Document MMB84o2MoQKVjY4Lr3ddOgaQk

0510102 1 ANSWER: (a) Since 1977, S. K. Wellman, pursuant to OSHA regulations has 2 requested its errployees working in areas with possible asbestos exposure to undergo anterior and posterior chest x-rays; 3 (b) See answer to 4.05(a); (c) X-rays were taken by radiologists in Cleveland, Chio who were 4 contracted to perform these tests for S. K. Wellman; (d) See answer to 4.05(a) above; 5 (e) None; (f) Plant nurse and cutside doctors; 6 (g) No such records exist as to info requested in this interrogatory'. 4.06 For each and every such program identified in your 7 answer to the preceding interrogatory, describe in detail the 8 method by which the results of such testing was made available to 9 the employees. 10 ANSWER. jn-gievant objection. 11 12 13 14 IS 16 17 REQUEST FOR PRODUCTION S: Pursuant to CR 34, attach or 18 produce according to the above instructions a copy of the records 19 of the implementation of the afore-identified chest x-ray 20 programs. 21 RESPONSE: Irrelevant objection. 22 23 24 25 26 PLAINTIFF'S FIRST INTERROGS, ETC. 73