Document BR0w0BjGELo5wY8aYggBo7EoE

' 37. Has defendant ever had a department or departments which had responsibility for, or were engaged in, the preparation and dissemination of warnings and/or instructions respecting health hazards relative to asbestos exposure, to auto dealerships, service stations, repair shops and/or to auto workers and/or mem bers of the general public? If so, state as to each applicable department: (a) the name and address of the department; (b) the dates each such department was so involved; (c) a detailed description of all activities conducted by each said department; (d) the name, address and present job title of the party responsible for such department at any time from 1920 to the present; (e) a detailed description of all actions undertaken by defendant as a result of any report or communication received from said department; (f) the annual cost of the department; (g) the title, author, date and substance of all re ports or any other written communications promulgated or drafted JLn said department, as well as the name, address, and job title of the present custodian of all such reports or communications .(or alternatively attach copies of same hereto); (h) the substance of all oral reports or communica tions by said department as well as the name, address, and job title of the parties involved in said report or communication; (i) the title, author, date of issue, and substance of any and all warnings and/or instructions promulgated, drafted or disseminated by the department. ANSWER: See answer to Interrogatory 10(e), supra, for the substance of current warnings and instructions issued by GM. (a) GM has departments which are responsible for the preparation and dissemination of warnings and instructions relating to GM products. However, there is no single de partment specifically charged with responsi bility for the development of warnings re garding "health hazards relative to asbestos exposure". B002 0S<*3 PRODUCED BY FORD