Document V2Dr7vKg3x6Y2KVR7x9Z8jKq

your products were being used or installed to make or take dust level counts? If so, state when this procedure started, the purpose of such procedures, and all results of such procedures. SVJ.aj See Preliminary Statement and General Objections, which are incorporated herein as if fully rewritten. Further objecting, the interrogatory is overly broad given the parameters and subject matter of this case. Further objecting, the information sought is neither relevant to the subject "latter of the pending action nor reasonably calculated to lead to the discovery of admissible evidence as it relates to Dana. Subject to and without waiving objections, Dana does not know-whether Smith & Kanzler Company or its subsidiaries or predecessor(s) before 1970 ever arranged for any labor inspectors, insurance company inspectors or anyone from Smith & Kanzler Company to go to job sites where its products were being used or installed to make or take dust level counts. ?NIgRRCK?AT0&YMQ,.4$: If Defendant performed or had performed any dust level counts, what action, based on the results, did your company take? MSWgR: * See answer to Interrogatory No. 45, which is incorporated herein as if fully rewritten. Subject to and without waiving objections, Dana does not know what action, if any. Smith & Kanzler Company took based upon the results of any dust level counts it had performed. lilia ^ROGATORY NO. 47: Has your company or its subsidiaries or predecessors) ever conducted or caused to be conducted any studies designed to assist in minimising or eliminated the inhalation of asbestos dust and fibers by those exposed to the use of your company's products? If so, give the following: (a) Name of die person or firm conducting such studies; (b) The date the studies began and the date they were completed; (c) Any publication or other written dissemination of the results of the studies; (d) The nature of any action to eliminate or minimize the inhalation of asbestos dust fibers; defendants responses to plaintiffs* master interrogatories F:\KELLY\DISC\DANA.INT PAGE -36-