Document by0pEq6zX1aV9EK6NZ0QkZvjg

formulations used in the manufacture of brake linings are valuable, proprietary information that are disclosed only within GM on a need-toknow basis. These formulations are the result of decades of investment of time and money and their disclosure would put GM at a serious competitive disadvantage because domestic and foreign competitors could duplicate GM products without having to undertake the lengthy and expensive laboratory and vehicle testing program that GM undertook. Competitors could also use this information to improve their products and processing methods without having to compensate GM for its efforts. For these reasons, GM objects to the disclosure of the specific details of its formulations. (f) GM stopped manufacturing these linings in 1985 because of production priorities, but continues to sell them. (g) Not applicable. (h) Automotive disc brake linings segments are a dense grayish or tan material. Typical dimensions are height 57-63 millimeters, width of 125-142 millimeters, and thickness of 11-13 millimeters. (i) Disc brake linings are one component of a vehicle braking system. ($) GM has distributed asbestos-containing linings from 1966 to present. CLUTCH PLATES AND BANDS FOR AUTOMATIC TRANSMISSIONS (a) Automatic transmissions were introduced in GM model year 1940. Clutch plates and bands containing asbestos were used as early as 1946. GM (Delco Moraine) manufactured some of the band material (approximately 1965-1979) and the rest was purchased. See response to subpart (e). (b) See responses to subparts (a), (c) and (e). (c) Trade Names: United Motors (1940-61), United Delco (1961-1964), GM Parts (1969 - Present); Delco Moraine, Hydra-Matic, Allison (1940s-1969), Detroit Diesel Allison (1970-1987), Allison Transmission (1988-Present); Goodwrench (1985 - Present). (d) See response to subpart (h). (e) The band linings GM manufactured contained about 40-50 percent chrysotile asbestos. The rang? of weight percentage for certain materials used for automobiles and light trucks was approximately 10 to DEFENDANT GENERAL MOTORS CORPORATION'S RESPONSES AND OBJECTIONS TO PLAINTIFFS' MASTER INTERROGATORIES AND REQUESTS FOR PRODUCTION-Parc 6 30366 05491 LIT 178211