Document g23G1qErDeEMYpN0aaJa5337Q

FILE NAME Paccar PAC DATE 2024 June 27 DOC PAC012 DOCUMENT DESCRIPTION Legal - Paccar's Objections & Answers to Plaintiffs Interrogatories Morris v Bel Air Auto Ex ] EXHIBIT I EFiled Jul 05 2024 PMEDT Transaction ID 73559242 THE CIRCUIT COURT FOR BALTIMORE CITY IN RE BALTIMORE CITY ASBESTOS LITIGATION ROSALIND MORRIS Individually and as Personal Representative of the Estate of John Alan Morris et al Plaintiffs VS. BEL AIR AUTO PARTS INC et al Defendants * * * * * * CASE NO 23-000029 * * April 8 2025 Trial Date * * * * * * * * * * DEFENDANT PACCAR INC'S OBJECTIONS AND ANSWERS TO PLAINTIFFS MASTER INTERROGATORIES AND NOW Comes Defendant PACCAR Inc Defendant PACCAR or PACCAR INC by and through their counsel DeHay & Elliston LLP and responds to Plaintiffs Master Interrogatories as follows PRELIMINARY STATEMENT These discovery responses are provided only for those products identified by Plaintiff and to which Plaintiff alleges exposure These discovery responses are based on an ongoing review of PACCAR's documents and information obtained from ongoing discussions with various PACCAR personnel Much of the information requested dates back many years and is difficult or impossible to reconstruct or retrieve These discovery responses are made pursuant to a reasonable and diligent investigation and search for the information requested PACCAR reserves the right to amend these discovery responses if new or additional information becomes available to it PACCAR prepared these discovery responses with the assistance of counsel No single employee officer or agent of PACCAR has hand knowledge regarding each and every response The person signing these responses does so to satisfy whatever requirement may exist under the applicable rules regarding verification That person is informed and believes that the information known as of the date of his signature supports the discovery responses below Page 1 of 193 INSTRUCTIONS Plaintiff's definitions and instructions are not repeated herein for the sake of brevity PACCAR objects to Plaintiff's definitions and instructions to the extent they are overbroad unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence PACCAR further objects to Plaintiff's definitions and instructions to the extent they include meanings and characterizations inconsistent with PACCAR's interpretation of the defined terms and phrases GENERAL OBJECTIONS PACCAR asserts the following objections and incorporates each by reference into each and every Answer to Plaintiff's Interrogatories set forth herein a PACCAR objects to Plaintiff's Interrogatories to the extent that they seek corporate knowledge as it is extremely difficult for PACCAR to set forth the collective knowledge of all of its past or present employees PACCAR reserves the right to revise correct supplement and amend its discovery responses to provide information discovered subsequent to the responses contained herein b PACCAR asserts the right to object on the grounds of competency privilege relevancy materiality or any other proper ground to the use of any said discovery response for any purpose in whole or in part in any subsequent step or proceeding in this litigation c PACCAR asserts the right to object on any other ground to other interrogatories or other discovery procedures involving or relating to the subject matter of the Interrogatories answered herein d PACCAR asserts the right to revise correct supplement or clarify any of its discovery responses set forth herein at any time and PACCAR reserves the right to object to the use of these discovery responses at trial or any other proceeding as deemed necessary and appropriate by PACCAR e PACCAR objects to the extent Plaintiff seeks documents no longer in PACCAR's possession PACCAR's document retention policy is 7 years save for documents that fall under specific categories As such PACCAR may no longer possess documents responsive to certain Requests f PACCAR objects to Plaintiff's Interrogatories to the extent that they involve matters outside of the geographical area at issue in this litigation and limits its discovery responses to said area (g) Furthermore these Interrogatories ask PACCAR to disclose information of which may no longer exist or may not be readily available is unrelated to the products at issue in this case Such information is also unrelated to the locations at which Decedent may have used any PACCAR product the conditions under which Decedent may have Page 2 of 193 used any PACCAR product the time period during which Decedent may have used any PACCAR product or the time period during which Plaintiff alleges exposure to any PACCAR product Thus Plaintiff's Interrogatories seek information which is neither material nor relevant to the issues in this litigation are overbroad in time scope and location and are otherwise not reasonably calculated to lead to the discovery of admissible evidence h Plaintiff's Interrogatories are oppressive burdensome and would require PACCAR to undertake a massive and extraordinary document search the results of which would have little to no demonstrable bearing on this litigation in light of the alleged exposure Moreover many of these Interrogatories are not susceptible to a response because they request information which dates back many years and is now virtually impossible for PACCAR to reconstruct or retrieve in its entirety PACCAR objects to Plaintiff's Interrogatories because they were propounded to harass and coerce a settlement despite the lack or complete absence of verifiable product identification and the lack of evidence of injury as a result of alleged exposure to or use of any product which PACCAR may or may not have assembled j PACCAR objects to these Interrogatories because they are propounded for an additional improper purpose namely as a fishing expedition for the purposes of obtaining information that may be taken out of context by Plaintiff's counsel to create allegations against PACCAR where none may legitimately exist k PACCAR objects to Plaintiff's Interrogatories as overbroad in that they seek information from entities other than itself or its predecessors PACCAR over the course of its long history has owned several businesses which are not involved in the instant litigation Therefore all references in Plaintiff's Interrogatories to DEFENDANT YOU or YOUR and the like are assumed to refer only to PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company 1 PACCAR objects to each and every Interrogatory that seeks production of any information constituting a trade secret confidential financial data or other confidential research development or commercial information m PACCAR objects to Plaintiff's Interrogatories as argumentative because they assume that a health hazard is created by the PACCAR products that may have incorporated asbestoscontaining component parts which PACCAR denies n PACCAR objects to Plaintiff's Interrogatories on the basis that they are vague and ambiguous Interrogatories relating to certain diseases fail to provide facts relating to the amount of exposure duration of exposure fiber type in exposure and latency period o PACCAR objects to Plaintiff's Interrogatories in that they tend to group together all of Defendants in this litigation and are therefore overbroad unduly burdensome harassing and not calculated to lead to the discovery of relevant and material evidence Page 3 of 193 p PACCAR objects to each and every Interrogatory that calls for either pure speculation or legal conclusions on the part of PACCAR q PACCAR objects to each and every Interrogatory that calls for a medical conclusion beyond the scope of PACCAR's knowledge and capability r PACCAR objects to each and every Interrogatory that purports to impose any obligations on it that are not set forth in the Maryland Rules of Civil Procedure PACCAR objects that Plaintiff has propounded more than 30 interrogatories in violation of Maryland Rule of Civil Procedure 2-421 These responses are made without waiving its objection based on Rule 2-421 a s PACCAR objects to each and every Interrogatory that seeks information protected by the attorney privilege or attorney work product doctrine t PACCAR objects to each and every Interrogatory that seeks disclosure of information generated by persons other than PACCAR that has come into the possession of PACCAR's counsel during the course of discovery and trial preparation in asbestos litigation u PACCAR objects to each and every Interrogatory that seeks information for any time period unrelated to Decedent's alleged exposure v PACCAR objects to each and every Interrogatory that seeks information that is not under PACCAR's custody or control or which is within the public domain or otherwise equally available to Plaintiff or their counsel Subject to and without waiving any of the foregoing objections PACCAR states as follows RESPONSES TO INTERROGATORIES INTERROGATORY NO 1 State the name address and official capacity of each person who has supplied information used in answering these Interrogatories and indicate for which Interrogatory each such person is responsible RESPONSE TO INTERROGATORY NO 1 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR also objects to this Request as oppressive and burdensome as it would require PACCAR to undertake a massive and extraordinary document search the results of which would have little to no demonstrable bearing on this litigation in light of the alleged exposure Page 4 of 193 Subject to and without waiver of the foregoing objections PACCAR prepared its Answers to Plaintiff's Interrogatories with the assistance of counsel No single employee officer or agent of PACCAR has firsthand knowledge regarding each and every response The following responses were prepared based upon the review of various documents and discussions with various individuals over the course of many years Because many of the subjects of inquiry occurred in some instances more than several decades ago due to the passage of time it is extremely difficult to pinpoint with any degree of accuracy when certain information was obtained or the identities of the individuals who may have located the information Rod Curbo PACCAR's corporate representative has verified these answers and has supplied responsive information Mr. Curbo's knowledge is based on his experience with the company and his conversations over the years with various Peterbilt and Kenworth personnel PACCAR has made a reasonable inquiry of the available sources of information in its responses to these Interrogatories Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 2 Identify each document that was examined reviewed and used in answering each Interrogatory and identify the present custodian of each document RESPONSE TO INTERROGATORY NO 2 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound unduly burdensome and oppressive PACCAR also objects to this Request as oppressive and burdensome as it would require PACCAR to undertake a massive and extraordinary document search the results of which would have little to no demonstrable bearing on this litigation in light of the alleged exposure PACCAR also objects to the extent this Interrogatory seeks information and documents protected from disclosure by the attorney privilege the work product doctrine or any other applicable protection Page 5 of 193 Subject to and without waiver of the foregoing objections PACCAR directs Plaintiff to its Objections and Response to Interrogatory No. 1 incorporated herein by reference Answering further and to the extent responsive documents exist PACCAR directs Plaintiff to the documents produced bates labeled PACCAR000001 - PACCAR002248 which contain documents that are responsive to the particular facts of this case Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 3 State whether you are a corporation If so state your corporate name state of incorporation date of incorporation address of principal place of business address of any other place of business whether if you are a foreign corporation as defined in Maryland General Corporation Law 1-101 you are now or have ever been registered or qualified to do business in the State of Maryland and the corporate name state of incorporation and date of incorporation of any subsidiary predecessor or affiliate corporation RESPONSE TO INTERROGATORY NO 3 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound harassing and unduly burdensome and oppressive PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR objects that the requested information is either already in Plaintiff's counsel's possession and equally available to Plaintiff as public record Subject to and without waiving these objections this Defendant's name is PACCAR Inc Page 6 of 193 no punctuation PACCAR is incorporated in Delaware with its principal place of business at 777 106th Avenue Bellevue Washington 98004 PACCAR's predecessor Pacific Car & Foundry was first incorporated in 1905 as the Seattle Car Manufacturing Company a manufacturer of railroad cars for the logging industry In 1911 Seattle Car changed its name to Seattle Car & Foundry which in turn was renamed Pacific Car & Foundry in 1917. Pacific Car & Foundry acquired Kenworth in 1945 and Peterbilt in 1958 PACCAR was originally incorporated in 1971 as a subsidiary of Pacific Car & Foundry Co. In January of 1972 Pacific Car & Foundry Co. was merged into PACCAR Finally PACCAR states that upon information and belief it is currently registered to do business in the State of Maryland as a foreign corporation and it has been since at least July 14 2011. Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO.4 NO.4 Identify all prior names by which you have existed RESPONSE TO INTERROGATORY NO.4 NO.4 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound harassing and unduly burdensome and oppressive PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company Page 7 of 193 PACCAR objects that the requested information is either already in Plaintiff's counsel's possession and equally available to Plaintiff as public record Subject to and without waiver of the foregoing objections PACCAR directs Plaintiff to its Objections and Response to Interrogatory No. 3 incorporated herein by reference Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 5 If you have divisions which have ever mined manufactured produced fabricated imported converted compounded processed sold merchandised supplied distributed and otherwise placed in the stream of commerce asbestos products identify each such division and state the names addresses and job titles of each person who supervised each division specifying the applicable time periods RESPONSE TO INTERROGATORY NO.5 NO.5 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound harassing and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR objects that the requested information is either already in Plaintiff's Page 8 of 193 counsel's possession and equally available to Plaintiff as public record PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR further objects on the basis that its Kenworth and Peterbilt divisions have assembled hundreds of thousands of trucks during their histories that those trucks were custom at the direction request and specification of the purchaser that certain information regarding those trucks is maintained by Vehicle Identification Number that Plaintiff has not identified the Vehicle Identification Number of any Kenworth or Peterbilt truck and therefore the location and identification of information responsive to this Interrogatory is unduly burdensome and oppressive and obtainable through less expensive and burdensome means Subject to and without waiving the foregoing objections PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks These vehicles included among other components axles transmissions and engines that were manufactured by various component suppliers PACCAR is informed and believes that some of these assembled component parts did at various points in time incorporate brakes clutches and gaskets that contained some form of encapsulated chrysotile These products were at all times manufactured by and obtained from various component part suppliers that are unrelated to PACCAR PACCAR did not specify the use of asbestos in these brakes clutches and engine gaskets and did not know the exact formulation or exact chemical Page 9 of 193 composition of the components manufactured by unrelated entities When those products contained asbestos at some point in time it was because the component manufacturers independently determined that asbestos was a necessary part of the formulation to achieve mandated performance specifications Those other entities would be considered the manufacturers and distributors of containing automotive friction products As such this Interrogatory should be directed to those entities PACCAR is informed and believes that for those cam brakes used in typical applications on Kenworth and Peterbilt trucks that historically contained asbestos the brake lining manufacturers completed their transition to asbestos in 1987. PACCAR is informed and believes that for certain severe duty applications and wedge brakes used on Kenworth and Peterbilt heavy duty trucks that historically contained asbestos the brake lining manufacturers completed their transition in 1990. Wedge brakes were typically used on a small subsection of heavy duty trucks either specifying light weight components or used in off highway applications With respect to clutches that historically contained asbestos PACCAR is informed and believes that PACCAR's primary clutch supplier completed its transition to asbestos in 1982 Discovery responses produced in asbestos litigation also confirm that at least one of PACCAR's primary engine suppliers transitioned away from using asbestos gaskets in the 1980s PACCAR's heavy duty trucks are custom These are extremely complicated machines that vary in form and function based on customer specification and commercial or vocational purpose The possible variations of these custom trucks number in the tens of thousands at least Accordingly the types of component parts that could safely perform on a given vehicle vary from truck to truck The component manufacturers transition to asbestos materials was a process that began in the late 1970s to early 1980s timeframe and took several Page 10 of 193 years to complete Early versions of asbestos brakes and clutches could safely be used on certain trucks for certain applications Thus certain Kenworth and Peterbilt trucks contained nonasbestos components prior to the date when manufacturers completely stopped using asbestos in their products Kenworth and Peterbilt provided service literature authored by their component suppliers to dealers and customers Specifically Kenworth and Peterbilt provided their dealers with master shop manuals that were comprised of a series of three binders which included component supplier service manuals Kenworth and Peterbilt also made these master shop manuals available to users for purchase Customers could also purchase custom maintenance manuals that include only specific information for their specific truck Additionally Kenworth and Peterbilt provided individual component supplier manuals inside the glove compartments or sleeper compartments of their trucks These manuals would correspond to the particular components specified by the user for a given truck Upon information and belief some of these component service manuals would have contained asbestos warnings starting in the 1970s For example PACCAR has located a 1978 Rockwell brake maintenance manual containing such a warning Additionally PACCAR may make additional documents available upon request if responsive documents exist at a mutually agreeable time and place should the parties meet and confer to narrow this Request to the relevant facts in this matter and Plaintiff identifies the relevant model and year for the equipment in issue Answering further PACCAR's primary suppliers of axles and brake assemblies during the relevant time period were Eaton and Rockwell Upon information and belief Eaton and Rockwell primary suppliers of engines during the relevant time period were Cummins Caterpillar and Page 11 of 193 Detroit Diesel PACCAR's primary supplier of clutches during the relevant time period was Spicer Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO.6 NO.6 Have you controlled purchased or in any way acquired any interest in any corporation or business entity which has mined manufactured produced fabricated imported converted compounded processed sold merchandised supplied distributed and otherwise placed in the stream of commerce asbestos products RESPONSE TO INTERROGATORY NO.6 NO.6 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound harassing and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR objects that the requested information is either already in Plaintiff's counsel's possession and equally available to Plaintiff as public record PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Page 12 of 193 Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their asbestoscontaining products PACCAR further objects on the basis that its Kenworth and Peterbilt divisions have assembled hundreds of thousands of trucks during their histories that those trucks were custom at the direction request and specification of the purchaser that certain information regarding those trucks is maintained by Vehicle Identification Number that Plaintiff has not identified the Vehicle Identification Number of any Kenworth or Peterbilt truck and therefore the location and identification of information responsive to this Interrogatory is unduly burdensome and oppressive and obtainable through less expensive and burdensome means Subject to and without waiver of the foregoing objections PACCAR directs Plaintiff to its Objections and Response to Interrogatory No. 5 incorporated herein by reference Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO.7 If your Answer to Interrogatory No. 6 is in the affirmative identify and attach copies of all documents related thereto and state a The name including prior name and the business address of any and all such corporation or business entity b The date on which you first controlled purchased or acquired said interest c The manner in which you acquired said interest i.e. cash purchase merger consolidation exchange or sale of assets et cetera d The percentage of assets ownership and control acquired by you e Whether the corporation or business entity acquired by you continued to exist following the acquisition and if not the date on which its existence ceased f The nature of and amount of consideration paid by you for said interest g The terms and conditions of any contracts or agreements by and between you and such corporation or business entity including but not limited to the terms and conditions relating to the transfer of liabilities for obligations of such corporation or business entity h Whether you continued the manufacture sale and distribution of such corporation's or business entity's asbestos products and if so whether you used the same product name in so doing and ) Whether there was an identity of name officers directors personnel property Page 13 of 193 suppliers distribution outlets and clients between you and such corporation or business entity RESPONSE TO INTERROGATORY NO PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound harassing and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR objects that the requested information is either already in Plaintiff's counsel's possession and equally available to Plaintiff as public record PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR further objects on the basis that its Kenworth and Peterbilt divisions have assembled hundreds of thousands of trucks during their histories that those Page 14 of 193 trucks were custom at the direction request and specification of the purchaser that certain information regarding those trucks is maintained by Vehicle Identification Number that Plaintiff has not identified the Vehicle Identification Number of any Kenworth or Peterbilt truck and therefore the location and identification of information responsive to this Interrogatory is unduly burdensome and oppressive and obtainable through less expensive and burdensome means PACCAR also objects to the extent this Interrogatory seeks information and documents protected from disclosure by the attorney privilege the work product doctrine or any other applicable protection Subject to and without waiver of the foregoing objections PACCAR directs Plaintiff to its Objections and Response to Interrogatory No. 6 incorporated herein by reference Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 8 If you have directly or indirectly mined manufactured produced fabricated imported converted compounded processed sold merchandised supplied distributed installed and otherwise placed in the stream of commerce asbestos or asbestoscontaining products state as to each such product indicating separately those products dealt with by you your predecessor in interest your subsidiary and your affiliate if any the following 390 Brand name name and mark 390 The generic name or identity 390 Description including size shape color and composition i.e. solid powder or other form d Chemical and physical composition including but not limited to the percentage of asbestos by weight and volume e Type of asbestos i.e. chrysotile amosite crocidolite actinolite anthophyllite or tremolite indicating specifically the percentage of each such asbestos fiber by weight and volume f Intended marketable use and (g) Dates during which each asbestos product was mined manufactured produced fabricated imported converted compounded processed sold merchandised supplied distributed installed and otherwise placed in the stream of commerce Page 15 of 193 RESPONSE TO INTERROGATORY NO.8 NO.8 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound harassing and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR objects that the requested information is either already in Plaintiff's counsel's possession and equally available to Plaintiff as public record PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR further objects on the basis that its Kenworth and Peterbilt divisions have assembled hundreds of thousands of trucks during their histories that those trucks were custom at the direction request and specification of the purchaser that certain Page 16 of 193 information regarding those trucks is maintained by Vehicle Identification Number that Plaintiff has not identified the Vehicle Identification Number of any Kenworth or Peterbilt truck and therefore the location and identification of information responsive to this Interrogatory is unduly burdensome and oppressive and obtainable through less expensive and burdensome means PACCAR also objects to the extent this Interrogatory seeks information and documents protected from disclosure by the attorney privilege the work product doctrine or any other applicable protection Subject to and without waiver of the foregoing objections PACCAR directs Plaintiff to its Objections and Response to Interrogatory No. 6 incorporated herein by reference Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 9 State whether you presently mine manufacture fabricate import convert compound process sell merchandise supply distribute install and otherwise place in the stream of commerce any asbestos product listed in your Answer to the preceding Interrogatory RESPONSE TO INTERROGATORY NO.9 NO.9 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound harassing and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not Page 17 of 193 involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR objects that the requested information is either already in Plaintiff's counsel's possession and equally available to Plaintiff as public record PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR further objects on the basis that its Kenworth and Peterbilt divisions have assembled hundreds of thousands of trucks during their histories that those trucks were custom at the direction request and specification of the purchaser that certain information regarding those trucks is maintained by Vehicle Identification Number that Plaintiff has not identified the Vehicle Identification Number of any Kenworth or Peterbilt truck and therefore the location and identification of information responsive to this Interrogatory is unduly burdensome and oppressive and obtainable through less expensive and burdensome means