Document dYBbZJQnkxaGVB59no8ZmQ2GQ

19. Does Defendant have or control any documents, including but not limited to, written memoranda, specifications, recommendations, blueprints or other written materials of any kind or character relating to the testing of the products listed in Interrogatory No. 5 hereinabove? a) Identify each such written material or document; b) Identify each person who presently has possession of each such document; c) State where each such document is located. ANSWER: Westinghouse incorporates by reference its Preliminary Statement and General Objections. Westinghouse further objects to responding to this Interrogatory concerning any products not alleged to have contributed to the alleged injuries of plaintiffs), on the grounds that the Interrogatory, as applied to Westinghouse, is overly broad and unduly burdensome and seeks information which is irrelevant and immaterial to these proceedings and is not reasonably calculated to lead to the discovery of admissible evidence. If a particular plaintiff will specifically and credibly identify the Westinghouse product(s) alleged to have given off respirable asbestos fibers in his or her presence, Westinghouse will endeavor to answer this Interrogatory for such produces), if any, to the extent Westinghouse reasonably can do so. 20. Were any design changes or modification made as a result of such tests listed in answer to Interrogatory No. 18 hereinabove? If so, please state: a) The trade name of the product changed or modified; b) the nature of the change made and the date of such changes or modifications; c) The name, address, and job classification of each person in charge of making a change. ANSWER: Westinghouse incorporates by reference its Preliminary Statement and General Objections. Westinghouse further objects to responding to this Interrogatory concerning any products not alleged to have contributed to the alleged injuries of plaintiffs), on the grounds that the Interrogatory, as applied to Westinghouse, is overly broad and unduly burdensome and seeks information which is irrelevant and immaterial to these proceedings and is not reasonably calculated to lead to the discovery of admissible evidence. If a particular plaintiff 21