Document RjzaZge0jykVymGxzv1grjpDz
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1 (b) The time span during which each named item was
2 produced;
3 (c) The amount of each product, expressed in pounds or tons, which was produced by each plant during
4 the Relevant Times;
5 (d) The person(s) at each such plant in charge of producing each such asbestos product;
6 (e) The person(s) in charge of packaging each
7 asbestos product;
8 (f) The person(s) in charge of labeling each such product.
9
10 t..(a) In the U.S. - Cleveland, Ohio up to 1952 - Bedford, Ohio 1952-present
11 - Nashville, Tennessee 1982-present (b) 1963-present--roll lining, fabricated parts
12 1974-present--paper friction materials; (c) Irrelevant objection and probably not able to lead to
13 :he development of this data, in any event; (d) Bedford - Robert Martin, Vice President, Manufacturing
14 Nashville - Ed Stanek, Plant Manager? (e) See response to No. 1.12(d);
15 (f) See response to No. 1.12(d).
16 17
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19 1.13 During the Relevant Times, did you maintain or
20 distribute manuais, instructions, dealer handbooks or pricing
21 22 information pertaining to the sale, use, installation or removal of 23 asbestos or asbestos products?
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26 PLAINTIFF'S FIRST INTERROGS, ETC.
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