Document 711vXY6LejzebKQJJeeLYqDBe

(d) State the date or dates upon which said test was conducted; (e) Identify any and all documents referring to, relating to or reflecting said test or the results thereof; and (f) Identify each and every individual who received a copy of any document referring to, relating to or reflecting the results of said test. SECOND AMENDED ANSWER TO INTERROGATORY NO. 44: See Objections and Answer to Interrogatory No. 43, which are incorporated by reference as though set forth herein in full. INTERROGATORY NO. 45: Did any person, including but not limited to, an officer, agent or employee of Defendant, any predecessor or related company recommend any design changes as a result of any test referenced in your response to the preceding interrogatory? SECOND AMENDED ANSWER TO INTERROGATORY NO. 45: See Objections and Answer to Interrogatory No. 43, which are incorporated by reference as though set forth herein in full. INTERROGATORY NO. 46: If your answer to Interrogatory No. 45 is "Yes," with respect to each such recommended design change; (a) State the product or products involved; (b) State the test or tests involved; (c) State the nature of the change recommended; (d) Identify the person(s) making the recommendation; (e) State the nature and effective date of any change made; and (f) Identify each and every person who participated in the decision to make or not make the recommended design change. 81