Document Ex0g5vybZVpZ3aGjq0y05zNjR

INTERROGATQRYJjQ, 43: Based upon the material contents of your asbestos-containing products, the method of. manufacturing, and the method of application, can such products be generally applied without liberating asbestos fibers into the air? (a) If there is a different answer concerning different products manufactured, sold, distributed, or used by your company, then specify the different products by precise manufacturer's name and popular name. (b) If there is a difference in your answer depending on the year or years in which a particular product was used, then specify in detail what year or years you are referring to and the specific products you are referring to and year involved. See answer to Interrogatory 6, which is incorporated herein as if fully rewritten. Subject to and without waiving objections, Dana does not know whether Smith & Kanzler Company products can be generally applied without liberating asbestos fibers into the air. ^ROGATORY NO. 44: Was it a foreseeable use of your asbestos-containing products that they may have been removed, stripped, or replaced at some time after installation? 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. Further objecting, the terms "foreseeable" and "at some time" are vague, ambiguous and undefined. Subject to and without waiving objections, Dana does not know whether it was a foreseeable use of Smith & Kanzler Company's asbestoscontaining products that they may have been removed, stripped, or replaced at some time after installation. INTERROGATORY NO. 45: Before 1970, did you or your subsidiaries or predecessors) ever arrange for any labor inspectors, insurance company inspectors or anyone from your company to go to job sites where DEFENDANT'S RESPONSES TO PLAINTIFFS* MASTER INTERROGATORIES F:\KELLY\DISODANA-INT PAGE -35-