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B. The date on which Defendant first suspected that mesothelioma was caused by inhalation of asbestos dust and fibers.
C. How Defendant or its subsidiary or predecessor became aware of the disease and that it was caused by exposure to asbestos.
D. Who within the company or its subsidiary or predecessor first discovered or recognized the adverse consequences or effects of asbestos exposure.
E. What information was disseminated within Defendant's company or its subsidiary or predecessor regarding such adverse consequences or effects.
F. Whether any such information is still maintained by Defendants or its subsidiary or predecessor in a written form.
G. Who is the custodian of such information.
H. Whether Defendant agrees that there is no known medical cure for mesothelioma.
ANSWER: See Answer to Interrogatory No. 25.
INTERROGATORY NO. 29:
As to gastrointestinal cancer, laryngeal cancer, pharyngeal cancer or lymphatic cancer, state:
A. The_ type, of cancer and the date on which Defendant or.its subsidiary or predecessor first learned that such diseases were caused by inhalation of asbestos fibers by humans,.
B. What cancers has the Defendant or its subsidiary or predecessor become aware can be caused by exposure to asbestos fibers?
C. The date on which Defendant first suspected other cancers were caused by asbestos inhalation.
NY1-86445. 03/31/95 2:34pm
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