Document b52397GpXV0q2gmXLRZex9Z9D

INTERROGATORY NO. 3B: State whether you or any of your predecessors and/or subsidiaries maintain, from 1940 through the present or for any portion thereof copies of invoices, shipping documents, bills of lading, purchase orders, or other documents of a similar nature relating to the mining, manufacture, marketing, sale or distribution of asbestos products. If so, state: (a) The location of such documents. (b) The name and address of the custodian of the documents. (c) The format in which the documents are kept, L&, hard copy, microfilm, microfiche, etc. (d) In what form the documents can be accessed, Lfi,, by state, by product, etc., and if by product, whether kept according to asbestos or non-asbestos. ANSWER: See Preliminary Statement and General Objections, which are incorporated herein as if fully rewritten. Subject to and without waiving objections, Dana's Victor Products Division documents are available for inspection and copying at the office of Cooper & Walinski in Toledo, Ohio at a mutually convenient time, and have been inspected by Plaintiffs' counsel. INTERROGATORY NO. 39: May you call company representatives as witnesses at the trial of any of these cases? If so, list: (a) The name, address, and job title of each company representative who may be called. (b) A summary of the testimony expected to be given by each such witness. (c) Cist any and all previous times that the named witnesses have either given deposition or trial testimony in an asbestos-related case, including the jurisdiction, style of the case, case number, date of testimony, and the name of the attorney taking the deposition for the Plaintiffs in that case. 29 DEFENDANT'S ANSWERS TO PLAINTIFFS' MASTER INTERROGATORIES AND REQUESTS FOR PRODUCTION