Document ZJEVonDNyXrN1B4YbaDLjB0ZJ

ever litigated the issue of insurance coverage in a case involving exposure to asbestos. U ROGATORY NO. 241 Has Defendant ever conducted any tests or studies concerning the health hazards to an individual exposed to both asbestos dust/fibers and tobacco smoke? If so, provide the names and dates of each test or study. AN?WEB:- See Preliminary Statement and General Objections, which are incorporated herein as if fully rewritten. Further objecting, the interrogatory is overly broad given the parameters and subject matter of this case. Further objecting, the information sought is neither relevant to the subject matter of the pending action nor reasonably calculated to lead to the discovery of admissible evidence as it relates to Dana. Subject to and without waiving objections, Dana does not know whether Smith & Kanzler Company ever conducted any tests or studies concerning the health hazards to an individual exposed to both asbestos dust/fibers and tobacco smoke. INTERROGATORY NO. 25: To date, has Defendant furnished any information to consumers, other users of asbestos-containing products, or to the general public, about the health hazards to an individual exposed to both asbestos dust/fibers and tobacco smoke? If so, state how and when this information was conveyed. ANSWER: See Preliminary Statement and General Objections, which are incorporated herein as if fully rewritten. Further objecting, the interrogatory is overly broad given the parameters and subject matter of this case. Further objecting, the information sought is neither relevant to the subject matter of the pending action nor reasonably calculated to lead to the discovery of admissible evidence as it relates to Dana. Subject to and without waiving objections, Dana does not know whether Smith & Kanzler Company ever furnished any information to consumers, other users of asbestoscontaining products, or to the general public, about the health hazards to an individual exposed to both asbestos dust fibers and tobacco smoke. INTERROGATORY NO. 26: DEFENDANT'S RESPONSES AND OBJECTIONS TO PLAINTIFFS * INTERROGATORIES AND REQUESTS FOR PRODUCTION f:\asb3\roga.all Page 17