PACCAR also objects to the extent this Interrogatory seeks information and documents protected from disclosure by the attorney privilege the work product doctrine or any other applicable protection PACCAR further objects to the extent this Interrogatory implies it mine asbestos Subject to and without waiver of the foregoing objections PACCAR states no and directs Plaintiff to its Objections and Response to Interrogatory No. 6 incorporated herein by reference Page 18 of 193 Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 10 Identify each individual who participated in the design and preparation of manufacturing specifications for each asbestos product identified in your Answer to Interrogatory No. 8 RESPONSE TO INTERROGATORY NO 10 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous harassing and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR further objects Page 19 of 193 on the basis that its Kenworth and Peterbilt divisions have assembled hundreds of thousands of trucks during their histories that those trucks were custom at the direction request and specification of the purchaser that certain information regarding those trucks is maintained by Vehicle Identification Number that Plaintiff has not identified the Vehicle Identification Number of any Kenworth or Peterbilt truck and therefore the location and identification of information responsive to this Interrogatory is unduly burdensome and oppressive and obtainable through less expensive and burdensome means INTERROGATORY NO 11 State whether any written memoranda specifications blueprints or other written materials of any kind or character now exist relating to the design and preparation of the asbestos products identified in your Answer to Interrogatory No. 8. If so identity a Each such written material or document and b The custodian identity and location of each such written material or document RESPONSE TO INTERROGATORY NO 11 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous harassing and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Page 20 of 193 Motors Company PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR further objects on the basis that its Kenworth and Peterbilt divisions have assembled hundreds of thousands of trucks during their histories that those trucks were custom at the direction request and specification of the purchaser that certain information regarding those trucks is maintained by Vehicle Identification Number that Plaintiff has not identified the Vehicle Identification Number of any Kenworth or Peterbilt truck and therefore the location and identification of information responsive to this Interrogatory is unduly burdensome and oppressive and obtainable through less expensive and burdensome means PACCAR also objects to the extent this Interrogatory seeks information and documents protected from disclosure by the attorney privilege the work product doctrine or any other applicable protection Subject to and without waiver of the foregoing objections and to the extent responsive documents exist PACCAR directs Plaintiff to the documents bates labeled PACCAR000001PACCAR002248 Additionally PACCAR may make additional documents available upon request if responsive documents exist at a mutually agreeable time and place should the parties meet and confer to narrow this Request to the relevant facts in this matter and Plaintiff identifies the relevant model and year for the equipment in issue Answering further PACCAR possesses the following documents that may be responsive to Plaintiff's Request Page 21 of 193 1. Build Sheets for trucks assembled prior to 1988 are on microfiche and microfilm For those microfiche and microfilm in PACCAR's possession PACCAR stores the aforementioned microfiche related to Kenworth trucks in Washington and microfiche related to Peterbilt trucks in Texas PACCAR also possesses Peterbilt Build Sheets on microfilm for trucks assembled prior to 1972. These files are indexed by chassis number so with that information documents specific to a particular truck can be identified PACCAR can make these microfiche and microfilm available for physical review and copying at a mutually convenient time at Plaintiff's expense 2. Build Sheets previously kept on microfiche and converted to electronic format for Kenworth and Peterbilt trucks assembled prior to 1988 are stored as TIFF tagged image file format files For Kenworth vehicles these digitized Build Sheets are for trucks assembled from the late 1960s to 1987. For Peterbilt vehicles these digitized Build Sheets are for trucks assembled from the early 1970s to 1987. PACCAR can make all TIFF files available to Plaintiff at Plaintiff's expense upon reasonable notice These files are indexed by chassis number so with that information documents specific to a particular truck can be identified and 3. Build Sheets for trucks assembled from 1988 to the present are available electronically in vertical bar delimited text files PACCAR can make these vertical bar delimited text files available to Plaintiff at Plaintiff's expense upon reasonable notice Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 12 Identify by location and product each plant of yours in which the asbestos products identified in your Answer to Interrogatory No. 8 have been manufactured and assembled and the dates said plants have been in operation Page 22 of 193 RESPONSE TO INTERROGATORY NO 12 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous harassing and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products In addition PACCAR notes that to the best of its knowledge Plaintiff has not alleged that Decedent was employed by PACCAR worked at a PACCAR facility or was otherwise involved in the assembly of its trucks To the extent this Interrogatory seeks information about PACCAR facilities and employment practices that are not at issue it has no legitimate purpose other than to harass PACCAR and confuse the issues Page 23 of 193 PACCAR further objects on the basis that its Kenworth and Peterbilt divisions have assembled hundreds of thousands of trucks during their histories that those trucks were custom at the direction request and specification of the purchaser that certain information regarding those trucks is maintained by Vehicle Identification Number that Plaintiff has not identified the Vehicle Identification Number of any Kenworth or Peterbilt truck and therefore the location and identification of information responsive to this Interrogatory is unduly burdensome and oppressive and obtainable through less expensive and burdensome means Subject to and without waiver of the foregoing objections PACCAR's Kenworth and Peterbilt heavy trucks were assembled in various locations These locations include but are not limited to the following Kansas City Missouri 1964-1986 Chillicothe Ohio opened in 1973 Denton Texas opened in 1980 Nashville Tennessee opened in 1969 stopped assembling trucks in 2008 and closed in 2009 Renton Washington plant opened in 1993 Newark California plant closed in 1986 Oakland California plant closed in 1960 Mexicali Mexico St. Therese Montreal and Seattle Washington from 1945 the time PACCAR purchased Kenworth until the facility closed in 2001 Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 13 If you have discontinued mining manufacturing producing fabricating importing converting compounding processing selling merchandising supplying distributing and otherwise placing in the stream of commerce any asbestos products listed in your Answer to Interrogatory No. 8 identity the products discontinued give the date of discontinuance and specify the reason for such discontinuance RESPONSE TO INTERROGATORY NO 13 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound harassing and unduly burdensome and oppressive PACCAR objects that Page 24 of 193 this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR further objects on the basis that its Kenworth and Peterbilt divisions have assembled hundreds of thousands of trucks during their histories that those trucks were custom at the direction request and specification of the purchaser that certain information regarding those trucks is maintained by Vehicle Identification Number that Plaintiff has not identified the Vehicle Identification Number of any Kenworth or Peterbilt truck and therefore the location and identification of information responsive to this Interrogatory is unduly burdensome and oppressive and obtainable through less expensive and burdensome means Page 25 of 193 Subject to and without waiving the foregoing objections PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks These vehicles included among other components axles transmissions and engines that were manufactured by various component suppliers PACCAR is informed and believes that some of these assembled component parts did at various points in time incorporate brakes clutches and gaskets that contained some form of encapsulated chrysotile These products were at all times manufactured by and obtained from various component part suppliers that are unrelated to PACCAR PACCAR did not specify the use of asbestos in these brakes clutches and engine gaskets and did not know the exact formulation or exact chemical composition of the components manufactured by unrelated entities When those products contained asbestos at some point in time it was because the component manufacturers independently determined that asbestos was a necessary part of the formulation to achieve mandated performance specifications Those other entities would be considered the manufacturers and distributors of containing automotive friction products As such this Interrogatory should be directed to those entities PACCAR is informed and believes that for those cam brakes used in typical applications on Kenworth and Peterbilt trucks that historically contained asbestos the brake lining manufacturers completed their transition to asbestos in 1987. PACCAR is informed and believes that for certain severe duty applications and wedge brakes used on Kenworth and Peterbilt heavy duty trucks that historically contained asbestos the brake lining manufacturers completed their transition in 1990. Wedge brakes were typically used on a small subsection of heavy duty trucks either specifying light weight components or used in off highway applications Page 26 of 193 With respect to clutches that historically contained asbestos PACCAR is informed and believes that PACCAR's primary clutch supplier completed its transition to asbestos in 1982 Discovery responses produced in asbestos litigation also confirm that at least one of PACCAR's primary engine suppliers transitioned away from using asbestos gaskets in the 1980s PACCAR's heavy duty trucks are custom These are extremely complicated machines that vary in form and function based on customer specification and commercial or vocational purpose The possible variations of these custom trucks number in the tens of thousands at least Accordingly the types of component parts that could safely perform on a given vehicle vary from truck to truck The component manufacturers transition to asbestos materials was a process that began in the late 1970s to early 1980s timeframe and took several years to complete Early versions of asbestos brakes and clutches could safely be used on certain trucks for certain applications Thus certain Kenworth and Peterbilt trucks contained nonasbestos components prior to the date when manufacturers completely stopped using asbestos in their products Answering further and to the extent responsive documents exist PACCAR directs Plaintiff to the documents produced bates labeled PACCAR000001 PACCAR002248 which contain documents that are responsive to the particular facts of this case Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 14 If you have done so when did you first determine that any other material could be used in place of asbestos for temperature insulation or any other use to or for which asbestos has been applied If you have in fact substituted other material for asbestos in your product then state a The identity of such substituted material b When the product with such substituted material was first marketed and c The name and brand name of the product marketed with such substituted material Page 27 of 193 RESPONSE TO INTERROGATORY NO 14 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR further objects on the basis that its Kenworth and Peterbilt divisions have assembled hundreds of thousands of trucks during their histories that those trucks were custom at the direction request and specification of the purchaser that certain information regarding those trucks is maintained by Vehicle Identification Number that Plaintiff has not identified the Vehicle Identification Number of any Kenworth or Page 28 of 193 Peterbilt truck and therefore the location and identification of information responsive to this Interrogatory is unduly burdensome and oppressive and obtainable through less expensive and burdensome means Subject to and without waiving the foregoing objections PACCAR directs Plaintiff to its Objections and Response to Interrogatory No. 13 incorporated herein Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 15 State whether you have ever made any changes to or alterations of your asbestos products from 1930 to the present If so state a The identity by brand name and trade name of each such product b The date each such product was changed or altered c The manner in which each such product was changed or altered including but not limited to any changes in the asbestos content or chemical composition of each such product d The reason for each change or alteration and e The identity of the person responsible for instituting each change or alteration RESPONSE TO INTERROGATORY NO 15 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent Page 29 of 193 that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR further objects on the basis that its Kenworth and Peterbilt divisions have assembled hundreds of thousands of trucks during their histories that those trucks were custom at the direction request and specification of the purchaser that certain information regarding those trucks is maintained by Vehicle Identification Number that Plaintiff has not identified the Vehicle Identification Number of any