Document VJ0Vj3KOqKdzL5bbRm4dDEzyo

K8895DIA058 (a) which refer to, relate to or reflect the subject of asbestos; (b) which refer to, relate to or reflect a relationship between asbestos exposure and any disease; or (c) which refer to, relate to or reflect the placement or providing of warnings with respect to hazardous products. ANSWER TO INTERROGATORY 100. Borg-Warner answers that it knows of no documents responsive to this interrogatory. INTERROGATORY NO. 101: Identify any and all agreements, oral or written, between or among Defendant, any of the other defendants in this lawsuit, any organization, association or other entity including, but not limited to. those identified in your answer to Interrogatory No. 94 and/or any medical or scientific foundations, relating to the standardization of: (a) Specifications for asbestos cloth products; (b) Specifications for paper or burlap bags, or other packaging to be used for the transport and/or storage of asbestos cement; (c) Warning or caution labels to be applied to asbestos products and/or their packaging, cartons, containers, or boxes; (d) Methods of dissemination of public relations information to defendant's purchasers, advertisers, distributors, factory workers, contractors, insulators, users, consumers of asbestos products and/or the general public; (e) Safety equipment and/or protective clothing to be utilized while handling defendant's asbestos products; (f) Medical programs to be offered or sponsored by defendant. ANSWER TO INTERROGATORY 101. None known. INTERROGATORY NO. 102: Did Defendant, any predecessor or related company, direct to be performed, sponsor in whole or in part, finance in whole or in part, receive the results of, or become aware of, any studies or tests performed by the Saranac Lake Laboratory of the Trudeau Foundation relating to asbestos exposure and its effects upon human health? ANSWER TO INTERROGATORY 102. Not to answering defendant's knowledge;