Document YjqR4xRzX1xR6KQ06aLQ9koEn

1 RESPONSE: 2 No. 3 INTERROGATORY NO. 62: 4 Please state whether defendant ever subscribed to the Asbes 5 tos magazine and list the dates of subscription. 6 RESPONSE: 7 No. 8 INTERROGATORY NO. 63: 9 Please identify all booklets, manuals, journals and publica 10 tions provided to the recipients of any asbestos-containing prod 11 ucts manufactured, sold or distributed by defendant regarding the 12 proper use and application of products. Include in your answer 13 the dates said information was provided. 14 RESPONSE: 15 OBJECTION. Interrogatory No. 63 is objected to on the 16 grounds that it is overly broad, vague, ambiguous, burdensome and 17 seeks information which is not reasonably calculated to lead to 18 the discovery of admissible evidence. 19 INTERROGATORY NO. 64: 20 Please identify and describe in detail all tests and experi 21 ments conducted by defendant to determine whether or not asbestos 22 contained within its asbestos-containing products would become 23 airborne with normal use. Include in your answer the dates, 24 results and conclusions of each test and/or experiment. 25 RESPONSE: 26 OBJECTION. Interrogatory No. 64 is objected to on the 27 grounds that it is overly broad, vague, ambiguous and NZ O O". 28 unintelligible. 'AR D 1161 3- ^-