Document 0q0xd3ex1b5YvMG6R902QR9ym

1 any year between 1930 to 1972. 2 RESPONSE: 3 Based upon information available at this time, defendant 4 responds that it does not believe so. 5 INTERROGATORY NO. 101: 6 Please state whether defendant possessed any ownership in 7 terest in any firm or corporation involved in the mining, proc 8 essing or sale of raw asbestos, any asbestos-containing products 9 which wre domiciled, headquartered or doing business in the 10 British Isles for any year from 1930 to 1972. 11 RESPONSE: 12 OBJECTION. Interrogatory No. 101 is objected to on the 13 grounds that it is vague, ambiguous and unintelligible. 14 INTERROGATORY NO. 102: 15 Please state whether any business or corporation described above 16 possessed any ownership interest in defendant from 1930 to 1972. 17 RESPONSE: 18. Not applicable. 19 INTERROGATORY NO. 103: 20 Please state when the first claim for Workers1 Compensation 21 was filed by any of the defendant's automobile repair employees 22 or factory workers in which it was alleged that said claimant had 23 developed: 24 (a) Asbestosis; 25 (b) Lung cancer; 26 (c) Masothelioma. 27 For each such claimant, list the date the claim was filed, the rZO o*. 28 claimant's name and the state in which the claim was filed. 'ADO M61 -47-