Document Jr71pNNVpEvY5RBxrab2NGdVa

/' --------------------------------------- t: ZITIS/PpTF.hMAM- THIOKOL CHEMICAL ANS TO ROGS ' V.i / 13. Has defendant ever sold, supplied, or distributed any asbestos .yoduct to any automobile dealership, wholesaler, retailer, distributor, i -anufacturer, or service station, at any time from 1940 to 1975? If so, js to each type of asbestos product sold, supplied, or distributed .by:..' defendant, set forth; s-. UK. -U* a. the generic, manufacturers, trade and/or brand name; Automobile dii_biyiie pads b. the inclusive dates defendant sold, supplied, or distributed each type; 1959 to present c. the type, grade, weight, and percentile of asbestos within each; and if there was ever any change in the type, grade, weight or percentile of asbestos utilized within any of the aforesaid products, set forth the type, grade, weight, and percentile of asbestos both before and after the change, and state the respective date of each such change; Object to question cr. ground that information sought is considered proprietary. d. the quantity per year sold, supplied,'and distributed by ' defendant; Use C ` e. a detailed description of each type, describing the color!, shape, and dimensions cf the product, as well as setting forth all distinguishing markings, names, symbols, designs, lettering or other writing thereon; Disc brake pads cf various configurations. f. a detailed description of the type of packages in which defend ant sells, distributes, or supplies the product, particularly setting forth the inclusive dates said packages were used, as well as the color, dimensions, shape, material composition of the package, and a description of all lettering, trademarks, writings or numbers which appear there.cn. -Friction 3cck. travs and R S C cartons which sizes run approximately 10 X 6 X 4 :(itiiuit I;/ V/ X 1? X 'i, U -Ti-lnp tlno conpjjny Jngo, pat number and -16- PQ8002 D6t>4 PRODUCED BY FORD