Document Xz55zL6zKQ7EBvYdGmn7B5znK

\ 1 RESPONSE: 2 Not applicable. 3 INTERROGATORY NO. 104: 4 Please state whether the defendant entered into any agree 5 ments with any British or German concerns which manufactured 6 asbestos-containing products from 1930 to 1972. 7 RESPONSE: 8 OBJECTION. Interrogatory No. 104 is objected to on the 9 groundsvthat it is overly broad, vague, ambiguous and unintelli 10 gible with respect to the use of the undefined term "agreements." 11 As presently framed, this defendant cannot respond to hhe inter 12 rogatory. 13 INTERROGATORY NO. 105: 14 If the answer to the above interrogatory is affirmative, 15 please list: 16 (a) The name, address and phone number of each such 17 British or German concern; 18 (b) The year the agreement was entered into and the 19 date said agreement terminated; 20 (c) The products exchanged or involved in said agree 21 ment, including: 22 (i) The percent composition of asbestos; 23 (ii) The intended use of the product; 24 (iii) Whether the products were marketed in the 25 United States. 26 RESPONSE: 27 Not applicable, given the objection to Interrogatory No. NfO 28 104. A4Q 60 -48-