Document ZnEBrjmRXZkOkdYYmkKQBGDvV

Identify any and all facilities at which Defendant, any predecessor or any related company, at any time, manufactured or processed asbestos-containing products, or processed raw asbestos. For each such facility identified: (a) State the date(s) which said facility was owned and/or operated by Defendant, any predecessor or any related company; (b) State the date(s) during which asbestos-containing products and/or raw asbestos were manufactured or processed, at said facility; and, (c) Identify each person serving as the manager or supervisor of said facility during any time which the facility has been owned and/or operated by Defendant, any predecessor or any related company, and state the date(s) of the tenure as manager or supervisor for each. RESPONSE TO INTERROGATORY NO. 38; See General Objections. Abex further objects to this request on the grounds that it is compound, vague, ambiguous, overly broad as to time and scope, unduly burdensome, irrelevant to any issue in this action and not reasonably calculated to lead to the discovery of admissible evidence. Without waiver of these objections, Abex responds that its asbestos-containing automotive friction products were manufactured at various times in Detroit, Michigan (approximately 1927 to early to mid 1950's); in Salisbury, North Carolina (1974 to 1987); and in Winchester, Virginia (1947 to 1987). INTERROGATORY NO. 39: Withdrawn by plaintiff or stricken by the Court. INTERROGATORY NO. 40; Identify any and all persons known by you to have any knowledge concerning the manufacture, sale, distribution, possession, application, installation or use of the products listed in response to Interrogatory No. 19. -29-