Document ZBmZKd8e7DqV1gj5ga5kGjYnL

1 RESPONSE TO INTERROGATORY NO. 37: 2 Wagner objects to this Interrogatory on the grounds 3 that it is overly broad and seeks information outside the plain 4 tiff's alleged period of exposure to asbestos-containing prod 5 ucts. Subject to this objection, Wagner states that during the 6 plaintiff's alleged exposure to asbestos-containing products, 7 Wagner retained physicians for the purpose of examining Wagner's 8 employees. These physicians are: 9 Douglas A. Ries, M.D. (deceased) 10 Curtis A. Meyer, M.D. (deceased) 11 John J. Keenoy, M.D. (deceased) 12 Lance D. Gerowin, M.D. 13 INTERROGATORY NO. 38: 14 Please list the names and addresses of all persons employed by defendant from 1930 until the present time who func 15 tioned as industrial hygienists. (As contemplated by these Interrogatories, an industrial hygienist is one that performs 16 engineering or health studies to identify and evaluate potential occupational health hazards and suggests methods of dealing with 17 same.) Include in your answer to the foregoing: 18 (a) The facility or office to which the individuals were assigned; 19 (b) A detailed description of their duties and re 20 sponsibilities . 21 RESPONSE TO INTERROGATORY NO. 38: 22 Wagner objects to this Interrogatory on the grounds 23 stated in its response to Interrogatory No. 37. Subject to this 24 objection, Wagner states that from 1975 through the end of 25 Plaintiff's alleged exposure period, it has used the consulting 26 industrial hygiene services of John A. Jurgiel, Certified Indus 27 trial hygienist, 2092 Concourse Drive, St. Louis, Missouri for 28 17