Document BR9yZ2aja10yQ4jYVXRpQBB28

1 matter of this action and is not calculated to lead to the dis 2 covery of admissible evidence. 3 INTERROGATORY NO. 21: 4 Does defendant have any records indicating that any of its asbestos-contaning products were sold or distributed to any 5 of the defendants named herein? 6 RESPONSE TO INTERROGATORY NO. 21: 7 Wagner objects to this Interrogatory on the grounds 8 that it is overly broad and unduly burdensome m that it does 9 not identify for which Wagner products it seeks information and, 10 is not relevant to the subject matter of this action and is not 11 calculated to lead to the discovery of admissible evidence in 12 that it is not limited to Wagner products to which Plaintiff 13 alleges exposure. 14 INTERROGATORY NO. 22: 15 If answer to Interrogatory No. 21 is affirmative, please state: 16 (a) the name, address, and 30b classification of each 17 individual who currently has possession of such records; 18 (b) The names of each defendant named herein to whom your products have been sold or disributed; 19 (c) The dates of each such sale; 20 (d) the amount and type of materials sold or distrib 21 uted; 22 (e) Whether defendant manufactured asbestos- containing products for any other business entity but placed 23 labels or logos not belonging to this defendant on said subsec tion. 24 RESPONSE TO INTERROGATORY NO. 22: 25 See Wagner's response to Interrogatory No. 21. 26 INTERROGATORY NO. 23: 27 Does defendant have policies of insurance that cover 28 the claims that have been made by plaintiff herein? I 12