Document 91JN12zpmMDG9xLOLG4X7ndyR

asbestos-containing products in Ohio from 19S0 to 1974. For each of those companies, please state the following: a) The name and address of each such company; b) the date of each sale from Defendant to such other company; c) The name ofthe person at each other company with whom Defendant primarily dealt. d) Names and quantities of the asbestos-containing products that you marketed, distributed, installed, and/or sold to each such company from 1950 to 1974. ANSWER: Westinghouse incorporates by reference its Preliminary Statement and General Objections. Westinghouse further objects to responding to this Interrogatory concerning any products not alleged to have contributed to the alleged injuries of plaintiffs), on the grounds that the Interrogatory, as applied to Westinghouse, is overly broad and unduly burdensome and seeks information which is irrelevant and immaterial to these proceedings and is not reasonably calculated to lead to the discovery of admissible evidence. If a particular plaintiff will specifically and credibly identify the Westinghouse product(s) alleged to have given off respirable asbestos fibers in his or her presence, Westinghouse will endeavor to answer this Interrogatory for such produces), if any, to the extent Westinghouse reasonably can do so. 8.4 Does Defendant have records and/or any knowledge that reflects sales of their asbestoscontaining products to ARMCO/A.K. Steel Middletown Plant and/or ARMCO/A.K. Steel Hamilton Plant? If so, please state: a) The names and last known addresses of those people with such knowledge. b) The location of such records. ANSWER: Westinghouse incorporates by reference its Preliminary Statement and General Objections. Westinghouse further objects to responding to this Interrogatory concerning any products not alleged to have contributed to the alleged injuries of plaintiffs), on the grounds that the Interrogatory, as applied to Westinghouse, is overly broad and unduly burdensome and seeks information which is irrelevant and immaterial to these proceedings and is not reasonably calculated to lead to the discovery of admissible evidence. If a particular plaintiff 13