Document 9JOJ2q9X6k6z3ELYrg6jwGBG7
1 respect to the terms "warnings," "cautions," "caveats" or "direc 2 tions." Without waiving said objection, and in the spirit of
3 liberal discovery, this defendant will respond that with respect
4 to cautions concerning asbestos, all asbestos-containing products
5 manufactured, distributed or supplied by this defendant since
6 1972, did have warning labels complying with the OSHA mandate.
7 (g) Please refer to objection and response contained
8 in subpart (f).
9 INTERROGATORY NO. 5:
10 If the answer to Interrogatory No. 3 is no, please
11 state:
12 (a) From what sources has defendant obtained asbes
13 tos-containing products since 1930?
14 (b) Whether any warnings, cautions, caveats or direc
15 tions accompanied the material referred to in (a);
16 (c) The nature and extent of said warnings, cautions,
17 caveats or directions accompanying said asbestos materials;
18 (d) Approximately what date said warnings, cautions,
19 caveats or directions first appears [sic] on the manufactured
20 asbestos materials.
21 RESPONSE:
22 Not applicable.
23 INTERROGATORY NO. 6:
24 Has defendant, at any time from 1930 to the present, engaged
25 in the mining and/or milling of material containing asbestos
26 fibers ?
27 RESPONSE: '
o-
28
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