Document Ra0VmLDyZnV6yg0GBKd133bEB

INTERROGATORY NO. S3: Did defendant and/or any predecessor/related entity direct to be performed, sponsor in whole or in part, finance in whole or in part, receive the results of, or become aware of, any studies or tests performed by the Saranac Lake Laboratory of the Trudeau Foundation relating to asbestos exposure and its effects upon human health? If so: (a) Identify any and all documents received by Defendant, its predecessor(s) , or a related company referring to, relating to or reflecting any findings or results of those studies or tests, and state the date upon which each was first received; (b) Identify any and all communications (oral or written), between Defendant, its predecessor(s) or a related company and Saranac personnel, including but not limited to Gerrit W.H. Schepers, M.D.; (c) Identify any and all documents referring to, relating to or reflecting the Saranac studies received or submitted by Defendant, its predecessor(s) or a related company either directly, through ' related or predecessor companies, through other companies, or through any trade associations, organizations or other entities; and (d) Identify any and all documents referring to, relating to or reflecting recommendations or findings of .such studies relating to: (i) Adequacy or inadequacy of threshold limit values; (ii) Substitution of materials other than asbestos to be used in the insulation process. ANSWER: - No. INTERROGATORY NO. 54: Identify each and every occasion on which any and/or GLEASON-000038