Document KR525pVLwJ9vVqg0284Jy6gEK

Cooper was a party at the time) in any case alleging exposure to asbestos and/or asbestos-containing products / materials, reflecting testimony by: (a) Any and all lay witnesses; (b) Any and all independent expert witnesses; (c) Any and/all controlled expert witnesses; and/or (d) Any and all other persons possessing knowledge and/or information concerning the facts of this case. N/A. 7. Any and all documents referring to, relating to, and/or reflecting any and/or all of the plaintiff(s)/decedent in this case. N/A. By way of further response, answering defendant does not have any documents in its possession related to plaintiff that was not received from plaintiff's counsel. 8. Any and all documents and/or exhibits that will and/or might be used by you at trial and/or in any other proceeding in this case. It is unknown at this time which documents and/or exhibits answering defendant intends to use at trial and/or any other proceeding in this case. Answering defendant reserves the right to supplement this response. ELZUFON AUSTIN REARDON TARLOV & MONDELL, P.A. MATTHEW P. DONELSON Bar No. 4243 300 Delaware Avenue, P.0. Box 1630 Wilmington, Delaware (302) 428-3181 17TM Floor 19899-1630