Document RjzaZge0jykVymGxzv1grjpDz

\) 0 I U I V - w 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 18 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? 24 25 26 PLAINTIFF'S FIRST INTERROGS, ETC. 14