Document JN8MmVo1nYzg922Q88L5Gzpwr

its assembling facility and bonding shops. Wagner has never had an industrial hygienist as an employee. INTERROGATORY NO. 39: Please state if the defendant's medical officers or industrial hygienists ever made any recommendations and/or sug gestions to the defendant pertaining to the risks or hazards to persons involved m the manufacturing or use of products con taining asbestos? If so, please state: (a) Where were such recommendations and/or sugges tions made? (b) To whom were such recommendations and/or sugges tions made? (c) By whom were these recommendations and/or sugges tions made? (d) The substance of the recommendations and/or sug gestions made? RESPONSE TO INTERROGATORY NO. 39: See Wagner's response to interrogatory No. 36. INTERROGATORY NO. 40: Please state the names of trade association periodicals to which defendant subscribed from 1930 to 1972. RESPONSE TO INTERROGATORY NO. 40: Wagner objects to this Interrogatory to the extent it seeks information outside the Plaintiff's alleged exposure peri od. Subject to that objection, Wagner states that it has sub scribed to the perodicals issued by the American Trucking Asso ciation, American Association of Motor Vehicle Administrators, Automotive Warehouse Distributors Association, Motor equipment Manufacturers' Association, Automotive Service Industry Associa tion, Automotive Parts and Accessories Association, and the distributors Institute, among others.