Document DOKQBreV8EO33KVOn1RqyVe4
11572-1000 MXY/dal
(b)
If applicable, identify the organization or association through which Defendant, its predecessor or related company, obtained the use of or access to, such library(ies).
ANSWER:
See Answer to Interrogatory No. 52, which is incorporated herein as if folly rewritten.
INTERROGATORY NO. 54: Has Defendant, any predecessor or any related company, or any person or entity acting on
behalf thereof, including but not limited to, any insurance company, at any time, conducted any industrial hygiene surveys concerning any product identified in response to Interrogatory No. 19, including, but not limited to, surveys concerning the manufacture, processing, application, installation, use and/or removal of said products? ANSWER:
See Answers to Interrogatory Nos. 43 and 56, which are incorporated herein as if folly rewritten. INTERROGATORY NO. 55:
Ifyour Answer to Interrogatory No. 54 is "yes," with respect to each such survey: (a) Identify the produces) which was used in the survey; (b) Identify any and all person(s), firm(s) or entity(ies) conducting or participating in the
conducting of said survey; (c) State the date(s) of said survey; (d) Describe the methodology, results and conclusions of said survey; (e) Identify any and all documents referring to, relating to, or reflecting said survey or
the results and conclusions thereof; and,
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