Kenworth or Peterbilt truck and therefore the location and identification of information responsive to this Interrogatory is unduly burdensome and oppressive and obtainable through less expensive and burdensome means PACCAR further objects to the misleading reference to your asbestos products which is argumentative and improper Subject to and without waiving the foregoing objections PACCAR directs Plaintiff to its Objections and Response to Interrogatory No. 13 incorporated herein Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 16 Do you contend that any of the asbestos products listed in your Answer to Interrogatory No. 8 require change or modification before they may be used If so specify what change or modification is required for each such product Page 30 of 193 RESPONSE TO INTERROGATORY NO 16 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR further objects to the undefined phrase change or modification as overbroad vague and ambiguous PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR further objects on the basis that its Kenworth and Peterbilt divisions have assembled hundreds of thousands of trucks during their histories that those trucks were custom at the direction request and specification of the purchaser that certain information regarding those trucks is maintained by Vehicle Page 31 of 193 Identification Number that Plaintiff has not identified the Vehicle Identification Number of any Kenworth or Peterbilt truck and therefore the location and identification of information responsive to this Interrogatory is unduly burdensome and oppressive and obtainable through less expensive and burdensome means INTERROGATORY NO 17 Identify all patents issued or any applications made therefore for any asbestos product listed in your Answer to Interrogatory No. 8. Specify the number of each patent the date of application issuance and renewal if applicable to whom each patent was issued and the product for which each patent was issued RESPONSE TO INTERROGATORY NO 17 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead Page 32 of 193 be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR further objects on the basis that its Kenworth and Peterbilt divisions have assembled hundreds of thousands of trucks during their histories that those trucks were custom at the direction request and specification of the purchaser that certain information regarding those trucks is maintained by Vehicle Identification Number that Plaintiff has not identified the Vehicle Identification Number of any Kenworth or Peterbilt truck and therefore the location and identification of information responsive to this Interrogatory is unduly burdensome and oppressive and obtainable through less expensive and burdensome means Subject to and without waiver of the foregoing objections PACCAR states that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture asbestos- containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products and any related patents Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 18 Identify all trademarks registered for any products listed in your Answer to Interrogatory No. 8. Specify the number and date of registration the term thereof the date of renewal if applicable by whom each trademark was registered and the product for which each trademark was registered RESPONSE TO INTERROGATORY NO 18 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered Page 33 of 193 by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR further objects on the basis that its Kenworth and Peterbilt divisions have assembled hundreds of thousands of trucks during their histories that those trucks were custom at the direction request and specification of the purchaser that certain information regarding those trucks is maintained by Vehicle Identification Number that Plaintiff has not identified the Vehicle Identification Number of any Kenworth or Peterbilt truck and therefore the location and identification of information responsive to this Interrogatory is unduly burdensome and oppressive and obtainable through less expensive and burdensome means Page 34 of 193 Subject to and without waiver of the foregoing objections and as PACCAR understands this Interrogatory PACCAR states that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products and any related trademarks Answering further PACCAR's heavy duty trucks were stamped or otherwise identified with the company name and logo that is Kenworth KW or Peterbilt Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 19 State whether you have distributed or sold any asbestos or containing products which were mined manufactured produced fabricated imported converted compounded processed sold merchandised supplied and otherwise placed in the stream of commerce by persons and business entities other than you or your predecessor in interest or subsidiary if any If so state a The identity of each such person and business entity whose asbestos products you sold or distributed on a product basis b The terms of all assignments agreements licenses and other arrangements which relate to same Identify and attach copies of all such documents c As to each product the brand name trade name and trademark adopted and used by the source from which you obtained said product for distribution or sale d As to each product the brand name trade name and trademark adopted and used by you for purposes of distribution or sale of said product e The generic name or identity of each such product f The dates during which you distributed or sold each such asbestos product g As to each such product a description including size shape color composition i.e. solid powder or other form h As to each such product the type of asbestos and the percentage of asbestos by weight and volume 36 As to each such product its intended marketable use 36 The identity of each person and business entity in the State of Maryland to whom or to which you sold or distributed each such product k The identity of each contractor subcontractor installer or other business in the Page 35 of 193 State of Maryland which ultimately installed applied or used each such product and ) The custodian identity and location of each document which refers to or contains information relevant to such sale or distribution RESPONSE TO INTERROGATORY NO 19 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound harassing and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR further objects on the basis that its Kenworth and Peterbilt divisions have assembled hundreds of thousands of trucks during their histories that those trucks were custom at the direction request and specification of the Page 36 of 193 purchaser that certain information regarding those trucks is maintained by Vehicle Identification Number that Plaintiff has not identified the Vehicle Identification Number of any Kenworth or Peterbilt truck and therefore the location and identification of information responsive to this Interrogatory is unduly burdensome and oppressive and obtainable through less expensive and burdensome means PACCAR also objects to the extent this Interrogatory seeks information and documents protected from disclosure by the attorney privilege the work product doctrine or any other applicable protection Subject to and without waiving the foregoing objections PACCAR directs Plaintiff to its Objections and Response to Interrogatory No. 5 incorporated herein Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 20 Identify the distributors of your asbestos products at any time during the period from 1930 to the present and identify and attach copies of all documents relating to said distributors For each distributor indicate a The terms of all assignments agreements licenses and other arrangements by and between you and said distributor b Whether the distribution relationship was exclusive c The year or years in which the distribution relationship was in effect d The identity of your asbestos products which the distributor was authorized to and did distribute and e The quantity of your asbestos products distributed by the distributor on a year year and product basis RESPONSE TO INTERROGATORY NO 20 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound harassing and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also Page 37 of 193 objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR further objects on the basis that its Kenworth and Peterbilt divisions have assembled hundreds of thousands of trucks during their histories that those trucks were custom at the direction request and specification of the purchaser that certain information regarding those trucks is maintained by Vehicle Identification Number that Plaintiff has not identified the Vehicle Identification Number of any Kenworth or Peterbilt truck and therefore the location and identification of information responsive to this Interrogatory is unduly burdensome and oppressive and obtainable through less expensive and burdensome means PACCAR also objects to the extent this Interrogatory seeks information and documents protected from disclosure by the attorney privilege the work product doctrine or any other applicable protection INTERROGATORY NO 21 State whether you have ever sold distributed or otherwise furnished any of your asbestos products to any other person and business entity for resale or Page 38 of 193 redistribution at any time from 1930 to the present If so state a The identity of each such person and business entity b The brand name trade name and trademark adopted and used by you for each such product c The brand name trade name and trademark adopted and used by each such person and business entity for each such product d The generic name or identity of each such product e The year in which each such product was sold distributed or otherwise furnished to each such person and business entity and for each year the quantity of each product sold distributed or otherwise furnished f The intended marketable use for each such product g Whether each such product was intended to be used resold or distributed by such other person and business entity in the same or substantially the same condition as it was when shipped or delivered by you and h The custodian identity and location of all documents pertaining to agreements for the resale distribution or furnishing of your asbestos products to each other person and business entity RESPONSE TO INTERROGATORY NO 21 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound harassing and unduly burdensome and oppressive PACCAR objects that this Interrogatory is vague ambiguous compound harassing and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Page 39 of 193 Motors Company PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR further objects on the basis that its Kenworth and Peterbilt divisions have assembled hundreds of thousands of trucks during their histories that those trucks were custom at the direction request and specification of the purchaser that certain information regarding those trucks is maintained by Vehicle Identification Number that Plaintiff has not identified the Vehicle Identification Number of any Kenworth or Peterbilt truck and therefore the location and identification of information responsive to this Interrogatory is unduly burdensome and oppressive and obtainable through less expensive and burdensome means INTERROGATORY NO 22 State the following with respect to the packages and containers in which you sold distributed or otherwise furnished each of the asbestos products described in your Answers to Interrogatory Nos 8 and 19 on a year and product basis a A description of the package or container in which each product was sold distributed or otherwise furnished including composition size shape and color b A description of the markings or printed material that appeared on each package or container indicating the size and color of the same c A description of any logo or other design appearing on the package or container d A verbatim description of any caution or warning notice appearing on the package or container setting forth the year in which each such notice appeared on each such product and e A verbatim description of any instructions appearing on the package or container RESPONSE TO INTERROGATORY NO 22 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound harassing and unduly burdensome and oppressive PACCAR objects that Page 40 of 193 this Interrogatory is vague ambiguous compound harassing and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR further objects on the basis that its Kenworth and Peterbilt divisions have assembled hundreds of thousands of trucks during their histories that those trucks were custom at the direction request and specification of the purchaser that certain information regarding those trucks is maintained by Vehicle Identification Number that Plaintiff has not identified the Vehicle Identification Number of any Kenworth or Peterbilt truck and therefore the location and identification of information Page 41 of 193 responsive to this Interrogatory is unduly burdensome and oppressive and obtainable through less expensive and burdensome means Subject to and without waiving the foregoing objections PACCAR's trucks are not nor have they ever been sold distributed or otherwise furnished in packages or containers as PACCAR understands those terms Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 23 If your Answer to Interrogatory No. 22 reflects that any changes were made to the packages and containers in which you sold distributed or otherwise furnished each of the asbestos products described in your Answer to Interrogatory Nos 8 and 19 indicate as to each such package or container a The nature of each such change e.g. changes in composition size shape and color and or changes regarding the placement modification or removal of any color logo design name word number instruction warning or other markings on the container (b) The date on which you decided to make the change (c) The date the container was in fact changed (d) The reason for the change (e) The identity of each present or former employee officer representative or agent of yours at any time from 1930 to the present with knowledge or information regarding your decision to change any aspect of the package or container and f The