Document YrEq2gKgM7VnVOQXZQZk9E74n

GM objects to the rest of this interrogatory because it is vague, ambiguous, overly broad, burdensome, and is not reasonably calculated to lead to the discovery of admissible evidence. INTERROGATORY NO. 54: Before 1970, did you ever manufacture or sell products which did not contain asbestos and which could be substituted for your asbestos-containing products? If so, state the date such asbestos-free products were first placed on the market. RESPONSE: Asbestos-containing friction products have characteristics different from non-asbestos friction products and, therefore, one is not a substitute for the other. See response to No. 52. INTERROGATORY NO. 55: Have any products you identified in your response to Interrogatory Nos. 52 and 54 not performed as intended? Please list all such products that have not performed as intended. RESPONSE: See responses to 52 and 54. INTERROGATORY NO. 56Did your company or its predecessor(s) or subsidiaries ever make, order, or arrange for any industrial hygiene surveys regarding asbestos or asbestos-containing dust? If so, give the date of such surveys and state who, or what entity, was responsible for completion of such surveys. DEFENDANT GENERAL MOTORS CORPORATION'S RESPONSES AND OBJECTIONS TO PLAINTIFFS* MASTER INTERROGATORIES AND REQUESTS FOR PRODUCTION-Page 51 30566 05491 UT 178211