW YORK
2873 MATHERS WAY TWINSBURG
PO BOX 910866 DALLAS
6300 MORRISON BLVD. CHARLOTTE
PO BOX no AMHERST
PO BOX 4699 HOUSTON
THE LANDINGS PO BOX 400209 PITTSBURG
SUITE 306-267 WEST ESPLANDE NORTH VANCOWER
PO BOX 411105 CHARlOTTE
PO BOX 404 WILLOW SPRINGS
PO BOX 667817 CHARLOTTE
PO BOX 30784 TAMPA
PO BOX 2200 BEDFORD PARK
3700 w. l03RD ST. CHICAGO
PO BOX 80-2542 CHICAGO
BUREAU. CORP. DIY PO BOX 30057 LANSING
UTAH DEPT. OF COMMERCE PO BOX 25125 SALT LAKE CITY
RETIREMENT INVESTMENT SERVICES POBOX 1389 BOSTON
PO BOX 5390 BOSTON
PO BOX 1521 BOSTON
1730 RHODE ISLAND AVENUE, N.W. SUITE 907 WASHINGTON
MEETINGS DEPT. 2400 KEY CENTER 127 PUBLIC SQ. CLEVELAND
ACCOUNTS RECEIVABLE PO BOX 6252 CHURCH ST. STA NEWYORK-
PO BOX 997 PURDY'S WARF TWR1 HALIFAX
doTAMeO 12459 ARROW ROUTE RANCHO CUCAMONGA
125 BROAD STREET NEW YORK
1721 E. WASHINGTON PHOENIX
1-1 HITOTSUBASHI 2CHOME CHIYODA-KU. TOKYO 101-8431 JAPAN T2KKB2
ATTN: MANAGING DIRECTOR SOOO USX TOWER 600 GRANT STREET PITTSBURGH
200 SOUTHSIDE DRIVE CHARLOTTE
1108 ELM STREET CHARLOTTE
US GOVERNMENT PRINTING OFFICE WASHINGTON
US GOVERNMENT PRINTING OFFICE PO BOX 371954 PITISBURGH
5555 DIXIE HWY. FAIRFIELD
9401 WILSHIRE BLVD. SUITE 826 BEVERLY HILLS
345 WINDING BROOK LANE MONROE
Page 12
STATEIPROV ZlP COUNTRY
NY 14221
NC 28277-5518
CA 93011
GA 31561
RI 02840
MO 65102
MN 55155-1299
MD 20n(J
NY 11520
NC 28078
NC 28209
NC 28277
NJ 08077-8779
MO 64105
NY 10022
AZ. 85255
VA 23229
IL 60602
CANADA M5H3Z7
NY 1004ll
OH 44087
1)( 75391-0866
NC 28211
NY 14226-0770
TX 770$T7-0075
PA 15268-0209
BC M1A5
NC 28241
IL 60480-0404
NC 28266-7817
FL 3363().3784
Il 60499-2200
IL 60655
Il S06lJ0.2542
MI 48909-7557
UT 84125-0125
MA 02104
MA 02206
MA 02104-9818
DC 20036-3101
OH
-
4 4 1 1 4 ~ 1 ~ 1 6 _
NY 10249-6252
NS 3J2X2
CA 91731l
NY 10004
AZ 85034
PA 15219
NC 28217
NC 28206
DC 20402
PA 15250-7954
OH 45014
CA 92012
OH 45050
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VENDOR NAME
SYCIP SALAZAR HERNANDEZ
SYNERGISTIC PSYCHOLOGY ASSOC
SYSTEM SUPPORT SERVICES. INC.
SYSTEMS ENGINEERING AlARM
T.L. JAMES INDUSTRIAL CONST.
TEMPORARY SOLUTIONS. INC.
TEXACO INC.
TEXTRONIX
THE AISE STEEL ROUNDATION
THE BANK OF NEW YORK
THE BLOSSOM SHOP, INC.
THE BUSINESS JOURNAL
THE JOURNAl
THE CAPITAl HILTON
THE CHARLOTTE OBSERVER
THE CLOISTER SEA ISLAND
THE CONFERENCE BOARO. INC.
THE DAJSY BASKET
THE DEPOSITORY TRUST CO.
