Document LK76ZzMrJGRj16G4zYx3nmQZX

40. Notice/Asbestos Injury Did Defendant receive notice, prior to 1975, that any person was claiming injury as a result of using asbestos-containing products mined, manufactured, sold and/or used by you? If so, please state as to each .such claim. A. The name of the claimant; B. The date of notice of the claim; C. A description of the claim including the type of exposure experienced by the claimant (e.g., mining, milling, manufacturing, insulating, etc.); D. The type of injuries allegedly sustained; E. The caption and court, , address of the court or workers' compensation file number of the claim; F. Identify all documents relating to. the claim and the custodian thereof. RESPONSE TO MASTER INTERROGATORY 40: See Preliminary Statement and General Objections. Further objecting, this interrogatory is overly broad, unduly burdensome and not reasonably calculated to lead to the'discovery of admissible evidence. Subject to and without waiving objections, Dana states that complaints have been filed against Dana by other individuals claiming injury. Such bodily injury cases are handled for Dana by attorneys for the Center for Claims Resolution. 74