Document 5L7d46YrdjmZjBRd1Byd0ZXj8

(iv) The method or manner in which such publications are maintained. ANSWER: See Preliminary Statement and General Objections, which are incorporated herein as if fully rewritten. Further objecting, die interrogatory is overly broad given die parameters and subject matter of this case. Further objecting, the information sought is neither relevant to the subject matter of the pending action nor reasonably calculated to lead to the discovery of admissible evidence as it relates to Dana. Further objecting, the interrogatory is vague, ambiguous and argumentative. Subject to and without waiving objections, Dana believes that Smith & Kanzler Company was a member of or affiliated with the. Sprayed Mineral Fibre Manufacturer's Association, Inc. INTERROGATORY NO. 21: Identify by name and location each plant or manufacturing facility in which the products listed in your answers to Interrogatory Nos. 3-6 were manufactured, assembled, or prepared for sale or marketing, specifying which plants produced each item, the dates each plant is or was in operation, and the time span during which each named item was produced or manufactured. ctvia See Preliminary Statement and General Objections, which are incorporated herein as if fully rewritten. Further objecting, the interrogatory is overly broad given the parameters and subject matter of this case. Further objecting, the information sought is neither relevant to the subject matter of the pending action nor reasonably calculated to lead to the discovery of admissible evidence as it relates to Dana. Subject to and without waiving objections, from September 1967 until February 1969 Smith & Kanzler Company owned and operated a plant in Linden, New Jersey in which asbestos-containing products were manufactured, assembled, or prepared for sale or marketing. INTERROGATORY NO. 22: Have printed sales materials been prepared by Defendant or any of its subsidiary or predecessor companies or their agents for purposes of marketing or advertising products containing asbestos? If so, state: (a) The name, address, and job title of each person or entity who prepared such materials. DEFENDANT'S RESPONSES TO PLAINTIFFS* MASTER INTERROGATORIES F:\KELLY\DISC\DANA.INT PAGE -18-