Document NeyxMq59kEdYm88GzQd6JzLMg

1 (a) the date(s) defendant's automobile undercoat sealer was sold or delivered to said distributor; 2 (b) the quantity and type, including trade or 3 brand name'(s) of defendant's automobile undercoat sealer sold or delivered to said distributor. 4 RESPONSE TO INTERROGATORY NO. 113: 5 See Wagner's response to Interrogatory No. 111. 6 INTERROGATORY NO. 114: 7 Has defendant directly or indirectly sold or distrib 8 uted its automobile undercoat sealer to any of the following: 9 (a) Chrysler-Plymouth Corp.; (b) Ford Motor Company; 10 (c) General Motors; (d) American Motors; 11 (e) Nissan Motors; (f) Mitsubishi Motor Car Division; 12 (g) Volkswagon; (h) British Leyland; 13 (i) Sears & Roebuck. 14 RESPONSE TO INTERROGATORY NO. 114: 15 See Wagner's response to Interrogatory No. 111. 16 INTERROGATORY NO. 115: 17 If your answer to any part of Interrogatory No. 114 is affirmative, include as a part of your answer: 18 (a) the date(s) during which defendant's automo 19 bile undercoat sealer was sole or distributed to each entity; 20 (b) the quantity and type, including trade or 21 brand name, of defendant's automobile undercoat sealer sold or distributed to each entity; 22 (c) the identity of each employee or ex-employee 23 having knowledge of the sales and distributions to each entity. 24 RESPONSE TO INTERROGATORY NO. 115: 25 See Wagner's response to Interrogatory No. 114. 26 INTERROGATORY NO. 116: 27 Does defendant have or posses any data or information 28 regarding any shipments, sales or distributions of automobile 43