Document Kk3Y95DrMZqxROL5QJ1yonrN

(.t: ?-iTlfi/yTM- * BORG Karl Asch, Esq. February 9, 1981 Page Two 5. None; (a) inapplicable; (b) inapplicable; (c) inapplicable. 6. Inapplicable. 10. In addition to that already provided, it is highly unlikely that the pads sold by this defendant were ever sold to any of plaintiff's employers since all plaintiff's employers were G.M. dealers and our product 9PlY ugn1~ Pr>rrt- In addition, they were only for use on pplice and taxi fleets'" and to our knowledge, none of plaintiff's employers serviced this type of vehicle. 14. Approximately 75,275 sets of pads were shipped to Kelsey-Hayes & Bendix during the years 1971-1975. They were assembled and sold to Ford. Our material was tested and approved by Ford. The asbestos was purchased through Ronald R. Fitzgerald Co., Chicago, Illinois and produced by Asbestos Corporation Ltd. The fiber was identified as KB-563-5R. 15(a) The pads were approved_hy Ford (b) the pads were approved by Ford; (c) no; (d) no; (e) no; (f) no; (g) no; (h) no; (i);no; (j) no. 16. Inapplicable. 20. No - pads shipped in bulk to Kelsey & Bendix. 40. No - not a library as such. 41. No. 42. These possibilities come to light with this suit. 43. No. 44. Became aware of possibility from this suit. F. 6002 0565 PRODUCED BY FORD