Document 2Nb3Ow3x8JLQno0DvMObOb6rr

6. Does Defendant or any of its subsidiary companies claim that any patent would cover any product listed in answer to Interrogatoiy No. 5? If so, please state the following: ANSWER: Westinghouse incorporates by reference its Preliminary Statement and General Objections. Westinghouse 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 plaintifT 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. 7. Have any of the products listed above in answer to Interrogatory No. 5 been altered in chemical composition since first being marketed? Is so, please state the following: a) The trade name of each such product; b) The date each such product was altered; c) The nature of the alteration; d) The reason for the alteration. 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 plaintifT 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. 10