Document QXYJGZj2zm9aoNRoKozLQDYL4

05 I 0 I 0236 ii i I 1 i 1.15 During the period of time from 1940 to the present, 2 were any sales materials prepared by defendant or its agents for 3 the purposes of marketing or advertising defendant's asbestos or 4 asbestos-containing products anywhere in the United States? S 6 ANSWER: 7 Yes. 8 9 10 1.16 If your answer to the preceding interrogatory is in 11 the affirmative, state: 12 (a) The name and address of each person or entity 13 who prepared the same; 14 (b) The name, address and job title of each person who presently has possession of same; 13 (c) The date same was prepared; 16 (d) The media used to disseminate the sales 17 material. Specify the names of the magazines, trade publications, catalogs, trade shows and/or 18 sales staff involved in the dissemination; 19 (e) State whether any of the materials referred to in your answer to this interrogatory were 20 mailed, circulated, distributed or otherwise made available in the State of Washington during 21 * the Relevant Times. 22 23 24 23 26 PLAINTIFF'S FIRST INTERROGS, ETC. 16