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JAN.2S96* 1 5653 Gr< - 3 Z. IN RE: ASBESTOS LITIGATION IN THE DISTRICT COURTS OF CAMERON COUNTY, TEXAS DEFENDANT GENERAL MOTORS CORPORATION'S RESPONSES TO PLAINTIFFS' MASTER INTERROGATORIES AND REpOESTS FOR PRODUCTION To: Russell W. Budd, Baron & Budd, The Centrum, 3102 Oak Lawn Avenue, suite 1100, Dallas, Texas 75219. General Motors Corporation [GM] makes these Responses to Plaintiffs' First Set of Interrogatories and Request for Production of Documents to Defendant. RESPONSES -TO INTERROGATORIES INTERROGATORY NO. 1: State the name, address, job title, length of time employed by Defendant, and a year-by-year list of all other positions, titles, or jobs held when working for Defendant of each person who has supplied any information used in answering these interrogatories. RESPONSE: These interrogatories were verified in accordance with the Rules of Civil Procedure by the person signing the verification form. They were prepared by General Motors with the help of its lawyers, including Philip R. Cosgrove, Grace, Skocypec, Cosgrove & Schirm, 5700 Wilshire Boulevard, Suite 300N, Los Angeles, California 90036, (213) 487-6660. INTERROGATORY NO. 2: state whether or not you are a corporation. If so, state your correct corporate name, the state of your incorporation, the 1 SCF-EC-4425