Document DRojo0LYMq5em4MwVvr7zz1N

INTERROGATORY NO. SI: Did your company or its predecessors) or subsidiaries ever stamp or place the name of the company, its initials, or any identifying logo on any of its asbestos-containing products? If so, please state the name brand names of such products, a description of such stamp or logo and the dates such were placed on the referred products. 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 does not know whether Smith & Kanzler Company has or ever had or whether its predecessors) or subsidiaries ever stamped or placed the name of the company, its initials, or any identifying logo on any of its asbestos-containing products. lujaRROGATORYNQ, 52: Has your company, or your predecessors) or subsidiaries, ever devised a research plan to develop, or actually developed or had developed, a product which did not contain asbestos and which could be substituted for one or more of your asbestos-containing products? If so, state the date that such research plan was begun and when such asbestos-free product was first placed on the market. 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 does not know whether Smith & Kanzler Company has or ever had or whether its predecessors) or subsidiaries ever devised a research plan to develop, or actually developed or had developed, a product which did not contain asbestos and which could be substituted for one or more of its asbestos-containing products. DEFENDANTS .RESPONSES TO PLAINTIFFS* MASTER INTERROGATORIES F:\KELLY\DISCVDANA.INT PAGE -39-