Document 74Dxoma2d5DzG3MeaJjeb1za

used since 1974. Boxes with the name "Goodwrench" and colors of black and gray on white have been used since 1985. In addition to the brand name, the box or a label contains a boxmaker's certificate and box number. INTERROGATORY NO-32; Has Defendant or ahy of its subsidiary or predecessor companies at any time entered into a "rebranding" agreement with any other company, either as buyer or seller, concerning asbestos materials or asbestos products? If so, state, as to each such agreement: (a) The name of the company manufacturing the asbestos products. (b) The trade name affixed to those products. (c) The periods of time covered by each such agreement. (d) The volume, in dollar amount, of each transaction. (e) The initial purchaser of the products. RESPONSE: General Motors has not found agreements under which it relabeled asbestos-containing friction products that it manufactured so they could be sold by another company. GM objects to this interrogatory because it is vague, overly broad, burdensome and will not lead to admissible evidence. INTERROGATORY NO. 33: List the name and address of each company from which Defendant or its subsidiary or predecessor purchased materials or asbestos products which Defendant sold or distributed in any form, stating the form of the materials, the dates of such purchases, and the ultimate disposal of such materials. 28