Document 91w4VZEgz65gM2bqDwXROzKdV
0510 1031*1.
1`
REQUEST FOR ADMISSION LL: You were aware as early as 1960 2
of research, studies and/or articles indicating a causal connection 3
between asbestos exposure and 4
* (a) asbestos is;
5
i (b) lung cancer;
6i
II
ll
(c) mesothelioma;
7
1 (d) forms of cancer other than lung cancer.
a*
'l RE S PONS E: Denied.
10
11
12 REQUEST FOR ADMISSION MM; You were aware as early as 1970
13 . of research, studies and/or articles indicating a causal connection
14 between asbestos exposure and
15 (a) asbestosis;
16 17 (b) lung cancer; 18 (c) mesothelioma; 19 (d) forms of cancer other than lung cancer. 20 RESPONSE: Admitted as to (a) and (c). We are unclear as to what you are
j; referencing in fb) and (d) and therefore deny the same. 21 i'
22 I
23 .
24 :
25
26 PLAINTIFF'S FIRST INTERROGS, ETC. - 92
i