Document Z8jG4oDx8ON02DOpLRBxy9amJ

ANSWER: See Preliminary Statement and General Objections, which are incorporated herein as if fully rewritten. Subject to and without waiving objections. Defendant is not aware of any credible scientific or.medical data that supports the conclusion that the ordinary and foreseeable use of the products manufactured by Dana could cause diseases. Defendant denies that its products required a warning. In approximately January of 1985, Victor Products Division began inserting a caution label with certain gaskets and gasket materials. The label for finished gaskets read substantially as follows: "CAUTION, CONTAINS ASBESTOS FIBERS. AVOID CREATING DUST. BREATHING ASBESTOS DUST MAY CAUSE SERIOUS BODILY HARM." The label for certain gasket materials read substantially as follows: WARNING. This material contains asbestos fibers. Avoid creating air-bome fibers or dust. Follow OSHA work practices, including the use of appropriate dust control equipment. Inhalation of air-bom asbestos fibers may cause asbestosis or other serious bodily harm. Smoking greatly increases this risk of serious bodily harm." The language used in warnings piay have changed over time. Dana does not know whether SprayCraft contained any warning or caution concerning the health consequences of the use of the product or the breathing of asbestos dust particles or fibers. INTERROGATORY NO. 17: . -V'.: Do you have custody, possession, or control of any samples of the asbestos containing products you manufactured, processed, sold, distributed, or otherwise placed in the stream of commerce? Tf so,.'f'Vy.."/.-'y-' \ . 'i .. . / >. a. Identify each such sample; b. Identify the custodian of each such sample; . c. Identify the date on which each such sample was manufactured, processed, sold, . distributed or otherwise placed in the stream of commerce; d. State whether each such sample was retrieved from the stream of commerce or was retrieved from your warehouses or storage facilities; e. If it was retrieved from the stream of commerce, identify the person or company from whom it was retrieved; and ; f. If it was retrieved from in-house sources, i.e., warehouses, storage facilities, or sales representatives of your company, identify where and from whom it was retrieved. .ANSWER: