Document 44eOnkgd7K8yZxbZ4r5QKr4qN

(e) Identify all documents that you have provided to each person identified in response to subparagraph (a) above; (f) Describe in detail the education and work history of, and identify any books, treatises, articles, published and unpublished reports, studies or other scholarly works authored by any individual identified in response to subparagraph (a) above. Alternatively, in lieu of said response, attach a copy of a resume or curriculum vitae and a list of publications to your answers. RESPONSE: GM's investigation and discovery are continuing. GM and its lawyers have not yet decided what witnesses, evidence or experts GM may use at trial. GM will provide this information as required under the Texas Rules of Civil Procedure or by any order of the court. GM also objects to this interrogatory because it asks for the trial strategies and tactics of GM's lawyers and other similar information protected from disclosure by the work product doctrine. INTERROGATORY NO. 61: Please state the name, present address and present telephone number, along with the experience and qualifications, if applicable, of each and every person, known to Defendant or to Defendant's agents, having knowledge of facts relevant to these cases involving, but not limited to: (a) Identification of asbestos-containing products to which each and every individual Plaintiff, separate and distinct from all other Plaintiffs within the group, allegedly was exposed or facts disputing the identification of asbestoscontaining products in this case. (b) Each and every individual Plaintiffs, separate and distinct from all other Plaintiffs within the group, alleged damages, injuries and/or facts disputing each and every Plaintiffs alleged damages and/or injuries; (c) The negligence of any person or entity other than Defendant which Defendant contends was a cause of each and every individual Plaintiffs, separate and distinct from all other Plaintiffs within the group, alleged injuries and/or damages; DEFENDANT GENERAL MOTORS CORPORATION'S RESPONSES AND OBJECTIONS TO PLAINTIFFS' MASTER INTERROGATORIES AND REQUESTS FOR PRODUCTION-Paee 54 J0J66 0S491 LIT 178211