Document BvGr7vJ3pzQ5DajqvqqkXexQo

INTERROGATORY NCL35: Prior to 1968, did any person file a claim against a Worker's Compensation carrier covering Defendant or any of its subsidiaries or predecessors alleging that he/she contracted a disease from inhaling asbestos fibers? If so, provide: (a) A list of the claims, including each such claimant's name, address and the date each claim was filed, and including the caption and jurisdiction of the claim. (b) The disease alleged in each such claim. (c) A brief summary of the disposition of each such claim. (d) The name, address and title of the person having custody of the records pertaining to each such claim, ANSWER: See Preliminary Statement and General Objections, which are incorporated herein as if fully rewritten. Subject to and without waiving objections, Dana does not presently believe that, prior to 1968, any person filed a claim against a Worker's Compensation carrier covering Victor Products Division alleging that he/she contracted a disease from inhaling asbestos fibers. INTERROGATORY NO. 36: Did Defendant or any of its subsidiaries or predecessors maintain written minutes of ** corporate meetings, either board of directors, departmental, or otherwise, which reflect discussions pertaining to any subject matter related to asbestos, asbestos health hazards or asbestos products?. If so, for each such set of minutes, state: (a) The dates of each such meeting. (b) The general subject matter discussed at each meeting. (c) Who was in attendance at each meeting. (d) Where and by whom the written minutes are presently maintained. (e) By whom the minutes were taken and put into final format. 27 DEFENDANT'S ANSWERS TO PLAINTIFFS' MASTER INTERROGATORIES AND REQUESTS FOR PRODUCTION