Document N3EJzGyKQ63OxMm5nGdON4ag
C 051010242
1
Otherwise stated, identify what brake pads, 2 brake linings or brake facings went into which
of your motor vehicles during the period 1950 3 through 1978;
4 Ik) State when and how you were first made aware of
health hazards associated with the use of 5 asbestos;
6 (1) When did you first become aware that warnings
were plaed on asbestos products with respect to 7 the health hazards associated with the use of
asbestos; 8
(ra) When did you first learn in any manner or from 9 any source that asbestos or asbestos products
are hazardous or dangerous to the health of 10 persons;
11 (n) From whom did you learn the information referred
to in the answer to the preceding interrogatory; 12
(o) State what documents reflect the information 13 given in answer to the two preceding
interrogatories, their date, and the present 14 custodian of said records;
15 (p) Did you at any time maintain or distribute manuals, instructions or information relating to
16 the sale, use or removal of asbestos or asbestos products, including, but not limited to, the use
17 or removal of asbestos-containing brake linings, brake pads or brake facings;
18
19 (q) If the answer to the preceding interrogatory is in the affirmative, state the present location
20
of records or other such materials and thename and address of the custodian of said manuals,
21 *. instructions, directories or information.
22
23
24
25
26 PLAINTIFF'S FIRST INTERROGS. ETC.
22
I
I