Document ZByVdynR54Rowd5m7kzRE6exp
during 1965-2005:
(a) Identify by type, manufacture name, brand name,
trade name, make, model, number and/or like
designation each and every asbestos-containing
product present at said site during the time of
exposure,
which
was
manufactured,
sold,
distributed, installed, applied and/or specified
by Defendant and/or any predecessor /related
entity; OR,
(b) State specifically that Defendant denies that asbestos-containing products attributable to it or any predecessor / related entity were present at said site during the relevant time.; OR,
(c) State that Defendant lacks sufficient information to identify any asbestos-containing products or to specifically deny that any such products were present.
ANSWER:
Answering defendant acknowledges that certain Gleason machines were at the Ford site in question. Specifically, Gleason Model No. 116s and 950s and PHOENIX machines were at the plant in question. By way of further response, answering defendant states that some of the machines may have contained some asbestos containing parts at the time of original manufacture, such as brake assemblies. However, Gleason PHOENIX machines did not contain any asbestos parts.
INTERROGATORY NO. 3:
With respect to each site as described in Interrogatory No. 2:
(a) State whether or not any agent, employee or
representative of Defendant and/or any
predecessor/related
entity
and/or
of
any
affiliated distributor thereof was ever present at
said site during or prior to the time that
plaintiff/decedent was present for any purpose,
including, but not limited to, repair, servicing,
sales, installation, training, and/or technical
support. If your answer is "yes" identify each and
every such occasion as follows:
(i) (ii)
(iii)
state the date and location of the visit; identify the person(s) (agents, employees, representatives) involved; and, state the purpose of the visit (e.g. sales calll, technical support, repair etc.); and,