Document 8VMK2KZRV9Qj1o1jKDokvqQ0d

"~v\ 1 (c) If said testimony was recorded. 2 RESPONSE: 3 Not to our knowledge. 4 INTERROGATORY NO. 83: 5 Please state the names and addresses of all distributors and 6 companies to which the defendant sold or distributed asbestos or 7 asbestos-containing products for the years 1930 to 1972. 8 RESPONSE: 9 OBJECTION. Interrogatory No. 83 is objected to on the 10 grounds that it is overly broad, burdensome, oppressive and calls 11 for a compilation or abstract of records which does not exist. 12 The burden and expense to this responding defendant to compile 13 the information sought, is not outweighed by the questionable 14 evidentiary value of the information sought. Additionally, this 15 defendant has maintained sales records only since 1976, there 16 fore, this defendant has no way of knowing with certainty to whom 17 its products may have been distributed over the several decades. 18 Without waiving said objection, and in the spirit of liberal 19 discovery, those companies to whom defendant sold asbestos-con 20 taining products are reflected in response to Interrogatory No. 21 122, in addition to NAPA. 22 INTERROGATORY NO. 84: 23 Please state whether defendant has knowledge of any material 24 which could be or is being used for the same purpose as asbestos. 25 Include in your answer when defendant discovered that said mate 26 rial could be used as a substitute for asbestos. 27 RESPONSE: NZO Q* 28 OBJECTION. ARD 1(61 Interrogatory No. 84 is objected to on the -42-