Document N2ypDZw54Xe4Eq3DjoYw9207w

1 RESPONSE TO INTERROGATORY NO. 67: 2 Wagner is unable to respond to this Interrogatory due 3 to the lack of a definition of the phrase "threshold limit val 4 ue" and the lack of'a description of the application of the 5 threshold limit value to users of Wagner products. 6 INTERPOGATORY NO. 68; 7 Describe what action was taken by defendant prior to 1972, to determine whether the concentration of airborne asbes 8 tos fibers during normal use, application or repair of its as bestos-containing products was below the TLV. Include in your 9 answer the date the above-described actions were taken by defen dant. 10 RESPONSE TO INTERROGATORY NO. 68; 11 Wagner is unable to respond to this Interrogatory due 12 to the lack of a definition of the phrase "threshold limit 13 value" and the lack of a description of the application of the 14 threshold limit value to users of Wagner products. 15 INTERROGATORY NO. 69: 16 Describe the manner m which defendant recommended 17 that its asbestos-containing products be cut, ground, sawed, beveled, fabricated, mixed and/or prepared for use since 1930 by 18 its users. 19 RESPONSE TO INTERROGATORY NO. 69: 20 Wagner objects to this Interrogatory to the extent 21 that it seeks information outside the plaintiff's alleged expo 22 sure period. Subject to that objection, Wagner states that they 23 began informing mechanics and their employees that Wagner cam- 24 ground brake shoes were shaped to exact tolerances and should 25 not be ground before application. See Wagner's response to 26 Interrogatory No. 46. 27 28 29