Document G6ndq4XEQvNggpyk2Dnv3Q0ax

12. Asbestos/Facilities For the period 1920 to date, or during the period that Defendant mined, manufactured, sold or distributed asbestos containing products, whichever period is less, state the following regarding each facility that was used by you as a mining, milling, manufacturing, processing, distribution or marketing facility for asbestos containing products; A. The name and address of the building, mine, mill or facility; B. The inclusive dates the facility was in operation; and. C. The function of the facility (e.g., manufacturing, warehousing, mine, sales office, etc.) D. Plant managers and years of management; E. Name and type of asbestos-containing products manufactured or processed at each facility; F. Identify shipment records for each facility and the custodian thereof; G. If asbestos was mined and sold to any other entity besides this Defendant, please provide list of those entities. RESPONSE TO MASTER INTERROGATORY 12: See Preliminary statement and General objections. Further objecting, this interrogatory is overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving objections, see response to Interrogatory 14(1). 17