Document 5b0ZLqxQJ9Drx5ZXgg8bvveNe

INTERROGATORY NO. 38: State whether you or any of your predecessors and/or subsidiaries maintain, from 1940 through die present or for any portion thereof, copies of invoices, shipping documents, bills of lading, purchase orders, or other documents of a similar nature relating to the mining, manufacture, marketing, sale or distribution of asbestos products. If so, state: (a) The location of such documents. (b) The name and address of the custodian of the documents. (c) The format in which the documents are kept, i.c.. hard copy, microfilm, microfiche, etc. (d) In what form the documents can be accessed, ie^, by state, by product, etc., and if by product, whether kept according to asbestos or non-asbestos. ANSWER: 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, Dana does not know whether Smith & Kanzler Company or any of its predecessors and/or subsidiaries maintain, from 1940 through the present or for any position thereof, copies of invoices, shipping documents, bills of lading, purchase orders, or other documents of a similar nature relating to the mining, manufacture, marketing, sale or distribution of asbestos products. INTERROGATORY NO. 39: Will you call company representatives as witnesses at the trial of any of these cases? If so, list: (a) The name, address, and job title of each company representative who may be called. (b) A summary of the testimony expected to be given by each such witness. (c) List any and all previous times that the named witnesses have either given deposition or trial testimony in an asbestos-related case, including the jurisdiction, DEFENDANTS RESPONSES TO PLAINTIFFS* MASTER INTERROGATORIES F:\KELLY\DISC\DANA.INT PACE -32-