Document 3N2jqM1QwXmJwyEKbvQao6m0E

1 RESPONSE: 2 (a) One claim was made on 3/3/80 and one on 8/11/82, 3 for alleged asbestos related injuries. 4 (b) No claims for asbestosis were filed during the 5 years 1930 to 1972. 6 INTERROGATORY NO. 48; 7 Has the defendant ever been a member or the Asbestos Textile 8 Institute ("ATI")? If so, please list the years of membership. 9 RESPONSE; 10 No. 11 INTERROGATORY NO. 49: 12 Please state whether any representative, agent or employee 13 of the defendant corporation was a member of the Air Hygiene 14 Committee of the ATI. If so, please include in your answer a 15 list of the years of membership. 16 RESPONSE; 17 Not to our knowledge. 18 INTERROGATORY NO. 50: 19 Please state whether any representative, agent or employee 20 ever attended any meetings of the Air Hygiene Committee of the 21 ATI. 22 RESPONSE: 23 OBJECTION. Interrogatory No. 50 is objected to on the 24 grounds that it is overly broad, vague and ambiguous. Without 25 waiving said objection, and in the spirit of liberal discovery, 26 defendant responds that it does not believe so. 27 /// NZO o 28 /// 'ARO H6t -79-