Document 0Jdx1dK7eeZ6N5VRDkkVzVgkd
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1 INTERROGATORY NO. 118:
2 At any time during the period 1948 to 1978, has defendant
3 manufactured automobile brake linings or brake assemblies? If
4 so, please state:
5 (a) The trade or brand name(s) under which the brake
6 linings or brake assemblies were marketed;
7 (b) The years during which the b'-ake linings or brake
8 assemblies, under each trade or brand name, were manufactured;
9 (c) The date each product was withdrawn from the mar
10 ket, if such is the case;
11 (d) The quantitative percentage of each chemical com
12 ponent of the brake linings under each trade.or brand name;
13 (e) If asbestos was included in the composition of the
14 brake linings which defendant manufactured under any trade or
15 brand name, please state:
16 (i) The type of asbestos fiber (i.e., amosite,
17 chrysotile, crocidolite) used in the brake linings under each
18 trade or brand name;
19 (ii) The quantitative percentage of asbestos fiber
20 used in the brake linings under each trade or brand name;
21
(iii) The years during which asbestos fiber was
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i 22 included in the composition of the brake linings under each trade
23 or brand name;
24 (f) The location of the facility (facilities) where
25 the brake linings or brake assemblies were manufactured.
26 RESPONSE:
27 Yes.
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23 (a) OBJECTION. This responding defendant objects to
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