Document KDVDxNOq1n37vNVq75nrdyqo

1 set forth in Response to Interrogatory No. 40/ supra, and incor 2 porates the same by reference herein as though fully set forth. 3 INTERROGATORY NO. 46: 4 Please state whether any of the distributors of defendant's 5 asbestos-containing products were provided with any special in 6 structions, oral or written, in regard to utilizing said products 7 in a manner so as to avoid exposing workers' to dust. If so, 8 please state: 9 ,, (a) When these instructions were given; 10 (b) By whom these instructions were given; 11 (c) Whether the instructions oral or written; 12 (d) The precise content of the instructions; 13 (e) If the instructions were written, please attach a 14 copy of the instructions. 15 RESPONSE: 16 OBJECTION. Interrrogatory No. 46 is objected to on the 17 grounds that it is overly broad, vague and ambiguous. 18 INTERROGATORY NO. 47: 19 Please state whether any employee of the defendant has ever 20 made a claim for asbestosis under the Occupational Disease or 21 Workers' Compensation Statute of any state. If so, include in 22 your answer: 23 (a) The date that the defendant first received notice 24 of any claim for asbestosis under the Occupational Disease or 25 Workers' Compensation Statute of any state and state [sic]; and 26 (b) The total number of claims filed for the years 27 1930 to 1972. NZO o*. 28 ARO Ill -1161 60 -28-