Document K6a9yKBqpq8Vv6o0Q9jE3RX12
1 lawyer sometime in December of 1995.
Page 3750
2 I would like to read the responses to the
3 same interrogatory.
4 The interrogatory, again I won't go through
5 it, but it asks the plaintiff to list for each job in
6 which you have been exposed or are being exposed to
7 asbestos-containing products of any person, business
8 or entity other than this defendant, but who is a
9 party in this case, state the following information
10 which I cited earlier.
11 Here is the response, for the first jobsite,
12 Ryan Stevedore Company, Locust Point, Baltimore,
13 Maryland.
14 Job title and job description is
15 longshoreman.
16 The duration of the job, August, 1942 to
17 February of 1945.
18 The duration of your exposure to asbestos is
19 plaintiff's investigation is continuing.
20 The location of the job is Locust Point,
21 Baltimore, Maryland.