Document EqpdoQzG5ZdeZvxp6zEoKQYxx

INTERROGATORY NO. AAl Was it foreseeable use of your asbestos-containing products that they may have been removed, stripped, or replaced at some time after installation? RESPONSESi Brake linings wear out and it is expected that they will be replaced. INTERROGATORY NO. 45; Before 1970, did you or your subsidiaries or predecessor(s) ever arrange for any labor inspectors, insurance company inspectors or anyone from your company to go to job sites where your products were being used or installed to make or take dust level counts? If so, state when this procedure started, the purpose of such procedures, and all results of such procedures. RESPONSES: GM made measurements at its own facilities, but GM had no right to inspect work sites owned and operated by others. INTERROGATORY NO. 46: If Defendant performed or had performed any dust level counts, what action, based on the results, did your company take? RESPONSE; See response to 8. INTERROGATORY NO. 47; Has your company or its subsidiaries or predecessor(s) ever conducted or caused to be conducted any studies designed to assist 37