Document X2E2YbpX4rxk7vgEgmLNGGgJ

ANSWER: See Preliminary Statement and General Objections, which are incorporated herein by reference. Further objecting, the request is overly broad, unduly burdensome, and not reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving objections, defendant limits its response to Dana tests regarding possible health effects of exposure to vehicular gaskets and excludes tests conducted as attorney work product and/or subject to attorney-client privilege, tests regarding the quality or performance ofthe gaskets, and tests to assure compliance with applicable governmental regulations regarding the amount of asbestos dust at manufacturing facilities. and measuringthe air level ofdtistl" Documents demonstrating the j results of the tests were maintained at a Victor facility in Illinois. Dana will attempt to locate the $ information known to it if the specific Victor product plaintiff Allen Fuller was^ e^^^djjsp^' identified by plaintiffs and ifthe test relates to thatproducer ; :-`E'x3SrL,i1`"'aa' 10. ASBESTOS FREE PRODUCTS For each asbestos containing product identified in Interrogatory Answer No. 7 and 8, state: A. Was the product, or a substitute for that product, ever manufactured and/or sold by you without asbestos; if so, when did the manufacture and/or sale of the product commence; B. The brand name of the asbestos free product; C. The reason product was manufactured without asbestos; D. Was the asbestos-containing counterpart of the product manufactured and/or sold while the asbestos-free counterpart was being manufactured and/or sold, and, if so, provide the time periods. ANSWER: See Preliminary Statement and General Objections, which are incorporated herein by reference. Subject to and without waiving objections, see answers to Interrogatory Nos. 3,7, and 8. The primary substitute material is known as an aramid fiber, which is in the plastics family. The brand name used is known as Kevlar. The substitute for asbestos was used because the Victor Products Division discontinued use ofasbestos in its gaskets. 10