Document OJkyLYyx1qOZrgRBLY5XmnK8w

1 grounds that it is overly broad, vague, ambiguous and unintelli 2 gible and this responding defendant does not know to which "use" 3 the plaintiff refers. 4 INTERROGATORY NO. 85: 5 Please state whether this defendant has distributed any 6 catalogs, brochures, pamphlets or other advertising materials 7 regarding its asbestos-containing products b.tween 1930 and 1972. 8 RESPONSE: 9 Yes. 10 INTERROGATORY NO. 86: 11 Does defendant advertise its asbestos-containing products by 12 any media whatsoever. 13 RESPONSE: 14 Yes. 15 INTERROGATORY NO. 87: 16 Please state whether defendant sold any asbestos-containing 17 products to any United States governmental agency between 1930 to 18 1972. If so: 19 (a) List the name and address of each such agency; 20 (b) The dates of each sale; 21 (c) The final government destination of each product 22 sold; 23 (d) The type and serial or model number of products 24 sold or distributed to said agencies. 25 RESPONSE: 26 ii I 27 N20 o*. 28 AMO Ilf. 1 OBJECTION. Interrogatory No. 87 is objected to on the grounds set forth in response to Interrogatory No. 83, supra, and the same is incorporated herein as though fully set forth. Without -43-