Document 1QBBX6ZxDaKxGr2M3G5eKzDJK

1 INTERROGATORY NO. 39t 2 Please state if the defendant's medical officers or indus 3 trial hygienists ever made any recommendations and/or suggestions 4 to the defendant pertaining to the risks or hazards to persons 5 involved in the manufacturing or use of products containing as 6 bestos? If so, please state: 7 (a) Where were such recommendations and/or suggestions 8 made? 9 (b) To whom were such recommendations and/or sugges 10 tions made? 11 (c) By whom were these recommendations and/or sugges 12 tions made? 13 (d) The substance of the recommendations and/or sug 14 gestions made. 15 RESPONSE: 16 OBJECTION. Interrogatory No. 39 is objected to on the 17 grounds that it is overly broad, burdensome, oppressive, harass 18 ing and seeks information which is not reasonably calculated to 19 lead to the discovery of admissible evidence. 20 INTERROGATORY NO. 40: 21 Please state the names of trade association periodicals to 22 which defendant subscribed from 1930 to 1972. 23 RESPONSE: 24 OBJECTION. Interrogatory No. 40 is objected to on the 25 grounds that it is overly broad, burdensome, oppressive, harass 26 ing and seeks information which is not reasonably calculated to 27 lead to the discovery of admissible evidence. NZO Ox 28 Ill ARO U6i -25-