Document GKN0Qp6E39q7g4m5gBZ0bYR07

31* Knowledge/Mesothelioma Please state whether Defendant, prior to 1980, ever obtained any knowledge concerning the association, if any, between the inhalation of asbestos fibers and mesothelioma, in users, consumers and/or persons, exposed to asbestos and/or asbestos containing products. If so, please state: A. When any of this knowledge was first acquired, how it was acquired, identify by whom it was acquired, and state the substance of the knowledge acquired. B. As to each such occasion thereafter in which your knowledge as to mesothelioma increased either - relative to the types of exposures (i.e. trades and occupations, etc.) and/or types of products which became associated with the development of mesothelioma state: (1) when was this additional knowledge acquired; (2) how was this additional knowledge acquired; * (3) identify by whom it was acquired; (4) state the substance of the additional knowledge acquired; C. Identify all documents relevant to your acquisition of knowledge concerning mesothelioma and the custodian thereof; and. D. If any of the foregoing knowledge was acquired through an oral conversation, identify each such oral conversation, the approximate date of said conversation and the parties to said conversation. 65