Document daX3X3k6go7VV17QQBzL1rap9
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in this suit and rebranded or renamed such finished clutch pads
and clutch facings as the Defendant's?
ANSWER: No. ANSWER TO INTERROGATORY NO. 9: Not applicable.
(See response
to Interrogatory No. 8).
INTERROGATORY NO. 10? From 1945 until the present, has the
Defendant sold or distributed materials to any of the named
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Co-Defendants which were to be used in the manufacture of
brake shoes or brake linings?
ANSWER: Yes.
INTERROGATORY NO. 11: If the answer to Interrogatory No. 10
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is yes, please state and answer the following:
(a) Identify each document or record which would indicate
the material sold or distributed and the Co-Defendant to whom
such material was sold or distributed-
(b) Identify the material sold or distributed.
(c) Identify whether the material purchased or received
contained asbestos and the type of asbestos contained therein (i.e., amosite, chrysolite or crocidolite).
(d) Identify the dates such material was sold or distri
buted and the Co-Defendant to whom such material was sold or
distributed. ANSWER: (a.) Defendant Abex objects to this Interrogatory as
being unduly broad and unlimited. This information is available
at Defendant's Winchester, Virginia, facility, and can be re-
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