Document 3NgMqNMOdKwEM7LnydX1ywGoO

05 ! 0 I 32*2 i 3 4 .1 5I 6! 7 a 9 10 i li 12 '! 13 i! 14 it i 13 16 17 | I 18 ! i| 19 I 20 21 Otherwise stated, identify what brake pads, brake linings or brake facings went into which of your motor vehicles during the period 1950 through 1978; (k) State when and how you were first made aware of health hazards associated with the use of asbestos; (l) When did you first become aware that warnings were plaed on asbestos products with respect to the health hazards associated with the use of asbestos; (m) When did you first learn in any manner or from any source that asbestos or asbestos products are hazardous or dangerous to the health of persons; (n) From whom did you learn the information referred to in the answer to the preceding interrogatory; (o) State what documents reflect the information given in answer to the two preceding interrogatories, their date, and the present custodian of said records; (p) Did you at any time maintain or distribute manuals, instructions or information relating to the sale, use or removal of asbestos or asbestos products, including, but not limited to, the use or removal of asbestos-containing brake linings, brake pads or brake facings; (q) If the answer to the preceding interrogatory is in the affirmative, state the present location of records or other such materials and thename and address of the custodian of said manuals, instructions, directories or information. 23 24 ;| i 25 : 26 PLAINTIFF'S FIRST INTERROGS ETC. 22