THE DRAWING BOARD
THE DUKE MANSION
THE ECONOMIST
THE FURNITURE NETWORK, INC
THE GEORGE TOWN CLUB
THE HISTORIC GEORGE TOWN CLUB
THE HOlMING COMPANY
THE INSURANCE COMPANY OF NA
THE INYENTURE GROUP
THE JOURNAL OF COMMERCE
THE KIPLINGER LETTER
THE UEAHY NEWSLETTER. INC.
THE lEARNING CIRCLE
THE METROLOPOLITAN CLUB
THE MINT MUSEUM OF ART
THE PARK HOTEL
THE RITZ-cARLTON
THE SIDE PORCH. INC.
THE SPEEDWAY CLUB
THE TOWER CLUB
THE US AIR CLUB
THE WALDORF-ASTORIA
THE WALL STREET JOURNAL
THE WASHINGTON TIMES
THOMAS E. SMITH & COMPANY
THUNDERDOME RACING OF CHARLOTTE
TREE ISLAND INDUSTRIES. INC.
TIFFANY & CO.
TIME
TIME VALUE SOFTWARE
TONETECH
TOURNAMENT PLAYERS CLUB
TOWERS PERRIN FORSTER & CROSBY
TOWERY PUBLISHING, INC.
TRANSAMERICA OCCIDENTAL UFE
TRANSAX
ADDRESS 1
&GATMAITAN
SUITE 204 CAMERSON-BROWN B
7301 RIVERS AVE
PROTECTION SERVICE
PO BOX 77760
PO BOX 2474
PO BOX 31129
PO BOX910139
3 GATEWAY CENTER
101 BARKLEY ST.
2242 PARK ROAD
PO BOX 52250
PO BOX 52252
PO BOX 75208
PO BOX 70111
PO BOX 30861
PO BOX 4026
8824-B BELHAVEN BLVD.
ss WATER ST.
PO BOX 6213
400 HERMITAGE RD.
PO BOX 58525
10512 FAIRWAY RIDGE RD
1530 WISCONSIN AVE" N.W.
1530 WISCONSIN AVE . N.W.
6900 N. TEUTONIA AVE.
2200 PARKLAKE DRIVE. N.E.
8500 NORMANDALE LAKE BLVD.
PO BOX 65954
pOBOX 10910
PO BOX 467
142 NORTH RD.
ONE EAST SIXTIETH ST.
2730 RANDOLPH RD.
2200 REXFORD ROAD
KANSAS CrTY PAYMENT OFFICE
PO BOX 7fi!
PO BOX 600
201 SO. COLLEGE STREET
PO BOX 307
75 REMITTANCE DR.
200 BURNETT ROAD
ACCOUNTS RECEIVABLE
405 MEDWAY RD.
POBOX 1415
PO BOX SO
PO BOX 7247-8117
PO BOX 61140
4 JENNER ST.
PO BOX 12422
AT PIPER GLEN
PO BOX 850Q...6110
PO BOX 41079
PO BOX 419522
PO BOX 64888
GS.INDUSTRIES. INC_ MASTER CREDITOR LIST
Page 13
PO BOX 4223 MANILA PHILIPPINES
301 SOUTH MCDOWELL ST CHARLOTTE NC 28204-2622
SUITE 201 NORTH CHARLESTON SC 29406-4650
BATON ROUGE LA 70879-7760
MANASSAS VA 22110
TAMPA FL 33631-3129
DALLAS TX 75391-0139
401 LIBERTY AVE.. STE 1900 PITTSBURG PA 152229276
12TH FLOOR. EAST NEW YORK NY 10286
CHARLOTTE NC 28203
BOULDER CO 803212250
BOULDER CO 803212252
CHICAGO IL
CHARLOTTE NC 28272..()111
SEA ISLAND GA 31561
CHURCH STREET 5T ATION NEW YORK NY 10261-4026
CHARLOTTE NC 2821'
NEW YORK NY 10041
CAROL STREAM IL 60197--6213
CHARLOTTE NC 28201
BOULDER CO 80322-8525
CHARLOTTE NC 282n..ess1
WASHINGTON DC 20007
WASHINGTON DC 20007
WI 3523250
