Document 2JZ0d8oL5EJyEzYEB3yZr3Jz5

8. Have any of the asbestos-containing products listed in response to Interrogatory No. 5 ever been marketed, distributed, packaged, labeled, and/or sold by any other company or business? If so, please state the following: a) The name and address of each such company. b) The names and address of Defendant's distributors in Ohio and Illinois since 1940. c) The date of each sale. d) The name of the person at each location with whom you primarily dealt. e) A list of all asbestos-containing products that you sold to each location from 194S to 1980. 0 The amount of each asbestos product sold to each location during this period, g) Please identify all documents relating to this distributor for the particular location. ANSWER: Westinghouse incorporates by reference its Preliminary Statement and General Objections. Westinghouse further objects to responding to this Interrogatory concerning any products not alleged to have contributed to the alleged injuries of plaintiffs), on the grounds that the Interrogatory, as applied to Westinghouse, is overly broad and unduly burdensome and seeks information which is irrelevant and immaterial to these proceedings and is not reasonably calculated to lead to the discovery of admissible evidence. If a particular plaintiff will specifically and credibly identify the Westinghouse product(s) alleged to have given off respirable asbestos fibers in his or her presence, Westinghouse will endeavor to answer this Interrogatory for such produces), if any, to the extent Westinghouse reasonably can do so. 8.1 Does Defendant have reason to believe that the asbestos-containing products listed in response to Interrogatory No. 5 were used at the ARMCO/A.K. Steel Middletown Plant and/or the ARMCO/A.K. Steel Hamilton Plant. Ifyou answer is "yes", please state the basis ofyour answer. ANSWER: Westinghouse incorporates by reference its Preliminary Statement and General Objections. Westinghouse further objects to responding to this Interrogatory concerning any products not alleged to have contributed to the alleged injuries of plaintiffs), on the grounds that the Interrogatory, as applied to Westinghouse, is overly broad and unduly burdensome and seeks information 11