Document DdMeQgaanKGzrGo87MGJvb0jM

C 05IOI02C 1 REQUEST FOR ADMISSION L: You were aware as early as 1979 2 that one or more individuals had filed workmen's compensation 3 claims alleging injury or disease as a result of exposure to 4 asbestos while employed at one or more of your facilities. 5 RESPONSE: Admitted. 6 7 a 9 REQUEST FOR ADMISSION M: You were aware as early as 1980 10 that one or more individuals had filed workmen's compensation 11 claims alleging injury or disease as a result of exposure to 12 asbestos while employed at one or more of your facilities. 13 RESPONSE: S&s j-ggponse to Request for Admission L. 14 15 16 17 REQUEST FOR PRODUCTION Q: Pursuant to CR 34, attach or 18 produce according to the above instructions annual summaries of 19 compensation claims analyzed by nature of claims, lost time, 20 disposition and -the like. 21 22 RESPONSE: irrelevant objection. 23 24 25 26 PLAINTIFF'S FIRST INTERROGS, ETC. - 69 I I i t . * ; ; t i I i j ! I j ii I i