SUITE 140 ATLANTA GA 30345
SUITE 1750 MINNEAPOLIS MN 55437
DESMQINES IA 5034().()910
TUSTIN CA 92781
SUDBURY MA 01776
NEWVORK NY 100221054
CHARLOTTE NC 28207
CHARLOTTE NC 28211
401 WARD PARKWAY KANSAS CITY Me 64112
LANCASTER SC 2972H)757
CONCORD NC 28026-0600
27TH FLOOR CHARLOTTE NC 28244
pmSBURGH PA
SUITE 1106 CHICAGO _ IL 60675-1101L
CHICOPEE MA 01020
3600 NEW YORK AVE . N.E. WASHINGTON DC 20002
HIGHLAND HEIGHTS OH 44143
MOORESVILLE NC 28115
NEW WESTMINSTER BC CANADA V3L4Y1
PHILADELPHIA PA 19170-8117
TAMPA FL 33661-1140
SUITE 100 IRVINE CA 92618
CHARLOTTE NC 28220
4300 PIPER GLEN DRIVE CHARLOTTE NC 28277
PHILADELPHIA PA 19178
MEMPHIS TN 38174-1079
KANSAS CITY MO 64141-6522
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VENDOR NAME
TRAVELINE TRAVEL
TRAViSA
TREASURER OF STATE OF OHIO
TREASURER'S OFFICE
TRIPLE 'M' MESSENGER, INC
UNDERWOOD KINSEY WARRANT
UNITED PARCEL SERVICE
UNITED STATES POSTAL SERVICE
UPS CUSTOMHOUSE BROKERAGE, INC.
URSCHEL, RICHARD G
US AIRWAYS CLUB
US LIFE INSURANCE COMPANY GROUP

UTAH STATE TAX COMMISSION
V.W. EIMICKE ASSOCIATES. INC.
VALUE lOlNE PUBLISHING, INC.
VAN DYKE TECHNOLOGIES. INC.
VERIZON WIRELESS
VILLAGE FLOWER SHOP
VISTAR SINO SERVICES, INC.
VOLVO CAR FINANCE. INC.
VOLVO FINANCE NORTH AMERICA
WACCAMAW CORPORATION
WACHOVIA AUTO LEASING COMPANY
WADE DOOR SERVICES, INC.
WAKE FOREST UNIVERSrTY
WALLACE ZUCKERMAN, C.P.A.
WALSH, JAMES F.
WALTER, CONSTON, ALEXANDER
WARREN. GORHAM & LAMONT
WARREN, GORHAM & LAMONT, INC.
WASHINGTON SERVICE BUREAU
WASHQVIA BANK AND TRUST CO., NA
WATKINS, MAUREEN A
WAITS, SUSAN S.
WAYNE'S CARPET CLEANING
WEBB. RICHARD B
WELLS FARGO INVESTIGATIVE sves
WELT PUBLISHING LLC
WEST GROUP PAYMENT CENTER
WEYERHAEUSER RECYCLING BUSINESS
WHIRLPOOL CORPORATION
WHITE APPRAISAL INC.
WHITE STAR CONSTRUCTION, INC.
WIELAND, TIMOTHY E.
WILD DUNES RESORT
WILEY. REIN & FIELDING
WILLIAMM. MERCER, INC.
WILSON. MARlENE R.
WILSON, PAUL B.
WIRE ASSOC. INrL INC.
WM. E. O'BRIEND, CO. TREASURER
WOLF, JASON A.
WRI PUBLICATIONS
WYATI DATA SERVICES
ADDRESS 1
1396 SOM CENTER RD.
2122 P ST .. NW
OHIO DEP.T OF TAXATION
COlleGE OF CHARlESTON
PO BOX 672022
&TUCKER,P.A.
PO BOX 505820
CMRS--PB
PO BOX 34486
4622 WYNMEADE PARK
PO BOX 641170
ACCOUNTlNGlMSN3A
PO BOX'H01M
210N.1950W.
PO BOX 160
PO BOX 3988
4848 TRAMWAY RIDGE DR.. N.E.
PO BOX 580334
NEARGARDER. INC.
