Document MJONBNDQwrM68YERyQbyVV4ek

in-interest to Smith & Kanzler Company) and obtained by Dana, the communication indicates that the information should be limited to the purposes of that specific litigation " only. d. . In those gaskets that contained asbestos, the percentage by weight of asbestos varied widely, depending on the specifications of the gasket. Without the identification of a specific gasket product, Defendant is not able to reasonably respond to the entirety of this interrogatory. If plaintiffs identify an asbestos-containing product to which they claim exposure, Defendant will provide available information requested about the product. : Victor Products Division has manufactured gaskets without asbestos since its inception in 1967. See (c) above with respect to Smith & Kanzler Company's product SprayCraft. e. Ifplaintiffs identify an asbestos-containing Victor gasket to which they claim exposure. Defendant will provide available information requested about the product. f. Gaskets are intended to be used in vehicular applications. Smith & Kanzler's SprayCraft product was intended to be used as a building insulation. g. ,: Victor Products Division purchased raw asbestos fiber for the manufacture of gaskets from a number of suppliers, among them: Johns-Manville, Canadian Johns-Manville ..Asbestos, Ltd., and Lake Asbestos of Quebec. Dana does not know the names and addresses of Smith & Kanzler Company's suppliers. INTERROGATORY NO. 10: Ifyou manufactured or distributed any product containing any amount ofasbestos, please identify, by location and product produced, each plant in which such product was manufactured and/or assembled, the dates of operation for each such plant, and any employee of any such plant who has filed a claim under any occupational disease or worker's compensation statute for any asbestos-related disease, including, but not limited to, mesothelioma, asbestosis, and lung cancer. For each individual identified: a. State the date the claim was filed; b. Identify the governmental agency and location where the claim was filed; c. Identify where the records of the claim may be located, examined and copied; d. Identify the employee's occupation; and e. Identify the disease alleged by the claimant. . 14