Document Mgbo1Rq9gEmkeoOZvgD8v3EL

0 5 I 0 I 12 37 O ANSWER: (a) By or un<jer the direction of The S. K. Wellman Corp. or its predecessors; 3 (b) See response to Request for Production D; (c) See response to Request for Production D; 4 (d) Sales, staff, trade shows, mailings; (e) Unknown. 5 6 7!' a I! 9 10 REQUEST FOR PRODUCTION D; Pursuant to CR 34, attach or H 'produce according to the above instructions a copy of each such ;i 12 "item of sales or marketing information, including but not limited 13 i! to books, movies, sales literature, training and/or marketing aids, l> 14 ;and an index thereto. 15 RESPONSE; See answer to Request for Production C above, including ! attachments. 16 17 18 19 ! 1.17 State whether any of your agents, employees, 20 imanufacturers, representatives or dealers during the Relevant Times 21 |were instructed to advertise, solicit, sell or otherwise encourage ^the purchase of your asbestos products or asbestos-containing 22 I 23 products for use in motor vehicle brake linings, brake pads or 24 [brake facings. 25 ; 26 / PLAINTIFF'S FIRST INTERROGS, ETC. - 17