Document MMG37OGnrrrdO9dVz1BbngXbV

(c) A brief siunmaiy of the disposition of each such claim. (d) The name, address and title of the person having custody of the records pertaining to each such claim. ANSWER: See Preliminary Statement and General Objections, which are incorporated herein as if fully rewritten. Further objecting, the interrogatory is overly broad given the parameters and subject matter of this case. Further objecting, the information sought is neither relevant to the subject matter of the pending action nor reasonably calculated to lead to the discovery of admissible evidence as it relates to Dana. Subject to and without waiving objections, Dana does not know whether prior to 1968 any person filed a claim against a Worker's Compensation carrier covering Smith & Kanzler Company or any of its subsidiaries or predecessors alleging that he/she contracted a disease from inhaling asbestos fibers. ?NTHRRCy?AIQRY-NO, 36: Did Defendant or any of its subsidiaries or predecessors maintain written minutes of corporate meetings, either board of directors, departmental, or otherwise, which reflect discussions pertaining to any subject matter related to asbestos, asbestos health hazards or asbestos products? If so, for each such set of minutes, state: (a) The dates of each such meeting. (b) The general subject matter discussed at each meeting. (c) Who was in attendance at each meeting. (d) Where and by whom the written minutes are presently maintained, (e) By whom the minutes were taken and put into final format. (0 Whether the minutes were abstracted and reports disseminated to other individuals, and if so, the names and job titles of those individuals. ANSWER: See Preliminary Statement and General Objections, which are incorporated herein as if fully rewritten. Further objecting, the interrogatory is overly broad given the parameters and subject matter of this case. Further objecting, the information sought is neither relevant to the subject matter of the pending action nor reasonably calculated to lead to the discovery of DEFENDANTS RESPONSES TO PLAINTIFFS* MASTER INTERROGATORIES F:\KELLY\DISC\DANA-1NT PAGE -30-