custodian location and identity of each document in your custody control or possession which contains information relevant to your decision to change any aspect of the package or container RESPONSE TO INTERROGATORY NO 23 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound harassing and unduly burdensome and oppressive PACCAR objects that this Interrogatory is vague ambiguous compound harassing and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities Page 42 of 193 time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR further objects on the basis that its Kenworth and Peterbilt divisions have assembled hundreds of thousands of trucks during their histories that those trucks were custom at the direction request and specification of the purchaser that certain information regarding those trucks is maintained by Vehicle Identification Number that Plaintiff has not identified the Vehicle Identification Number of any Kenworth or Peterbilt truck and therefore the location and identification of information responsive to this Interrogatory is unduly burdensome and oppressive and obtainable through less expensive and burdensome means PACCAR also objects to the extent this Interrogatory seeks information and documents protected from disclosure by the attorney privilege the work product doctrine or any other applicable protection Subject to and without waiver of the foregoing objections PACCAR directs Plaintiff to its objections and response to Interrogatory No. 22 incorporated herein by reference Discovery is Page 43 of 193 ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 24 For each asbestos product identified in your Answer to Interrogatory Nos 8 and 19 as being manufactured sold distributed or otherwise furnished by you state a Whether you have actual packages or containers or photographs of packages or containers in which said products were sold distributed or otherwise furnished and b The identity of the custodian of said packages or containers or photographs thereof RESPONSE TO INTERROGATORY NO 24 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound harassing and unduly burdensome and oppressive PACCAR objects that this Interrogatory is vague ambiguous compound harassing and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather Page 44 of 193 they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR further objects on the basis that its Kenworth and Peterbilt divisions have assembled hundreds of thousands of trucks during their histories that those trucks were custom at the direction request and specification of the purchaser that certain information regarding those trucks is maintained by Vehicle Identification Number that Plaintiff has not identified the Vehicle Identification Number of any Kenworth or Peterbilt truck and therefore the location and identification of information responsive to this Interrogatory is unduly burdensome and oppressive and obtainable through less expensive and burdensome means Subject to and without waiving the foregoing objections PACCAR directs Plaintiff to its Objections and Response to Interrogatory No. 22 incorporated herein Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 25 State whether you prepared or published any catalogues brochures or other documents describing products containing asbestos or asbestos components If so identify each such catalogue brochure or other document and the custodian thereof RESPONSE TO INTERROGATORY NO 25 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound harassing and unduly burdensome and oppressive PACCAR objects that this Interrogatory is vague ambiguous compound harassing and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden Page 45 of 193 of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR further objects on the basis that its Kenworth and Peterbilt divisions have assembled hundreds of thousands of trucks during their histories that those trucks were custom at the direction request and specification of the purchaser that certain information regarding those trucks is maintained by Vehicle Identification Number that Plaintiff has not identified the Vehicle Identification Number of any Kenworth or Peterbilt truck and therefore the location and identification of information responsive to this Interrogatory is unduly burdensome and oppressive and obtainable through less expensive and burdensome means PACCAR further objects that this Interrogatory is confusing as drafted given that it does not refer to any particular product Subject to and without waiving the foregoing objections PACCAR states that upon information and belief Kenworth and Peterbilt provided service literature authored by their Page 46 of 193 component suppliers to dealers and customers Specifically Kenworth and Peterbilt provided their dealers with master shop manuals that were comprised of a series of three binders which included component supplier service manuals Kenworth and Peterbilt also made these master shop manuals available to users for purchase Customers could also purchase custom maintenance manuals that include only specific information for their specific truck Additionally Kenworth and Peterbilt provided individual component supplier manuals inside the glove compartments or sleeper compartments of their trucks These manuals would correspond to the particular components specified by the user for a given truck Upon information and belief some of these component service manuals would have contained asbestos warnings starting in the 1970s For example PACCAR has located a 1978 Rockwell brake maintenance manual containing such a warning Further to the extent responsive documents exist PACCAR directs Plaintiff to the documents produced bates labeled PACCAR000001 - PACCAR002248 which contain documents that are responsive to the particular facts of this case including the relevant time frame and that are related to the relevant product in issue Additionally PACCAR may make additional documents available upon request if responsive documents exist at a mutually agreeable time and place should the parties meet and confer to narrow this Request to the relevant facts in this matter and Plaintiff identify the relevant model and year for the equipment in issue Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 26 Identify each present or former employee officer agent or representative of yours who directed handled solicited supervised promoted or otherwise participated in the sale supply distribution delivery installation or removal in Maryland at any time from 1930 to the present of any asbestos products -identified in your Answers to Interrogatory Nos 8 and 19 Page 47 of 193 RESPONSE TO INTERROGATORY NO 26 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound harassing and unduly burdensome and oppressive PACCAR objects that this Interrogatory is vague ambiguous compound harassing and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR further objects on the basis that its Kenworth and Peterbilt divisions have assembled hundreds of thousands of trucks during their histories that those trucks were custom at the direction request and specification of the purchaser that certain information regarding those trucks is maintained by Page 48 of 193 Vehicle Identification Number that Plaintiff has not identified the Vehicle Identification Number of any Kenworth or Peterbilt truck and therefore the location and identification of information responsive to this Interrogatory is unduly burdensome and oppressive and obtainable through less expensive and burdensome means PACCAR further objects that this Interrogatory is confusing as drafted given that it does not refer to any particular product INTERROGATORY NO 27 For each person identified in your Answer to Interrogatory No. 26 who participated in the advertising in Maryland of any asbestos products identified in Answer to Interrogatory Nos 8 and 19 at any time from 1930 to the present state a His or her duties responsibilities and inclusive years of employment b The identity of each product advertised marketed or promoted and c The method by which each product was advertised marketed or promoted and if by print the name of the publication the inclusive dates during which the advertisement or promotion appeared therein and the publisher RESPONSE TO INTERROGATORY NO 27 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound harassing and unduly burdensome and oppressive PACCAR objects that this Interrogatory is vague ambiguous compound harassing and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities Page 49 of 193 other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR further objects on the basis that its Kenworth and Peterbilt divisions have assembled hundreds of thousands of trucks during their histories that those trucks were custom at the direction request and specification of the purchaser that certain information regarding those trucks is maintained by Vehicle Identification Number that Plaintiff has not identified the Vehicle Identification Number of any Kenworth or Peterbilt truck and therefore the location and identification of information responsive to this Interrogatory is unduly burdensome and oppressive and obtainable through less expensive and burdensome means PACCAR further objects that this Interrogatory is confusing as drafted given that it does not refer to any particular product INTERROGATORY NO 28 Describe your corporate structure and policy concerning the subject of employee safety in the design development manufacture testing and use of asbestos products identified in your Answers to Interrogatory Nos 8 and 19 from 1930 to the present In your Answer to this Interrogatory identify each present or former corporate department division subdivision or other group responsible for the described activities and dates related thereto and with respect to each identify the name title duties responsibilities dates of employment and current or last known business and residential address of the highest supervisory employee with knowledge of any of those activities during any time from 1930 to the present RESPONSE TO INTERROGATORY NO 28 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR further objects to the undefined phrase corporate structure as overbroad vague and ambiguous PACCAR objects Page 50 of 193 that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR further objects that this Interrogatory is confusing as drafted given that it does not refer to any particular product PACCAR further objects that this Interrogatory lacks sufficient specificity regarding the type of asbestos level duration and manner of alleged exposure PACCAR also objects to this Interrogatory as argumentative because it inappropriately assumes that exposures to all asbestoscontaining products are equal and hazardous despite the abundance of epidemiological studies which demonstrate that mechanics are not at an increased risk of developing an asbestos disease Accordingly without more specificity regarding the type of product type of asbestos Page 51 of 193 fiber amount of exposure duration of exposure and latency period PACCAR cannot fully answer this Interrogatory In addition PACCAR notes that to the best of its knowledge Plaintiff has not alleged that Decedent was employed by PACCAR worked at a PACCAR facility or was otherwise involved in the assembly of its trucks To the extent this Interrogatory seeks information about PACCAR facilities and employment practices that are not at issue it has no legitimate purpose other than to harass PACCAR and confuse the issues PACCAR also objects to the extent that this Interrogatory implies that PACCAR had a duty to conduct or contribute to the conducting of any sampling analyses studies or testing of any product which allegedly contained asbestos and was manufactured by another company PACCAR objects to this Request as overbroad in that it seeks information from entities other than itself or its predecessors PACCAR also objects to this Request as oppressive and burdensome as it would require PACCAR to undertake a massive and extraordinary document search the results of which would have little to no demonstrable bearing on this litigation in light of the alleged exposure INTERROGATORY NO 29 Describe your corporate structure concerning the subject of research and development of asbestos products identified in your Answers to Interrogatory Nos 8 and 19 from 1930 to the present In your Answer to this Interrogatory identify each present or former corporate department division subdivision or other group responsible for any of these activities and with respect to each identify the name title duties responsibilities dates of employment and current or last known business and residential address of the highest supervisory employee during any time from 1930 to the present RESPONSE TO INTERROGATORY NO 29 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR further objects to the undefined phrase corporate structure as overbroad vague and ambiguous PACCAR further objects to the undefined phrase corporate structure as overbroad vague and ambiguous PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact Page 52 of 193 witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products INTERROGATORY NO 30 Describe your corporate structure concerning medical directors industrial hygienists physicians biological scientists or consultants in these fields from 1930 to the present In your Answer to this Interrogatory identify the name title duties responsibilities period of employment to whom the individual reported and the current or last known business and residential address of each medical director industrial hygienist or consultant of yours or your predecessor in interest or subsidiary if any RESPONSE TO INTERROGATORY NO 30 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR further objects to the undefined phrase corporate structure as overbroad vague and ambiguous PACCAR further Page 53 of 193 objects to the undefined phrase corporate structure as overbroad vague and ambiguous PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company In addition PACCAR notes that to the best of its knowledge Plaintiff has not alleged that Decedent was employed by PACCAR worked at a PACCAR facility or was otherwise involved in the assembly of its trucks To the extent this Interrogatory