Document 5L2KvM3nEYyvJ7kEm1YL7LwZ4

1 RESPONSE: 2 Not applicable by virtue of the objection interposed in 3 response to Interrogatory No- 15. 4 INTERROGATORY NO. 17; 5 If the answer to Interrogatory No. 16 is affirmative, please 6 state: 7 (a) The nature of the change made; 8 (b) The name, address, and job classification of each 9 person ordering the change in design. 10 RESPONSE: 11 Not applicable by virtue of the objection interposed in 12 response to Interrogatory Nos. 15 and 16. 13 INTERROGATORY NO. 18: 14 Has defendant, at any time since 1930, published and/or 15 distributed any brochures, sales literature, pamphlets, or other 16 written materials of any kind that contain any warnings, cau 17 tions, caveats or directions concerning the possibility of injury 18 resulting form the use of the products listed in Interrogatory 19 No. 10, above? If so, identify each brochure, sales literature, 20 pamphlet or other written material and the date of publication 21 and distribution. 22 RESPONSE: 23 Yes. Since 1972, all asbestos-containing products were 24 accompanied by warning labels affixed to the package in which the 25 product was contained. Additionally, documents falling within 26 the scope of this interrogatory were produced by defendant at the 27 deposition' of Charles Mallory in 'Washington, D.C. on June 11, HZO 28 1984. AR O u6i