Document RaZ2zgyaLEanynJK1wa763Era

INTERROGATORY HO. 27: Did the Defendant ever warn any labor union representing insulation workers, or any union members individually, of any potential health hazard from use of insulation products containing asbestos? If so, state: (a) The' Union- ' (b) How said Union was informed. (c) The date and place of said information or warning. . (d) The content and nature of said warning. (e) The individual Or individuals warned. ANSWER: Defendant objects tothis Interrogatory as irrelevant, in that insulation products are not involved in this lawsuit. INTERROGATORY NO. 28: Kas any investigation or other reports been prepared, compiled, submitted or made by or on your behalf in this action? If so, describe each document dealing with each such investigation cr report. ANSWER: No.