Document ByvvgOOdj03OmeMr3vg7b6VrX

1 cation or for disc brake applications predating recent design 2 changes. 3 INTERROGATORY NO. 85: 4 Please state whether this defendant has distributed any catalogs, brochures, pamphlets or other advertising materi 5 als regarding its asbestos-containing products between 1930 and 1972. 6 RESPONSE TO INTERROGATORY NO. 85; 7 Wagner objects to this interrogatory on the grounds 8 that it is overly broad, unduly burdensome and not calculated to 9 lead to the discovery of admissible evidence. 10 INTERROGATORY NO. 86: 11 Does defendant advertise its asbestos-containing prod 12 ucts by any media whatsoever. 13 RESPONSE TO INTERROGATORY NO. 86; 14 Wagner objects to this interrogatory on the grounds 15 that it is overly broad, unduly burdensome and not calculated to 16 lead to the discovery of admissible evidence. 17 INTERROGATORY NO. 87; 18 Please state whether defendant sold any asbestoscontaining products to any United States governmental agency 19 between 1930 to 1972. If so: 20 (a) List the name and address of each such agen cy; 21 (b) The dates of each sale; 22 (c) The final government destination of each 23 product sold; 24 (d) The type and serial or model number of prod ucts sold or distributed to said agencies. 25 RESPONSE TO INTERROGATORY NO. 87: 26 Wagner objects to this interrogatory on the grounds 27 that it is irrelevant, is not calculated to lead to the discov28 35