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 aD r. 61 No. i i i j i 5-