Document DD9Y93Nyw1MnoeEnz19QK4gyN

form, stating the form of the materials, the dates of such purchases, and the ultimate disposal of such materials. ANSWER: See Preliminary Statement and General Objections, which are incorporated herein as if fully rewritten. Further objecting, the interrogatory is overly broad given the parameters and subject matter of this case. Further objecting, the information sought is neither relevant to the subject matter of the pending action nor reasonably calculated to lead to the discovery of admissible evidence as it relates to Dana. Subject to and without waiving objections, Dana has little knowledge concerning Smith & Kanzler Company's operations but believes that it may have purchased raw asbestos from several suppliers including Philip Carey and Johns-Manville of Canada. INTERROGATORY NO. 34: Does Defendant or any of its subsidiaries or predecessor currently have possession of any writings or contracts on those rebranding agreements set forth in the answer to Interrogatory No. 32? If the answer is affirmative, state: (a) The name, address, and job title of each person having custody of each of those documents ami their current location. (b) A brief description of each such document, including the dates and the parties signatory. ANSWER: See response to Interrogatory No. 32, which is incorporated herein as if fully rewritten. INTERROGATORY NO- 35: 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. DEFENDANTS RESPONSES TO PLAINTIFFS' MASTER INTERROGATORIES F:\KELLY\DISODANA.INT PAGE -29-