Document KJZYjr3mnMm8YoMgDrardndyX
CASE NO. 05-12959 (27) ASBESTOS DIVISION
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protected from disclosure by the attorney-client privilege, work product' doctrine, consulting
expert privilege, joint defense privilege, or any other applicable privilege.
Request No. 5
Current training provided by YOU to automobile mechanics not employed by YOU or YOUR dealerships about asbestos during automobile servicing, including, brake and clutch repair and replacement
RESPONSE: With the exception of the student guide, entitled "Mbtorcraft: Advanced
Brake Service and Brake Lathe Training," which is being produced herewith, a copy of the
training resources currently provided to both Ford employees and dealership mechanics
concerning automobile servicing, including but not limited to brake and clutch^ repair and
replacement, is available to Plaintiff in the public domain on Ford's Motorcraft website fbr a
nominal per course fee, and is located at www.motorcraft.com. Older resources are also
available to Plaintiff in the public domain on a third party website for a nominal per course fee,
and are located at www.helminc.com.
Ford otherwise objects to the request because it is overly broad, unduly burdensome, and
seeks information that is neither relevant to the subject matter of this action nor reasonably
calculated to lead to the discovery of admissible evidence. Ford also objects to this request to the
extent it seeks information that is protected from disclosure by the attorney-client privilege, work
product doctrine, consulting expert privilege, joint defense privilege, or any other applicable
privilege.
Request No. 6
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The "brake dust biological study" reflected in the bills from Exponent, Inc. to YOU. (See e.g. Exponent Invoice No. 92599, 95700; Chemrisk Invoice Nos, 20668, 21035, 21249, 21358 produced in Mallia, Dade County Case No.: 04-16237 CA 42).
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