Document DGaZ76yejJQYbDZj89mKxmrLO

To the extern this interrogatory asks for more information, GM objects because it is overly broad, vague, burdensome, and is not reasonably calculated to lead to the discovery of admissible evidence. INTERROGATORY NO. 15: Before 1970, had you received notice that any individual or individuals, other than those Plaintiffs who have filed personal injury actions in Dallas County, Texas, is or are claiming or has or have claimed an injury as a result of using asbestos products manufactured and/or sold by your company or any of its predecessors or Subsidiaries before 1970? If so, state: A. The name and address of each claimant. B. The date of notice of each claim. C. A description of the claim. D. The type of injuries allegedly sustained. E. The name and address of each attorney who represents each individual making a claim. F. The style and court number of each claim. G. The disposition of each claim that has been settled or taken to judgment. RESPONSE: GM has not found any record of a product liability lawsuit or claim alleging injury from exposure to asbestos from a GM product before 1970. INTERROGATORY NO. 16: Were your asbestos products distributed, marketed, packaged, labeled and/or sold by companies other than your own? If the answer is affirmative, list the names and addresses of each of those companies, and the products in question. DEFENDANT GENERAL MOTORS CORPORATION'S RESPONSES AND OBJECTIONS TO PLAINTIFFS' MASTER INTERROGATORIES AND REQUESTS FOR PRODUCTION-Page 16 30366 05491 LIT 178211