Document GmwrZoOOYZwvdGw6rRVLVjDJN

j 1 defendant's asbestos--containing mechanical parts for the years 2 1930 to 1972. 3 RESPONSE: 4 Based upon information available at this time, defendant 5 responds that it does not believe so. 6 INTERROGATORY NO. 110: 7 Please list the names and addresses of all insurance carri 8 ers which provided Workers' Compensation coverage for occupa 9 tional diseases for defendant's employees, including automobile 10 repair employees, between the years of 1930 and 1972. 11 RESPONSE: 12 OBJECTION. Interrogatory No. 110 is objected to on the 13 grounds that it is overly broad, burdensome and oppressive. The 14 burden and expense to this defendant to compile the information 15 sought is not outweighed by the questionable probative value of 16 the information sought. The information requested is not rele 17 vant and not reasonably calculated to lead to the discovery of 18 admissible evidence. 19 INTERROGATORY NO. Ill: 20 At any time during the period 1948 to 1978, has defendant 21 manufactured automobile undercoat sealer? If so, please state: 22 (a) The trade or brand name(s) under which the 23 undercoat sealer was marketed; 24 (b) The years during which the undercoat sealer, under 25 each trade or brand name, was manufactured; 26 (c) The dates each product listed in (a) was withdrawn 27 from the market; NZO o*. 28 AflO H6 III 60 -50-