Document 5D3Vobo5Yoe01DDxnqN8GNRbV

if your answer to 63(e) is yes, when was the first date Defendant relied on the Fleischer-Drinker report in whole or in part for the proposition stated in 63(e) above? ANSWER; Abex objects to this interrogatory on the grounds that it is burdensome and overly broad. Subject to and without waiving these objections Abex states; Abex does not know precisely when, if ever, its management became aware of the above-referred article. Abex further states that it never manufactured or sold pipe covering. INTERROGATORY NO. 64; When, if ever, did Defendant or any of its predecessors-in-interest first receive a copy of the article entitled "A Study of Asbestos in the Asbestos Textile Industry", published in 1938 in Public Health Bill, No. 241, U.S. Public Health Service and authored by W.C. Dreessen ("the Dreessen Report")? a. Identify the name and position.of. the. employee or officer who received same; b. please produce all documents"generated by Defendant which discuss or in any way reference the."Dreessen" study prior to 1968; c. please produce all documents upon which your Answers above are based; d. please identify the name(s) and.,,.addr.essJes) of any person(s) who can verify your above Answer; e. did Defendant ever rely on the Dreessen Report in whole or in part as a basis that Defendant's asbestos products could be used in the workplace without risk of asbestos-related health impacts to the consumer and/or bystander; f. if so, please produce every document which evidences in any way that Defendant relied on the Dreessen Report in whole or NY1-86445. 03/31/95 2:34pm -56-