Document J3Kv2zRxX0wdo7vrg0zLDvwYr

GM has no way of determining when one of its hundreds of thousands past and present employees may have received this article. INTERROGATORY NO. 64: When, if ever, did Defendant or any of its predecessors-ininterest first receive a copy of the article entitled "A Study of Asbestos (sic) in the Asbestos Textile Industry", published in 1938 in Public Health Bill (sic). No. 241, U.S. Public Health Service and authored by W. c. Dreessen ("the Dreessen Report")? (a) Identify the name and position of the employee or officer who received same; (b) Please produce all documents generated by Defendant which discuss or in any way reference the "Dreessen" study prior to 1968 ? (c) Please produce all documents upon which your responses above are based; (d) Please identify the name(s) and address(es) of any person(s) who can verify your above response; (e) Did Defendant ever rely on the Dreessen Report in whole or in part as a basis that Defendant's asbestos products could be used in the workplace without risk of asbestosrelated health impacts to the consumer and/or bystander; (f) If so, please produce every document which evidences in any way that Defendant relied on the Dreessen Report in whole or in part for the proposition stated in Interrogatory No. 63(a) above; (g) If your answer to 63(e) is yes, when was the first date Defendant relied on the Dreessen report in whole' or in part for the proposition stated in 63(e) above? RESPONSE: A reference to the Dreessen article was made in an Industrial Hygiene Department report written in late 1939 or 1940. It is not known when the article was received. 47