Document 0Jdx1dK7eeZ6N5VRDkkVzVgkd

~\ 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linings or brake 8 assemblies, under each trade or brand name, were manufactured; 9 (c) The date each product was withdrawn from the mar 10 ket, if such is the case; 11 (d) The quantitative percentage of each chemical com 12 ponent of the brake linings under each trade.or brand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 .I 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. fZO 1 i o** 23 (a) OBJECTION. This responding defendant objects to 1'6' 60 -55-