Document 2JQeMdDxNKYDYaXYq3G91a3xg

o5 t 0 r0299 I' 1 REQUEST FOR PRODUCTION U; Pursuant to CR 34, attach or 2 produce according to the above instructions a copy of the records 3 of the implementation of the above-identified no-smoking programs. 4 RESPONSE; <^ answer to 4.09 above. 9 6 7 8 9 REQUEST FOR ADMISSION N: Prior to 1900, dust counts, air 10 sampling surveys, or other types of studies or tests were conducted 11 12 at one or more of your facilities where products containing 13 1 asbestos were manufactured to determine the levels of dust or 14 asbestos fiber concentrations in the air. 15 RESPONSE: Denied. 16 17 18 h 19 20 REQUEST FOR ADMISSION 0: Prior to 1910, dust counts, air |i 21 [.sampling surveys* or other types of studies or tests were conducted ii 22 i1 at one or more of your facilities where products containing 23 ! asbestos were manufactured to determine the levels of dust or 24 i asbestos fiber concentrations in the air. 25 26 PLAINTIFF'S FIRST INTERROGS, ETC. - 77