Document 3wgOqqOJ1N7xrJOd95xn0ORy

which were manufactured, sold, distributed, installed, applied and/or specified by Defendant and/or any predecessor /related entity, during the times alleged by plaintiff; and, (d) Identify each and every person known to you to knowledge and/or information concerning the same. ANSWER: See response to Interrogatory #2. INTERROGATORY NO. 5: As to each site as described in Interrogatory No. 2, for which Defendant denies that any asbestos-containing products were present, which were manufactured, sold, distributed, installed, applied and/or specified by Defendant and/or any predecessor /related entity: (a) Describe the basis for said denial; (b) State whether or not there were ever any asbestos- containing products present at said site, which were manufactured, sold, distributed, installed, applied and/or specified by Defendant and/or any predecessor /related entity, within five (5) years of the times alleged by plaintiff; (c) State whether or not there were ever any nonasbestos-containing products present at said site, which were manufactured, sold, distributed, installed, applied and/or specified by Defendant and/or any predecessor /related entity, during the times alleged by plaintiff; (d) Identify any and all documents referring to, relating to, and/or reflecting the basis for said denial; and, (e) Identify each and every person known to you to knowledge and/or information concerning the basis for said denial. ANSWER: See response to Interrogatory #2. INTERROGATORY NO. 6: With respect to each and every piece /type of equipment (such as a vehicle, turbine, pump, aircraft etc.) that was manufactured, sold and/or distributed by Defendant and/or any predecessor / related entity that incorporated any asbestos-containing component and which has been identified