Document aJOzG0RaYVn2gZZ4xNYg09Goa

051010256 1 2 ANSWER: 3 see 1.35 above. 4 S 6 7 8 9 REQUEST FOR PRODUCTION I: Pursuant to CR 34, attach or 10 produce according to the above instructions a copy of all documents 11 identified in subparagraph: (d) above. 12 RESPONSE: objection--ovecly broad and cannot identify documents, if 13 any, which should be produced in response to this Request for Production. J. E. Mencini is aware of state and federal safety and 14 health standards which we assume represent the state of domestic knowledge. The standards are available to the general public and 15 production of same is objected to. 16 17 1.37 Do you have or have you ever had person(s) IS responsible for monitoring the state of current foreign knowledge 19 of the safety and health aspects of your industry? 20 ANSWER: ,, 21 22 23 24 25 26 PLAINTIFF'S FIRST INTERROGS, ETC. - 34