seeks information about PACCAR facilities and employment practices that are not at issue it has no legitimate purpose other than to harass PACCAR and confuse the issues PACCAR also objects to this Request as oppressive and burdensome as it would require PACCAR to undertake a massive and extraordinary document search the results of which would have little to no demonstrable bearing on this litigation in light of the alleged exposure Subject to and without waiving the foregoing objections PACCAR is informed and believes it may have employed David Bissonnette as an industrial hygienist from 1974 to 2000 and Robert Shumacher was an industrial hygienist from 1984 to 1986. Steve Miller was an Page 54 of 193 industrial hygienist from 1989 until 2014. As for medical directors PACCAR is informed and believes that it employed Dr. J. F. Johanson as a medical director in the 1970s Dr. J.M. Hughes as a medical director in 1984 and Dr. Francis VonFeldt as a medical director from 1985 to 2000 Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 31 Identify any medical examination program offered or sponsored by you or your insurance carrier from 1930 to the present for employees handling or otherwise exposed to asbestos and asbestos products With respect to each such program indicating applicable time periods state a The manner of communicating with employees about such program b Whether examination was optional or mandatory and if the latter how frequently such examination was required c What percentage of employees permitted to undergo such examination actually participated d What percentage of employees who underwent such medical examination were found to have pneumoconiosis asbestosis mesothelioma lung cancer or other cancers and e With respect to the employees referred to in your Answer to Part d of this Interrogatory what percentage of these employees were paid disability and worker's compensation benefits and for what percentage of employees were medical expenses paid for purposes of treatment of such condition RESPONSE TO INTERROGATORY NO 31 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR further objects to the undefined phrase corporate structure as overbroad vague and ambiguous PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not Page 55 of 193 reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company In addition PACCAR notes that to the best of its knowledge Plaintiff has not alleged that Decedent was employed by PACCAR worked at a PACCAR facility or was otherwise involved in the assembly of its trucks To the extent this Interrogatory seeks information about PACCAR facilities and employment practices that are not at issue it has no legitimate purpose other than to harass PACCAR and confuse the issues PACCAR also objects to this Request as oppressive and burdensome as it would require PACCAR to undertake a massive and extraordinary document search the results of which would have little to no demonstrable bearing on this litigation in light of the alleged exposure PACCAR further objects that this Interrogatory lacks sufficient specificity regarding the type of asbestos level duration and manner of alleged exposure PACCAR also objects to this Interrogatory as argumentative because it inappropriately assumes that exposures to all containing products are equal and hazardous despite the abundance of epidemiological studies which demonstrate that mechanics are not at an increased risk of developing an asbestos disease Accordingly without more specificity regarding the type of product type of asbestos fiber amount of exposure duration of exposure and latency period PACCAR cannot fully answer this Interrogatory PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Page 56 of 193 Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their asbestos- containing products PACCAR also objects to the extent this Interrogatory seeks information and documents protected from disclosure by the attorney privilege the work product doctrine or any other applicable protection Subject to and without waiving the foregoing objections and as PACCAR understands this Interrogatory PACCAR provided medical coverage to qualified employees under which any individual could seek a medical determination of the presence or absence of asbestos related disease Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 32 State whether you or anyone on your behalf ever conducted engaged in or participated in any tests studies and research concerning the human health consequences of persons coming in contact with and inhaling asbestos fibers or asbestos dust during the manufacture and use of asbestos products If so identify a What tests studies and research were done b When said tests studies and research were done (c) The individuals who ordered and supervised the tests studies and research d The individuals or groups engaged in or participating in the tests studies and research e The substance of any recommendations and suggestions given as a result of the tests studies or research State when by whom and to whom said recommendations were made including the addresses of these individuals f All written documents including but not limited to reports memoranda specifications and correspondence which refer relate or pertain to said tests studies and research and (g) The present custodian of the written documents identified in your Answer to Part of this Interrogatory RESPONSE TO INTERROGATORY NO 32 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR further objects to the undefined term dust as overbroad vague and ambiguous PACCAR objects that this Page 57 of 193 Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR further objects that this Interrogatory is confusing as drafted given that it does not refer to any particular product PACCAR further objects that this Interrogatory lacks sufficient specificity regarding the type of asbestos level duration and manner of alleged exposure PACCAR also objects to this Interrogatory as argumentative because it inappropriately assumes that exposures to all asbestoscontaining products are equal and hazardous despite the abundance of epidemiological studies which demonstrate that mechanics are not at an increased risk of developing an asbestos disease Accordingly without more specificity regarding the type of product type of asbestos Page 58 of 193 fiber amount of exposure duration of exposure and latency period PACCAR cannot fully answer this Interrogatory In addition PACCAR notes that to the best of its knowledge Plaintiff has not alleged that Decedent was employed by PACCAR worked at a PACCAR facility or was otherwise involved in the assembly of its trucks To the extent this Interrogatory seeks information about PACCAR facilities and employment practices that are not at issue it has no legitimate purpose other than to harass PACCAR and confuse the issues PACCAR also objects to the extent that this Interrogatory implies that PACCAR hada duty to conduct or contribute to the conducting of any sampling analyses studies or testing of any product which allegedly contained asbestos and was manufactured by another company PACCAR also objects to this Request as oppressive and burdensome as it would require PACCAR to undertake a massive and extraordinary document search the results of which would have little to no demonstrable bearing on this litigation in light of the alleged exposure PACCAR also objects to the extent this Interrogatory seeks information and documents protected from disclosure by the attorney privilege the work product doctrine or any other applicable protection Subject to and without waiving the foregoing objections David Bissonette CIH was hired in 1974 and in 1976 Mr. Bissonette enumerated a three testing process in a 1976 presentation 1 identify a possible hazard 2 evaluate the possible hazard and 3 if the evaluation shows that there is a hazard put controls in place Mr. Bissonnette's testing revealed that there were no health hazards to mechanics performing brake work Responding further and to the extent responsive documents exist PACCAR directs Plaintiff to the documents produced bates labeled PACCAR000001 PACCAR002248 which contain documents that are responsive to the particular facts of this case including the relevant time frame and that are related to the relevant product in issue These documents contain testing related to asbestos and only with regard to Page 59 of 193 PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 33 State whether any of the medical directors industrial hygienists physicians biological scientists or consultants in these fields identified in your Answer to Interrogatory No. 30 ever made any recommendations and suggestions to you pertaining to the risks or hazards to persons involved in the manufacture or use of asbestos products If so identify a The date when said recommendations and suggestions were made b The individual to whom said recommendations and suggestions were made (c) The individual who made said recommendations and suggestions (d) The substance of the recommendations and suggestions and (e) What actions if any were taken by you as a result of said recommendations and suggestions RESPONSE TO INTERROGATORY NO 33 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects on the basis that this Interrogatory appears to be Page 60 of 193 directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR further objects that this Interrogatory is confusing as drafted given that it does not refer to any particular product PACCAR further objects that this Interrogatory lacks sufficient specificity regarding the type of asbestos level duration and manner of alleged exposure PACCAR also objects to this Interrogatory as argumentative because it inappropriately assumes that exposures to all asbestoscontaining products are equal and hazardous despite the abundance of epidemiological studies which demonstrate that mechanics are not at an increased risk of developing an asbestos disease Accordingly without more specificity regarding the type of product type of asbestos fiber amount of exposure duration of exposure and latency period PACCAR cannot fully answer this Interrogatory In addition PACCAR notes that to the best of its knowledge Plaintiff has not alleged that Decedent was employed by PACCAR worked at a PACCAR facility or was otherwise involved in the assembly of its trucks To the extent this Interrogatory seeks information about PACCAR facilities and employment practices that are not at issue it has no legitimate purpose other than to harass PACCAR and confuse the issues PACCAR also objects to this Request as oppressive and burdensome as it would require PACCAR to undertake a massive and extraordinary document search the results of which would have little to no demonstrable bearing on this litigation in light of the alleged exposure Subject to and without waiving the foregoing objections PACCAR directs Plaintiff to its Objections and Answer to Interrogatory No. 32 incorporated herein Discovery is ongoing and Page 61 of 193 PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 34 State whether you have ever conducted or directed any studies to determine the amount of asbestos dust in your asbestos product manufacturing facilities If so identify a The date of each such study b The individual or group conducting each such study (c) The result or conclusion of each such study d All documents which refer relate or pertain to each such study and (e) The present custodian of all documents identified in your Answer to Part d of this Interrogatory RESPONSE TO INTERROGATORY NO 34 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR further objects to the undefined term dust as overbroad vague and ambiguous PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Page 62 of 193 Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR further objects that this Interrogatory is confusing as drafted given that it does not refer to any particular product PACCAR further objects that this Interrogatory lacks sufficient specificity regarding the type of asbestos level duration and manner of alleged exposure PACCAR also objects to this Interrogatory as argumentative because it inappropriately assumes that exposures to all asbestos- containing products are equal and hazardous despite the abundance of epidemiological studies which demonstrate that mechanics are not at an increased risk of developing an asbestos disease Accordingly without more specificity regarding the type of product type of asbestos fiber amount of exposure duration of exposure and latency period PACCAR cannot fully answer this Interrogatory In addition PACCAR notes that to the best of its knowledge Plaintiff has not alleged that Decedent was employed by PACCAR worked at a PACCAR facility or was otherwise involved in the assembly of its trucks To the extent this Interrogatory seeks information about PACCAR facilities and employment practices that are not at issue it has no legitimate purpose other than to harass PACCAR and confuse the issues PACCAR also objects to this Request as oppressive and burdensome as it would require PACCAR to undertake a massive and extraordinary document search the results of which would have little to no demonstrable bearing on this litigation in light of the alleged exposure INTERROGATORY NO 35 State whether any written memoranda specification blueprints or other written materials of any kind or character exist relating to any testing of the asbestos products identified in your Answers to Interrogatory Nos 8 and 19. If so identify a Each such written material or document and b The custodian identity and location of each such written material or document Page 63 of 193 RESPONSE TO INTERROGATORY NO 35 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR further objects that this Interrogatory lacks sufficient specificity regarding the type of asbestos level duration and manner of alleged exposure PACCAR also objects to this Interrogatory as argumentative because it inappropriately assumes that exposures to all containing products are equal and hazardous despite the abundance of epidemiological studies which demonstrate that Page 64 of 193 mechanics are not at an increased risk of developing an asbestos disease Accordingly without more specificity regarding the type of product type of