Document 4vrz0qrQ98n2maxRZXRKLrm2G

0510102*0 II I !! 1' for each such person you have identified, state the time periods 2 'each such person represented you. 3 ANSWER: objection - this is privileged, proprietary information. * Counsel in Seattle has in his possession the names and addresses and iwill deliver same for an inspection by the court and would agree to a " ireview of the list by plaintiff's counsel pursuant to an agreement of liconfidentiality and nondisclosure to other persons or parties including 6 (defendants in the present litigation without further order of the court {Western Brake is not a distributor, dealer, agent or manufacturing 7 (representative of S. K. Wellman. S. K. Wellman has no records of ,, isales to the Western Brake Co. 8i {, 10 i' 'i 1.21.1 If you are a defendant manufacturer, seller or 11 i!distributor of motor vehicles, identify! 12 ; ( 13 1 (a) The name and address of each and every 14 i; manufacturer from whom defendant or any of its 11 subsidiary companies obtained brake linings or 13 brake pads or brake facings for installation or I use in any motor vehicles manufactured or sold 16 I by defendant from 1950 through 1978; 17 ; 18 I, 19 l| j! 20 lj 21! 22 j 23 ;iI1 24 (b) The name and address of the distributor or seller from whom defendant or any of its subsidiary companies obtained brake linings, brake facings or brake pads for use in any motor vehicles manufactured or sold by defendant from 1950 through 1978; (q) The type, including dimensions, and brand name of each brake lining, brake facing or brake pad defendant or any of its subsidiary companies purchased or obtained for use in any motor vehicles manufactured or sold by defendant from 1950 through 1978, and from whom each such product was purchased or otherwise obtained; 25 26 PLAINTIFF'S FIRST INTERROGS, ETC. - 20