Document 6wDRLBBMka1M29MkNZJg8RvJg
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1 REQUEST FOR ADMISSION NN: You were aware as early as 1975
2 of research, studies and/or articles indicating a causal connection
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between asbestos exposure and 4
(a) asbestosis; 5'
6j; (b) lung cancer;
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(c) mesothelioma;
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(d) forms of cancer other than lung cancer.
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Admitted as to (a) and (c). We are unclear as to what you are 9 referencing in (b) and (d) and therefore deny the same.
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4.19 Have you ever lobbied for or participated in the 13
lobbying for, or in the creation of, governmental/legislative 14
remedies for abestos-related lung diseases? 15
ANSWER: 16
No.
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4.20 If_your answer to the preceding interrogatory is in
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iit r
the
affirmative,
state
in detail:
23 ' (a) The form such lobbying took; i
24 (b) All person(s) acting on behalf of defendant;
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26 PLAINTIFF'S FIRST INTERROGS, ETC. - 93
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