Document QkxrnX8jGk9eXZ705bQdaOwmL
C 651010236 C
1 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?
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ANSWER: 7
Yes>
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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;
15 (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.
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26 PLAINTIFF'S FIRST INTERROGS, ETC.
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