Document YjJk0DE78LenXKBJgDoKmKNyO

1 (in) The years during which asbestos fiber was included m the composition of the brake linings 2 under each trade or brand name; 3 RESPONSE TO INTERROGATORY NO. 119. 4 (a)-(b) See Wagner's response to Interrogatory No. 5 10(a)-(b). 6 (c) See Wagner's response to Interrogatory No. 10(c). 7 (d) -(e) See Wagner's response to Interrogatory No. 8 10(d)-(e). 9 (f) Wagner brake products have been assembled at 10 various bonding shops throughout the country. 11 INTERROGATORY NO. 120: 12 Identify all distributors of defendant's automobile brake linings or brake assemblies in and for the State of Cali 13 fornia, and for each distributor, state: * 14 (a) the date(s) defendant's automobile brake linings or brake assemblies were sold or delivered to 15 said distributor; 16 (b) the quantity and type, including trade or brand name(s), of defendant's automobile brake linings 17 and brake assemblies sold or delivered to said dis tributor. 18 RESPONSE TO INTERROGATORY NO. 120: 19 Wagner objects to this interrogatory on the grounds 20 that it is overly broad, unduly burdensome and not calculated to 21 lead to the discovery of admissible evidence and seeps propri 22 etary business information. 23 INTERROGATORY NO. 121: 24 Has defendant directly or indirectly sold or distrib 25 uted its automobile brake linings or brake assemblies to any of the following: 26 (a) Chrysler-Plymouth Corp.; 27 (b) Ford Motor Company; (c) General Motors; 28 (d) American Motors; 46