Document KJRo8KDKOBkNvBQqK4KLOnpko
e. Whether you have copies of any warnings in your possession at the present time end if so, identify the location and the custodian of the warning and identify the document by title, author and identification number (alternatively, attach
same hereto).
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14, Set forth the date that defendant first became aware of a causal relationship or a possible causal relationship between asbestos and any health hazards, illnesses or disease, and state the name and address of the person who on defendant's behalf first became aware of such causal' or possible causal relation ship in each instance.
I ANSWER! R-N first bocaaso aware of a potential health haiard
from the use of asbootos friction materials during the 1970'e
R-M does not know which of its employees was the first to
become aware of such information.
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15, State the full name, job title end home and business
j address of any and all persons who have knowledge of any relevant: i
! facts relating to the instant matter,
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ANSVtERi fartieiij all persons named in any of those interrogatoricai j.
'i all persons named by all parties in all answers to interrogator!oo; i;
,! all persons whose depositions have been taken in this suit or the j j
!i suit with which this case was oonsildated for eottlumont nuroooosr1 j!
ij John 11. iiavshi Isaac II. Woavon Predoriok C. Daly, r,, all c/o
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`i f-oybcstos-Mnnhattan, Inc., tratfor4 Connecticut! personnel and l I;
;i records Including x-rays, oto. of ths hospitals at which plaintiff's ;
decedent wee treated for the oondltlon for vhloh this cleimaio
!!
; made,
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(i' 16. Are any of defendant's asbestos products or parts coni, taining asbestos marketed or sold by any other person or entity |' in any manner whatsoever? If so, set forth:
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; ANSWERi Vcs. t'loaso oeo anewore to interrogatories 4, 5 and 10.
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