asbestos fiber amount of exposure duration of exposure and latency period PACCAR cannot fully answer this Interrogatory PACCAR also objects to the extent that this Interrogatory implies that PACCAR had a duty to conduct or contribute to the conducting of any sampling analyses studies or testing of any product which allegedly contained asbestos and was manufactured by another company PACCAR also objects to this Request as oppressive and burdensome as it would require PACCAR to undertake a massive and extraordinary document search the results of which would have little to no demonstrable bearing on this litigation in light of the alleged exposure INTERROGATORY NO 36 State whether after you released to the public any of the asbestos products identified in your Answers to Interrogatory Nos 8 and 19 you ever conducted or directed any tests thereon to determine potential health hazards involved in the use of the materials contained therein RESPONSE TO INTERROGATORY NO 36 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities Page 65 of 193 other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR further objects that this Interrogatory is confusing as drafted given that it does not refer to any particular product PACCAR further objects that this Interrogatory lacks sufficient specificity regarding the type of asbestos level duration and manner of alleged exposure PACCAR also objects to this Interrogatory as argumentative because it inappropriately assumes that exposures to all asbestoscontaining products are equal and hazardous despite the abundance of epidemiological studies which demonstrate that mechanics are not at an increased risk of developing an asbestos disease Accordingly without more specificity regarding the type of product type of asbestos fiber amount of exposure duration of exposure and latency period PACCAR cannot fully answer this Interrogatory In addition PACCAR notes that to the best of its knowledge Plaintiff has not alleged that Decedent was employed by PACCAR worked at a PACCAR facility or was otherwise involved in the assembly of its trucks To the extent this Interrogatory seeks information about PACCAR facilities and employment practices that are not at issue it has no legitimate purpose other than to harass PACCAR and confuse the issues PACCAR also objects to this Request as oppressive and burdensome as it would require PACCAR to undertake a massive and extraordinary document search the results of which would have little to no demonstrable bearing on this litigation in light of the alleged exposure Page 66 of 193 Subject to and without waiving the foregoing objections PACCAR directs Plaintiff to its Objections and Answer to Interrogatory No. 32 incorporated herein Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 37 State whether prior to 1970 you ever had any labor inspectors or persons from your company go to job sites or other areas where your asbestos products were being used or installed to make a dust level count If so indicate when such a practice or procedure began the purpose of the practice or procedure and what action if any was taken by you in response to the findings made as a result of said practice or procedure RESPONSE TO INTERROGATORY NO 37 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR further objects to the undefined term dust as overbroad vague and ambiguous PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Page 67 of 193 Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR further objects that this Interrogatory lacks sufficient specificity regarding the type of asbestos level duration and manner of alleged exposure PACCAR also objects to this Interrogatory as argumentative because it inappropriately assumes that exposures to all containing products are equal and hazardous despite the abundance of epidemiological studies which demonstrate that mechanics are not at an increased risk of developing an asbestos disease Accordingly without more specificity regarding the type of product type of asbestos fiber amount of exposure duration of exposure and latency period PACCAR cannot fully answer this Interrogatory PACCAR also objects to the extent that this Interrogatory implies that PACCAR had a duty to conduct or contribute to the conducting of any sampling analyses studies or testing of any product which allegedly contained asbestos and was manufactured by another company PACCAR also objects to this Request as oppressive and burdensome as it would require PACCAR to undertake a massive and extraordinary document search the results of which would have little to no demonstrable bearing on this litigation in light of the alleged exposure PACCAR further objects that this Interrogatory is confusing as drafted given that it does not refer to any particular product INTERROGATORY NO 38 State whether you ever conducted or directed any studies designed to learn how to minimize or eliminate the inhalation and ingestion of asbestos dust and fibers by those who use your asbestos products or are exposed to asbestos dust or fibers therefrom RESPONSE TO INTERROGATORY NO 38 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR further objects to the Page 68 of 193 undefined term dust as overbroad vague and ambiguous PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR further objects that this Interrogatory is confusing as drafted given that it does not refer to any particular product PACCAR further objects that this Interrogatory lacks sufficient specificity regarding the type of asbestos level duration and manner of alleged exposure PACCAR also objects to this Interrogatory as argumentative because it inappropriately assumes that exposures to all asbestoscontaining products are equal and hazardous despite the abundance of epidemiological studies which demonstrate that mechanics are not at an increased risk of developing an asbestos Page 69 of 193 disease Accordingly without more specificity regarding the type of product type of asbestos fiber amount of exposure duration of exposure and latency period PACCAR cannot fully answer this Interrogatory In addition PACCAR notes that to the best of its knowledge Plaintiff has not alleged that Decedent was employed by PACCAR worked at a PACCAR facility or was otherwise involved in the assembly of its trucks To the extent this Interrogatory seeks information about PACCAR facilities and employment practices that are not at issue it has no legitimate purpose other than to harass PACCAR and confuse the issues PACCAR also objects to this Request as oppressive and burdensome as it would require PACCAR to undertake a massive and extraordinary document search the results of which would have little to no demonstrable bearing on this litigation in light of the alleged exposure Subject to and without waiving the foregoing objections PACCAR directs Plaintiff to its Objections and Answer to Interrogatory No. 32 incorporated herein Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 39 Identify all trade organizations associations or other entities to which you belong or belonged Said organizations etcetera include at a minimum the following a Asbestos Textile Institute ATI b Industrial Hygiene Foundation and Industrial Health Foundation IHF (c) Mineral Wool Institute (d) Industrial Mineral Insulation Manufacturers Institute (e) Magnesia Silica Insulation Manufacturers Association f National Insulation Manufacturers Association NIMA (g) Thermal Insulation Manufacturers Association TIMA (h) Asbestos Information Association of North America AIA @ Quebec Asbestos Mining Association QAMA ) National Safety Council k Asbestos Cement Products Association ) Refractories Institute Page 70 of 193 RESPONSE TO INTERROGATORY NO 39 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company Subject to and without waiving the foregoing objections to the best of PACCAR's knowledge PACCAR has been a member of the Truck Manufacturers Association TMA and the Engine Manufacturers Association EMA Memberships to both the TMA and EMA would have commenced sometime in the middle 1990s Responding further PACCAR does not maintain information regarding trade associations and other professional organizations to which its employees may have had individual memberships over the years Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 40 For each trade organization association or other entity identified in your Answer to Interrogatory No. 39 state Page 71 of 193 390 Dates of membership 390 Type of membership i.e. regular or associate 390 The dates and type of any meetings you attended and the identity of the individuals who attended such meetings on your behalf d The identity title duties and responsibilities of any individual who held an elected appointed or designated position within said organization et cetera e The names of any publications or written materials distributed by or on behalf of said organization et cetera and f The identity of the present custodian of all written materials notes summaries minutes or transcripts relating to the transactions and proceedings of said organization etc. RESPONSE TO INTERROGATORY NO 40 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company Subject to and without waiver of the foregoing objections PACCAR directs Plaintiff to its Objections and Response to Interrogatory No. 39 incorporated herein by reference Discovery is Page 72 of 193 ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO.41 NO.41 For each trade organization association or other entity identified in your Answer to Interrogatory No. 39 identify all studies tests research recommendations suggestions seminars symposia and speeches conducted or made which concerned discussed addressed or dealt with the actual alleged or possible health hazards associated with exposure to asbestos RESPONSE TO INTERROGATORY NO 41 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a Page 73 of 193 better position to respond regarding their containing products PACCAR further objects that this Interrogatory is confusing as drafted given that it does not refer to any particular product PACCAR further objects that this Interrogatory lacks sufficient specificity regarding the type of asbestos level duration and manner of alleged exposure PACCAR also objects to this Interrogatory as argumentative because it inappropriately assumes that exposures to all asbestoscontaining products are equal and hazardous despite the abundance of epidemiological studies which demonstrate that mechanics are not at an increased risk of developing an asbestos disease Accordingly without more specificity regarding the type of product type of asbestos fiber amount of exposure duration of exposure and latency period PACCAR cannot fully answer this Interrogatory PACCAR also objects to the extent that this Interrogatory implies that PACCAR had a duty to conduct or contribute to the conducting of any sampling analyses studies or testing of any product which allegedly contained asbestos and was manufactured by another company PACCAR also objects to this Request as oppressive and burdensome as it would require PACCAR to undertake a massive and extraordinary document search the results of which would have little to no demonstrable bearing on this litigation in light of the alleged exposure PACCAR objects to this Request as overbroad in that it seeks information from entities other than itself or its predecessors PACCAR further objects that this Interrogatory is confusing as drafted given that it does not refer to any particular product Subject to and without waiver of the foregoing objections PACCAR directs Plaintiff to its Objections and Response to Interrogatory No. 39 incorporated herein by reference Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO.42 NO.42 With respect to each study test research project recommendation suggestion seminar symposium or speech identified in your Answer to Interrogatory No. 41 Page 74 of 193 identify a The individuals or groups involved therein b The date thereof c The complete results thereof d The recommendations if any which were made a as result thereof and e The custodian identity and location of each document which represents refers to or contains information relating thereto RESPONSE TO INTERROGATORY NO 42 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR also objects to the extent that this Interrogatory implies that PACCAR had a duty to conduct or contribute to the conducting of any sampling analyses studies or testing of any product which allegedly contained asbestos and was manufactured by another company PACCAR also objects to this Request as oppressive and burdensome as it would require PACCAR to undertake a massive and extraordinary document search the results of which would have little to no demonstrable bearing on this litigation in light of the alleged exposure PACCAR Page 75 of 193 objects to this Request as overbroad in that it seeks information from entities other than itself or its predecessors PACCAR further objects that this Interrogatory is confusing as drafted given that it does not refer to any particular product Subject to and without waiver of the foregoing objections PACCAR directs Plaintiff to its Objections and Response to Interrogatory No. 39 incorporated herein by reference Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 43 Describe each action taken by you as a result of each study test research project recommendation suggestion seminar symposium and speech identified in your Answer to Interrogatory No. 41. In your Answer to this Interrogatory state the date of each action and the identity of the individual who initiated said action RESPONSE TO INTERROGATORY NO 43 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR also objects to the extent that this Interrogatory implies that Page 76 of 193 PACCAR had a duty to conduct or contribute to the conducting of any sampling analyses studies or testing of any product which allegedly contained asbestos and was manufactured by another company PACCAR also objects to this Request as oppressive and burdensome as it would require PACCAR to undertake a massive and extraordinary document search the results of which would have little to no demonstrable bearing on this litigation in light of the alleged exposure PACCAR further objects that this Interrogatory is confusing as drafted given that it does