Document ev8ozqGM6Ze5ay9GOjJ2jrVmq

INTERROGATORY NO. 3: Has Defendant or any of its predecessor or subsidiary companies at any time engaged in the mining and subsequent sale of material containing asbestos fibers? If so, identify the location of the mine(s), the years of its operation, the type of asbestos mined and whether you sold any asbestos to any Defendants in the Dallas County asbestos litigation. ANSWER: See Preliminary Statement and General Objections, which are incorporated herein as if fully rewritten. Further objecting, the interrogatory is overly broad given the parameters and subject matter of this case. Further objecting, the information sought is neither relevant to the subject matter of the pending action nor reasonably calculated to lead to the discovery of admissible evidence as it relates to Dana. Subject to mid without waiving objections, Dana does not know whether Smith & Kanzler Company ever engaged in the mining and subsequent sale of material containing asbestos fibers. INTERROGATORY NO. 4: * Identify by name each product containing asbestos fibers that Defendant or any of its predecessor or subsidiary companies at any time manufactured or sold. ANSWER: See Preliminary Statement and General Objections, which are incorporated herein as if fully rewritten. Further objecting, the interrogatory is overly broad given the parameters and subject matter of this case. Further objecting, the information sought is neither relevant to the subject matter of the pending action nor reasonably calculated to lead to the discovery of admissible evidence as it relates to Dana. Subject to and without waiving objections, Dana believes that Smith & Kanzler Company manufactured and sold an asbestos product used in the construction industry known as SprayCraft. INTERROGATORY NO. 5: Identify by name each product containing asbestos fibers that Defendant or any of its predecessor or subsidiary companies at any time marketed or sold. DEFENDANTS RESPONSES TO PLAINTIFFS' MASTER INTERROGATORIES F:\KELLY\DISC\DANA.INT PAGE -7-