Document Rj1oz7JKBrdX92RR8nbmzRMEX

RESPONSE TO INTERROGATORY NO. 102: None. INTERROGATORY NO. 103: Please state when the first claim for Workers' Compen sation was filed by any of defendant's automobile repair employ ees or factory workers in which it was alleged that said claim ant had developed: (a) Asbestosis; (b) Lung cancer; (c) Mesothelioma For each such claimant, list the date the claim was filed, the claimant's name and the state m which the claim was filed. RESPONSE TO INTERROGATORY NO. 103: See Wagner's response to Interrogatory No. 47. INTERROGATORY NO. 104: i --I .1 - y Please state whether the defendant entered into any agreements with any British or German concerns which manufac tured asbestos-containing products from 1930 to 1972. RESPONSE TO INTERROGATORY NO. 104: No. INTERROGATORY NO. 105: If the answer to the above interrogatory is affirma tive, please list: (a) The name, address and phone number of each such British or German concern; (b) The year the agreement was entered into and the date said agreement terminated; (c) The products exchanged or involved in said agreement, including: (i) The percent composition of asbestos; (n) The intended use of the products; (iii) Whether the products were marketed in the United States 39