Document 7MVZv7BENd8MJ07y5ndxMODqj

\ 'S I 1 RESPONSE: 2 OBJECTION. Interrogatory No. 69 is objected to on the 3 grounds that it is overly broad, vague, ambiguous and unintelli 4 gible. Without waiving said objection, and in the spirit of 5 liberal discovery, defendant refers the plaintiff to Exhibit "C" 6 appended to these answers to interrogatories. 7 INTERROGATORY NO. 70: 8 Please state the manner in which the asbestos-containing 9 products it-mufactured by defendant were arched since 1930. 10 RESPONSE: 11 OBJECTION. Interrogatory No. 70 is objected to on the 12 grounds that it is overly broad, vague, ambiguous and unintelli 13 gible with respect to the use of the undefined word "arched." 14 Additionally, the interrogatory calls for information which is 15 not reasonably calculated to lead to the discovery of admissible 16 evidence. 17 INTERROGATORY NO. 71: 18 Is defendant aware of articles authored by W. C. Dressen in 19 Public Health Bulletin No. 241 of 1938, establishing threshold 20 limit values for airborne asbestos fibers? If so, when did de 21 fendant first learn of the above-mentioned article? 22 RESPONSE: 23 Articles by W. C. Dressen established threshold limit values 24 for airborne asbestos particles, not specifically fibers. ABEX 25 became aware of the articles published in the "Criteria for a 26 Recommended Standard Occupational Exposure to Asbestos" from the 27 U.S. Department of Health, Education, and Welfare, Public Health NZO o*. 28 III Aft o '6i -37-