Document Ky9vx9DBmJd0Xe5YvedQnkbw

VV INTERROGATORY no. 16: From 1945 to the present, has the De fendant sold or distributed finished manufactured clutch pads or clutch facings to any of the Co-Defendants named in this suit? 4 ANSWER: To Defendant's knowledge, no. ANSWER TO INTERROGATORY NO. 17: Not applicable. * (See response to Interrogatory No. 16). INTERROGATORY.NO. 18: Do you have any records or documents in dicating that, any of your products containing asbestos fibers were sold or distributed to the following company for the years 1945 until the present? Menco Corporation, formerly known as Auto Parts Warehouse, of Springfield, Illinois. (a) Please identify each document. (b) Please identify such products sold or distributed and the dates of such sale or distribution. ANSWER: Defendant Abex objects to this interrogatory as being unduly broad and unlimited. This information is available at' Defendant's Winchester, Virginia, facility, and can be retrieved only through a manual search of the files, and it would be unduly burdensome to require Defendant to expend a great many man-hours searching its files for each document. Further Defendant states that the information is available only for the last three years due to Defendant's current records retention procedures, and De fendant states that such records would be irrelevant as Plaintiff, by his own testimony, stopped working with asbestos products in 1975. 6