Document 3QkEpNbvr15GpE3DXBwEMzOGE

investigative and third-party communication privileges set forth in Rule 166b of the Texas Rules of Civil Procedure. Subject to and without waiving the foregoing objections, the precise date or manner in which GM, or any of its employees, learned that asbestosis is related to the prolonged, excessive exposure to respirable asbestos fibers is unknown, but it was no later than 1940. However, to the best of GM's knowledge, there is no recognized scientific substantiation that brake linings create an increased risk of illness to consumers or people who do repairs. 26. As to the disease lung cancer, state: (a) The date on which Defendant or its subsidiary or predecessor first learned that such disease was caused by inhalation of asbestos fibers by humans. (b) How Defendant or its subsidiary or predecessor became aware of the disease and its relationship to ssbestos exposure. (c) Who within the company or its subsidiary or predecessor first discovered or recognized the adverse consequences or effects of the'asbestos exposure. (d) What information was disseminated within Defendant's company or its subsidiary or predecessor regarding such adverse consequences or effects. (e) Whether any such information is still maintained by Defendants or its subsidiaries or predecessors in a written form. (f) Who is the custodian of such information. (g) The date on which you first received knowledge or information that lung cancer was caused by inhalation of asbestos dust and fibers. ANSWER: Defendant objects to Interrogatory No. 26 to the extent it refers to and inquires of a "predecessor" without identifying such or providing a definition of such. Further, for Defendant to identify a predecessor would involve a legal conclusion for which there is no factual basis or foundation. Further, the interrogatory is argumentative, implying that the asbestos-containing products nancASUOOMMuwH 30