Document 6RGjqKazaw90Djx5RZ3V9qdrg
c 0 5 1010 2 ''^
1 SECTION 4.0
2
3 4.01 Does or did defendant provide pulmonary function
4 tests on its asbestos-exposed workers?
5
6 Yes.
7
8
9 4.02 If the answer to the foregoing interrogatory is in
10 the affirmative, state:
11 (a) The nature of such program(s);
12 (b) Whether such program was optional or mandatory;
13 if mandatory, when it became so;
14 (c) The location(s) of such program(s);
15 (d) The date of service of such program(s);
16 (e) If any of the program(s) have undergone modification, the nature and dates of such
17 modification;
18 (f) The custodian (by name, address and position) of records of such pulmonary function test
19 program(s);
20 (g) The highest level of management (by name, * address and position) who participated in the
21 decision to institute such prograra(s).
22
23
24
25
26 PLAINTIFF'S FIRST INTERROGS, ETC.
70
*
'