PO BOX 510758
VCFOO-0453
1700 JAY ELI DR
3200 POTTERY DRIVE
100 N. MAIN STREET
596 GRIFFITH RD.
6805 MORRISON BLVD.
2505 BLACK ROCK TURNPIKE
6401 SETON HOUSE LANE
& GREEN, P.C.
PO BOX 4302
210 SOUTH STREET
655 RFTEENTH STREET
POBOX 31608
6422 TEAGUE LANE
2533 ROSWEll AVENUE
POBOX 18721
_5 STEEPLECHASE DR.
POBOX 99477
14 W. MT. VERNON PL.
PO BOX 6187
5232 HOVIS RD.
2783 PETERSON PL
4391 E. GALBRAITH RD.
6715 MIZE RD.
CIO ME INTERNATIONAL. INC
PO BOX 20575
1776 K STREET, NW
DEPT. 97512
2318 VALENCIA TERRACE
5016 TURN BERRY LN
PO BOX 578
111 S. CHERRY
9318 HANOVER SOUTH TRAIL
PO BOX 4652
218 ROUTE 17 NORTH
GS.INDUSTRIES, INC. MASTER CREDITOR LIST Page 14
MAYFIElD HEIGHTS OH 44124
WASHINGTON DC 20037
POBOX 1090 COLUMBUS OH 43266-0090
CHARLESTON SC 29424
HOUSTON TX 772672022
PO BOX 651524 CHARlOTTE NC 28265-1524
THE LAKES NV 88905-5820
PO BOX 7247-0166 PHIlADELPHIA PA 19170-0166
LOUISVILLE KY 40232
MARIETTA GA 30067
PITISBURGH PA 15264-1170
PO BOX 1590 NEPTUNE NJ 07754-1590
" . ':S2S4--n184
SALT lAKE CITY UT 84134
BRONXVILLE NY 10708
CHURCH STREET STATION NEW YORK NY 10008-3988
SUITE2()1 ALBUOUERQUE NM 87111
CHARlOTTE NC 28258.{)334
49 N. MAIN ST. GERMANTOWN OH 45327-1396
MELBOURNE BEACH FL 32951--0758
POBOX 9737 MACON GA 312979737
RICHARDSON TX 75081
MYRTLE BEACH sc 29sn
WINSTON-SALEM NC 27150
CHARlOTTE NC 28217
FAIRFIELD CT. 06432
CHARLOTTE NC 28277
90 PARK AVENUI:: NEW YORK NY 10016-1387
BOSTON MA 02111
WASHINGTON DC 20005
CHARlOTTE NC 28231
CHARlOTTE NC 28215
CHARLOTTE NC 28209
CHARLOTTE NC 28218
ROSWELL GA 30076
CHICAGO IL 60693
BALTIMORE MD 21201
CHARlOTTE NC 28208

NORCROSS GA 30071
CINCINNATI OH 45235
SHAWNEE KS 66226
3901 UNIVERSITY AVENUE N.E. MINNEAPOLIS MN 00005--5421
CHARlESTON SC 29413
WASHINGTON DC 20006
LOUISVILLE KY 40297
CHARLOTTE NC 28226
DAVENPORT IA 52807
GUILFORD CT 06437-0578
OLATHE KS 660613471
CHARLOTTE NC 28210
HAMPDEN STATION BALTIMORE MD 21211
ROCHELLE PARK NJ 07662
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VENDOR NAME
YARBOROUGH, DAVID M.
ZIPPO MANUFACTURING CO.
ZURlCH AMERICAN INS. GROUP
ADDRESS 1
661 HUNGERFORD PLACE
33 BARBOUR ST.
2 CONCOURSE Pt<:NAY
ADDRESS 2
BOX 364
SUITE 300
AODRESS3 CITY
CHARLonE
BRADFORD
ATlANTA
STATEIPROV
NC
PA
GA
P a g e ~ 15
ZIP COUNTRY
28207
16701-0364
30328
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John and Patricia Burgess.
Linda Cribb Davidson,
LJ. Meyer, Wilbur and Shirley
Carter, Marilyn Burkhardt,
Bruce Chandler, C_M. Bush.
Virginia Huggins, Paul I.
