Document KjbaB4nmX82Jp0K7Ke3qZ012

(d) Each of Defendant's defenses enumerated in Defendant's last filed Answer in each of these cases. RESPONSE: GM objects to this interrogatory because it asks for legal opinions or conclusions about what constitutes "relevant facts," information protected from disclosure by the work product doctrine. INTERROGATORY NO. 62: Please identify documents which will be used at time of trial, (Exhibit List, Deposition List, which are relevant to each of Defendant's enumerated defenses in Defendant's last filed Answer. RESPONSE: See response to 60. INTERROGATORY NO. 63: Please state when you first received a copy of the Fleischer/Drinker Report published in 1945/1946. RESPONSE: GM does not know when it first received the report and who at GM received it. GM objects to this request because it is vague, ambiguous, overly broad, and- is not reasonably calculated to lead to the discovery of admissible evidence. DEFENDANT GENERAL MOTORS CORPORATION'S RESPONSES AND OBJECTIONS TO PLAINTIFFS' MASTER INTERROGATORIES AND REQUESTS FOR PRODUCTION-Paee 55 10366 05491 LIT 178211