Document 6BRNXw8JLN4mKx5beNGeR7vx3

INTERROGATORY NO. 18: Before 1974, did Defendant ever furnish any papers, documents, internal memoranda, or other writings concerning asbestos-related diseases and/or the health hazards of inhaling asbestos dust and fibers, to the United States Navy or United States Naval Facilities? Zf so, identify the writings and the dates they were so furnished. 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, before 1974, ever furnished any papers, documents, internal memoranda, or other writings concerning asbestos-related diseases and/or the health hazards of inhaling asbestos dust and fibers, to the United States Navy or United States Naval facilities. INTERROGATORY NO, 19: Did Defendant ever provide any information to a military or other governmental entity concerning the health hazards of inhaling asbestos dust and fibers that was used, or was intended to be used, in the drafting of military specifications for the use of asbestoscontaining products? 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 ever provided any information to a military or other governmental entity concerning the health hazards of inhaling asbestos dust and fibers that were used, or were intended to be used, in the drafting of military specifications for the use of asbestos-containing products. pEFENPANT'S RESPONSES AND OBJECTIONS TO PLAINTIFFS INTERROGATORIES AND REQUESTS FOR PRODUCTION f:\aeb3\rogs.all Page 14