Skoko, Helen J. Keith, Marian Rowe,
John and Mamie CUnningham, Leola
Alston, Eunice Fraser. T. Goudy
Miller. Leonard Roach, and Patricia
and John Wiley, on behalf of
themselves and others similarly
situated.
Plaintiffs,
vs
Georgetown Steel
Corporation,
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TO: ALL INTERESTED PERSONS
CASE NO.: 98-CP-22-385
ORDER APPROVING
DISTRIBUTION OF
SETTLEMENT FUNDS
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This matter is before the Court pursuant to a Motion to Approve the Distribution of Settlement
Funds filed by the attorneys for the Plaintiffs. Present at the Hearing were]. Edward Bell, III and C.
Carter Elliott, Jr., attorneYs for the Plaintiffs and various Plaintiffs and other interested parties. Based upon
the filed documents, Pleadings, Motions and argwnents of counsel I find the following facts.
1) On or around July 1998, three(3) separate Class Action Iawsuits(including the above-
mentioned) were :filed by The Bell Law Finn on behalf ofvariousPlaintiftS against the
Georgetown Steel Corporation alleging that persons within a five(5) mileradiusQater
revised down to approximately within the City limits of Georgetown) of the Georgetown
Steel Mill were incuning damage to theirrea1 property> motor vehicles and watercrafts as
!1 Ull CCl reSW! ot mill dust created by the Steel mill operation. The tbree(3) Class Action
lawsuits which were filed in Georgetown County under the Case Numbers 98-CP22
385. 98-CP-22-414 and 98-CP-22-450, were stayed when a Bankruptcy Action was
filed by the Georgetown Steel Corporation in February of2001.
2) In response to various notices from the UIrited States Bankruptcy Court requiring the filing
ofl'Toof of Claims the above-mentioned Plaintiffs and other Claimants (by and through The
Bell Law Firm) filed individual Proof of Claim forms on or around July of200 1 all eging
damages to theirrea1 property, automobiles and watercrafts. The name of each Cl airnant
and amount of their original claim is listed on the attached Exhibit A.
3) Thereafter, the CJaimants and their attorneys received the First Claims Objection from
Georgetown Steel COIporation. The Debtors objected to each claim in their Claims
Objection and requested e,tpungement of all claims on grounds that there was no basis for
the claims. Thereafter, the Claimants by and through The Bell Law Finn filed a Response
to the Debtors Claims Objection on or around December of2002.
4) Thereafter, The Bell Law Firm obtained oral and/or written authority from the Plaintiffs
and/or Claimants to negotiate a settlement to resolve each of the 58 claims.
5) Thereafter, Georgetown Steel Corporation agreed to and allowed the claim amount of
$870,000.00, to settle andlorresolve all 58 claims. Even though The Bell Law Finn fi1ed
various Motions regarding their contention that the attorneys for Georgetown Steel
Corporation offered to pay $870,000.00 to settle al158 claims, the Bankruptcy Judge
George R. Hodges signed an Order on June 9,2003, stating that the Claimants would only
receive a certain "C Lt. . 11 _. . 4
ooofumed plan ofliquidation. The name of each Claimant, the amount of the original claim
and the amount of the allowed claim is listed on attached Exhibit A.
6) On or about JlUle 30, 2003, the Claimants received a check in the amount oUll3, 1 00.00
from GS fudustries, Inc. which represents an initial distnbution of] 3% of the total allowed
claim amount. Additionally, according to the attorneys for the Plaintiffs there may onnay
not be additional distributions made by OS Industries, Inc. toward the Claimants unsecwed
allowed claims.
7) The Bell Law Finn, as attorneys for the above-mentioned Plaintiffs and other Claimants,
are presently requesting an Order Approving the Distribution of the Settlement Funds
which they have already received in the amount of$113, 100.00 and which they may
receive in the future. I find that The Bell Law Firm has incurred $61,927.56 in out of
pocket costs and expenses to date to prosecute these cases and/or claims. After a review
of the breakdown of these costs and expenses, I further find that this amount is reasonable
and should be disbursed from the settlement proceeds to The Bell Law Firm. Further, The
Bell Law Finn has agreed to take no attorneys fee which I find is reasonable under the
circumstances. I further find it is reasonable that each Plaintiff and/or Claimant pay his or
herpro rata share of the total costs incurred based upon the total amount they are receiving
from the settlement funds. Therefore, out of the $113,100.00 each Plaintiffand/or
Claimant wouJd receive 13% of their allowed claim less a pro rata share of the total costs
inctmed by The Bell Law Finn to prosecute these claims. Thereafter, The Bell Law Finn
is authorized to distnbute any additional settlement funds, which may be distributed by OS
..
of any additional funds received.
