Document 2RKDvkJmje0KXd0gpR6NmJ8Lg

(c) Please produce all documents upon which your responses above are based; (d) Please identify die name(s) and address(es) of any person(s) who can verify your above response; .. . . i j (e) Did Defendant ever rely on the Dreessen Report in whole or in part as a basis that Defendant's asbestos products could be used in the workplace without risk of asbestos-related health impacts to the consumer and/or bystander; (f) If so, please produce every document which evidences in any way that Defendant relied on the Dreessen Report in whole or in part for the proposition stated in Interrogatory No. 63(a) above; (g) If your answer to 63(e) is yes, when was the first date Defendant relied on die Dreessen report in whole or in part for the proposition stated in 63(e) above? ANSWER: Sec Preliminary Statement and General Objections, which are incorporated herein as if fully rewritten. Further objecting, the interrogatory is overly broad given the parameters and subject matter of this case. Further objecting, the information sought is neither relevant to die subject matter of the pending action nor reasonably calculated to lead to the discovery of admissible evidence as it relates to Dana. Subject to and without waiving objections, Dana does not know when, if ever, Smith & Kanzler Company or any of its predecessors-in-interest first received a copy of the article entitled "A Study of Asbestos in the Asbestos Textile Industry", published in 1938 in Public Health Bill, No. 241, U. S. Public Health Service and authored by W. (c) Dreessen ("the Dreessen Report"). INTERROGATORY NO. 65: Please identify documents or things, including x-rays, MRIs, CT-scans or other materials which will be used at time of trial (Exhibit List, Deposition List), which arc relevant to each of Defendant's enumerated defenses in Defendant's lak filed Answer. ANSWES; eg General Objections and Preliminary Statement, if any, which are incorporated herein as if fully rewritten. Objection to the extent the request seeks information protected by the (a) attorney-client privilege, (b) the attorney work product doctrine, (c) any applicable privilege relating to communications between counsel for defendant and counsel for other defendants in this or other cases regarding defense of this case, (d) any applicable privilege relating to communication's between defendant's employees or counsel and defendant's insurers regarding S IS RESPONSES TO PLAINTIFFS* MASTER INTERROGATORIES F:\KELLY\DISC\DANA.INT PAGE -47-