Document DvkQp79OnLJYBnG6MJ4LGO0bQ

h /1 OBJECTION Defendant refers the plaintiff to the objection set forth in Response to Interrogatory No. 40, supra, and incor porates the same by reference herein as though fully set forth. Without waiving said objection and, in the spirit of liberal discovery, defendant responds that it appears that in or about 6 1936, American Brake Shoe and Foundry Company agreed to contribute 7 monies to a study to be conducted by Dr. LeRoy Gardner at Saranac 8 Laboratory, Saranac Lake, New York, and in 1937, American 9 Brake Shoe and Foundry Company committed $250 per annum for three 10 years by way of contribution. 11 INTERROGATORY NO. 44: 12 Please state whether the defendant had a department, divi 13 sion or section devoted to scientific and/or medical research 14 during the period from 1930 until the present time. 15 RESPONSE: 16 OBJECTION. Interrogatory No. 44 is objected to on the 17 grounds that it is overly broad, vague, ambiguous and unintelli 18 gible. Without waiving said objection and, in the spirit of 19 liberal discovery, this defendant will respond that it did not 20 have a department, division or section specifically devoted to 21 medical research during the indicated time period. 22 INTERROGATORY NO. 45: 23 Please state the scientific or medical periodicals to which 24 the defendant, its medical department or industrial hygiene divi 25 sion subscribed during the period between 1930 and 1972 specify 26 ing the date said subscriptions were begun. n7 RESPONSE: n:o 28 OBJECTION. Defendant refers the plaintiff to the rejection *0 60 'h n