Document VKaNvJQ4QNM0B1gNOGnO9480N

1 INTERROGATORY NO. 110: 2 Please list the names and addresses of all insurance carriers which provided Worker's Compensation coverage for occu 3 pational diseases for defendant's employees, including automo bile repair employees, between the years 1930 and 1972. 4 RESPONSE TO INTERROGATORY NO. 110; 5 Wagner objects to this Interrogatory on the grounds 6 that it is overly broad, unduly burdensome and not calculated to 7 lead to the discovery of admissible evidence. 8 INTERROGATORY NO. Ill: 9 At any time during the period 1948 to 1978, has defen 10 dant manufactured automobile undercoat sealer' If so, please state: 11 (a) the trade or brand name(s) under which the undercoat sealer was marketed, 12 (b) the years during which the undercoat sealer, 13 under each trade or brand name, was manufactured; 14 (c) the dates each product listed m (a) was withdrawn from the market; 15 (d) the quantitative percentative of each chemi 16 cal component of the undercoat sealer under each trade or brand name; 17 (e) if asbestos was included in the composition 18 of the undercoat sealer which you manufactured under any trade or brand name, please state: 19 (i) The type of asbestos fiber 20 (i.e., amosite, chrysotile, crocidolite) used in the undercoat sealer under each 21 trade or brand name; 22 (li) The quantitative percentage of asbestos fiber used in the undercoat sealer 23 under each trade or brand name; 24 (iii) The years during which asbestos fiber was included in the composition of the 25 undercoat sealer under each trade or brand name; 26 (f) the location of the facility (facilities) 27 where the undercoat sealer was manufactured. 28 41