Document NNNkedxpG5mYD5wwKLXebD44E

i.Kiia.;IROGATORY NO. 53: Did your company or its predecessors) or subsidiaries ever recall any products containing asbestos from the market or stream of commerce? If so, state: (a) All details of such recall; (b) The name of the product recalled, including the reason for die recall and the mmw and current addresses of those individuals who determined that it should take place; (c) The dates of recall; (d) The purpose for the recall. ANSWER: See Preliminary Statement and General Objections, which are incorporated herein as if fully rewritten. Further objecting, tire 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 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 Smith & Kanzler Company has or ever had or whether its predecessors) or subsidiaries ever recalled any products containing asbestos from the market or stream of commerce. INTERROGATORY NO. 54: Before 1970, did you ever manufacture or sell products which did not contain asbestos and which could be substituted for your asbestos-containing products? If so, state the date such asbestos-free products were first placed on the market. 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 Smith & Kanzler Company, before 1970, ever manufactured or sold products DEFENDANTS RESPONSES TO PLAINTIFFS* MASTER INTERROGATORIES F:\KELLY\DISCVDANA.INT PAGE-40-