8) I find that the attorneys for the Plaintiffs sent notice to all interested parties with claims of
the time, date and place of this hearing.
Based on the above-mentioned findings of fact, IT IS ORDERED, ADJUDGED AND
DECREED as foHows;
A) The Bell Law Finn shan place the settlement funds in the amountof$l13,l 00.00, in their
trust account and disburse the funds to each Claimant as set out and/or stated in the above
findings offllcts. Additionally, The Bell Law Finn is authorized to distribute any additional
funds as stated above without further order of this Cotlrt.
Georgetown, South CaroHna
September l5; 2003
Honorable Paula H. Thomas
Fifteenth Circuit Court Judge
Appendix - Bain Capital Private Equity Investments
Table I
Summary of all Bain Capital Private Equity Investments (Funds I - VI
Realized or Implied Average
Date of Investment estimate d annual annual
(5 t housands) investment amount amount(1) IRR!Z) IRRIZH3J
Key Airlines 1984 S 2.000 S 5.369 52.9%
Holson Burnes Group 1986-92 10.010 22.621 20.9
Accuride 1986 2.604 61.219 1.122.8
Vetco Gray 1988 3.776 15.995 66.4
Handbag Holdings 1988-91 4.189 993 (26.91
PPM 1988 2.184 254 (65.71
Stage Stores (SRI) 1988-92 9.587 184.432 62.9
Libri 1989 3.750 32.936 55.4
ABRY Communications 1989-90 4.290 30.430 55.1
Damon 1989 3.395 10.860 37.9
Polymerics{Tulip 1989 4.201 0
Ganner Group 1990 3.458 55.380 216.2
BrooKslone 1991 4.181 47.213 126.1
Masland 1991 10.442 69.948 132.9
EduServ Technologies 1991-93 4.132 400 (29.61
Leiner 1992 2.776 9.171 27.0
American Pad & Paper 1992 5.060 107.181 130.0
Duane Reade 1992 16.080 58.924 31.1
Preferred Technical Group 1992 6.958 74.545 207.7
Gilbert Engineering 1992 3.145 85.218 128.2
GS Industries 1993 24.518 58.402 416.3
GT Bicycles 1993 6.376 31.858 70.7
Stream Int'I/Corp SoftJModus Media 1993 9.577 20.587 29.3
PSI 1993 6.51 1 13.025 12.2
Totes 1994 9.410 9.410 0.0
Steel Dynamics 1994 18.263 103.960 82.5
Physio Control 1994 8.524 176.876 844.4
Waters 1994 26.633 204.516 227.9
ICON Health & Fitness 1994 45.534 13. 379 (43.81
Small Fry/Humpty Dumpty 1994 3.357 5.948 20.7
FTD 1994 5.711 5.711 0.0
Dade International 1994 26.669 229.898 61.0
Investment Resource Mgmt. 1995 4.533 4.152 (3.11
Auto Paiace/ADAP 1995 4.976 2. 166 (22.71
Alliance Entertainment 1995 25.137 10.021 (84.11
Jastens Learning 1995 13.616 0
Wesley Jessen VisionCare 1995 6.424 303.382 315.5
Jtech
1995 3.751 3.751 0.0
Miltex Instruments
1995 4.926 2.463 (16.31
Cambridge Industries
1995 15.749 0
Argencard
1995 4.312 6.740 13.8
SpoTtcrah
1995 4.329 1.082 (29.31
AMF Bowling
1996 18.598 5.358 (42.81
The lifelike Company
1996 2.108 2.108 0.0
Clarity Telecom
1996 6.702 24.478 60.2
Medical Specialties
1996 9.628 2.407 (32.71
Bacchi Laboratories
1996 4.286 4.286 0.0
Dynamic Details
1996 40.573 69.758 36.2
16

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