not refer to any particular product Subject to and without waiver of the foregoing objections PACCAR directs Plaintiff to its Objections and Response to Interrogatory No. 39 incorporated herein by reference Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 44 State whether you directed sponsored financed participated in or received any findings or results of any studies and tests performed by the Saranac Laboratory of the Trudeau Foundation concerning the human health consequences of exposure to asbestos RESPONSE TO INTERROGATORY NO 44 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not Page 77 of 193 involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR also objects to the extent that this Interrogatory implies that PACCAR had a duty to conduct or contribute to the conducting of any sampling analyses studies or testing of any product which allegedly contained asbestos and was manufactured by another company PACCAR also objects to this Request as oppressive and burdensome as it would require PACCAR to undertake a massive and extraordinary document search the results of which would have little to no demonstrable bearing on this litigation in light of the alleged exposure PACCAR further objects that this Interrogatory is confusing as drafted given that it does not refer to any particular product PACCAR further objects that this Interrogatory lacks sufficient specificity regarding the type of asbestos level duration and manner of alleged exposure PACCAR also objects to this Interrogatory as argumentative because it inappropriately assumes that exposures to all containing products are equal and hazardous despite the abundance of epidemiological studies which demonstrate that mechanics are not at an increased risk of developing an asbestos disease Accordingly without more specificity regarding the type of product type of asbestos fiber amount of exposure duration of exposure and latency period PACCAR cannot fully answer this Interrogatory PACCAR further objects that this Interrogatory is confusing as drafted given that it does not refer to any particular product Subject to and without waiver of the foregoing objections PACCAR has not located responsive information Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 45 identify If your Answer to Interrogatory No. 44 is in the affirmative Page 78 of 193 a All documents in your possession or control which summarize or explain the investigations or results of said studies or tests b All communications oral or written between you and Saranac Laboratory personnel including but not limited to Gerrit W. Schepers M.D c All documents relating to Saranac Laboratory studies or tests which were received or submitted by you either directly or indirectly through predecessor in interest subsidiary or affiliate if any through other companies or through any trade associations organizations or entities d All recommendations or findings of such studies in relation to i Adequacy or inadequacy of the threshold limit values ii The substitution of materials for asbestos and e The custodian and location of all documents and communications identified in your Answer to this Interrogatory RESPONSE TO INTERROGATORY NO 45 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR also objects to the extent that this Interrogatory implies that PACCAR had a duty to conduct or contribute to the conducting of any sampling analyses studies or testing of any product which allegedly contained asbestos and was manufactured by another Page 79 of 193 company PACCAR also objects to this Request as oppressive and burdensome as it would require PACCAR to undertake a massive and extraordinary document search the results of which would have little to no demonstrable bearing on this litigation in light of the alleged exposure PACCAR further objects that this Interrogatory is confusing as drafted given that it does not refer to any particular product PACCAR further objects that this Interrogatory lacks sufficient specificity regarding the type of asbestos level duration and manner of alleged exposure PACCAR also objects to this Interrogatory as argumentative because it inappropriately assumes that exposures to all containing products are equal and hazardous despite the abundance of epidemiological studies which demonstrate that mechanics are not at an increased risk of developing an asbestos disease Accordingly without more specificity regarding the type of product type of asbestos fiber amount of exposure duration of exposure and latency period PACCAR cannot fully answer this Interrogatory PACCAR further objects that this Interrogatory is confusing as drafted given that it does not refer to any particular product PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products Subject to and without waiver of the foregoing objections PACCAR directs Plaintiff to its Objections and Response to Interrogatory No. 44 incorporated herein by reference Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained Page 80 of 193 INTERROGATORY NO 46 State the amount of money spent or contributed by you annually from 1930 to the present for research of the relationship between exposure to asbestos dusts fibers and products and any pulmonary pathology and identify each person or organization to whom the expenditure or contribution was made RESPONSE TO INTERROGATORY NO 46 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR further objects to the undefined term dust as overbroad vague and ambiguous PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR also objects to the extent that this Interrogatory implies that PACCAR had a duty to conduct or contribute to the conducting of any sampling analyses studies or testing of any product which allegedly contained asbestos and was manufactured by another company PACCAR also objects to this Request as oppressive and burdensome as it would require PACCAR to undertake a massive and extraordinary document search the results of which would have little to no demonstrable bearing on this litigation in light of the alleged exposure PACCAR further objects that this Interrogatory is confusing as drafted given that it does not refer to any Page 81 of 193 particular product PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR further objects that this Interrogatory lacks sufficient specificity regarding the type of asbestos level duration and manner of alleged exposure PACCAR also objects to this Interrogatory as argumentative because it inappropriately assumes that exposures to all containing products are equal and hazardous despite the abundance of epidemiological studies which demonstrate that mechanics are not at an increased risk of developing an asbestos disease Accordingly without more specificity regarding the type of product type of asbestos fiber amount of exposure duration of exposure and latency period PACCAR cannot fully answer this Interrogatory INTERROGATORY NO 47 State whether you have ever maintained a library or libraries which contains books articles periodicals journals and reference materials that relate to the subjects of asbestos industrial hygiene medicine safety health occupational disease and engineering If so state a The date each such library was established b The location of each such library c The identity of each librarian or other person in charge of the operation and materials of each such library d For whose use each such library was established e The title publisher and dates of subscription to or acquisition of each such periodical or journal for each such library and f The title author publisher date and dates of acquisition of each such article and book for each such library RESPONSE TO INTERROGATORY NO 47 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Page 82 of 193 Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects that this Interrogatory is confusing as drafted given that it does not refer to any particular product PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture asbestos- containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR further objects that this Interrogatory lacks sufficient specificity regarding the type of asbestos level duration and manner of alleged exposure PACCAR also objects to this Interrogatory as argumentative because it inappropriately assumes that exposures to all asbestoscontaining products are equal and hazardous despite the abundance of epidemiological studies which demonstrate that mechanics are not at an increased risk of developing an asbestos disease Accordingly without more specificity regarding the type of product type of asbestos Page 83 of 193 fiber amount of exposure duration of exposure and latency period PACCAR cannot fully answer this Interrogatory In addition PACCAR notes that to the best of its knowledge Plaintiff has not alleged that he was employed by PACCAR worked at a PACCAR facility or was otherwise involved in the assembly of its trucks To the extent this Interrogatory seeks information about PACCAR facilities and employment practices that are not at issue it has no legitimate purpose other than to harass PACCAR and confuse the issues Subject to and without waiver of the foregoing objections PACCAR did not maintain a library whose purpose was to contain books articles periodicals journals and reference materials regarding asbestos PACCAR has maintained a general reference library since 1974 PACCAR also maintained a Technical Center library from 1986 until February 2018. Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO.48 NO.48 State whether any of the defendants in asbestos litigation have ever furnished you with any information as to the state of the medical knowledge at any time regarding the relationship between exposure to asbestos dusts fibers and products and the contracting of diseases including asbestosis pneumoconiosis mesothelioma lung cancer and other cancers RESPONSE TO INTERROGATORY NO 48 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR further objects to the undefined term dust as overbroad vague and ambiguous PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof Page 84 of 193 PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects that this Interrogatory is confusing as drafted given that it does not refer to any particular product PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture asbestos- containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR further objects that this Interrogatory lacks sufficient specificity regarding the type of asbestos level duration and manner of alleged exposure PACCAR also objects to this Interrogatory as argumentative because it inappropriately assumes that exposures to all asbestos- containing products are equal and hazardous despite the abundance of epidemiological studies which demonstrate that mechanics are not at an increased risk of developing an asbestos disease Accordingly without more specificity regarding the type of product type of asbestos fiber amount of exposure duration of exposure and latency period PACCAR cannot fully answer this Interrogatory INTERROGATORY NO 49 identify If your Answer to Interrogatory No. 48 is in the affirmative Page 85 of 193 a How the information was furnished b Who furnished said information c When said information was given to you and d The substance of said information RESPONSE TO INTERROGATORY NO 49 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company INTERROGATORY NO 50 State whether at any time since 1930 you have interchanged exchanged or communicated the results of research tests studies or experiments regarding the relationship between exposure to asbestos dusts fibers and products and the contracting of diseases including asbestosis pneumoconiosis mesothelioma lung cancer and other cancers with any other person corporation or other business entity including defendants in this action RESPONSE TO INTERROGATORY NO 50 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR further objects to the Page 86 of 193 undefined term dust as overbroad vague and ambiguous PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects that this Interrogatory is confusing as drafted given that it does not refer to any particular product PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture asbestos- containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR further objects that this Interrogatory lacks sufficient specificity regarding the type of asbestos level duration and manner of alleged exposure PACCAR also objects to this Interrogatory as argumentative because it inappropriately assumes that exposures to all asbestoscontaining products are equal and hazardous despite the abundance of epidemiological studies which demonstrate that mechanics are not at an increased risk of developing an asbestos Page 87 of 193 disease Accordingly without more specificity regarding the type of product type of asbestos fiber amount of exposure duration of exposure and latency period PACCAR cannot fully answer this Interrogatory PACCAR also objects to the extent that this Interrogatory implies that PACCAR had a duty to conduct or contribute to the conducting of any sampling analyses studies or testing of any product which allegedly contained asbestos and was manufactured by another company PACCAR also objects to the extent this Interrogatory seeks information and documents protected from disclosure by the attorney privilege the work product doctrine or any other applicable protection INTERROGATORY NO 51 state If your Answer to Interrogatory No. 50 is in the affirmative a When said interchanges exchanges or communications occurred b The identity of those persons corporations or business entities who participated in said interchanges exchanges or communications c The content of said interchanges exchanges or communications and d The identity of the custodian of any documents which relate to said interchanges exchanges or communications RESPONSE TO INTERROGATORY NO 51 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not Page 88 of 193 involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects that this Interrogatory is confusing as drafted given that it does not refer to any particular product INTERROGATORY NO 52 Identify all persons who have testified on your behalf before the Occupational Safety and Health Administration the National Institute of Occupational Safety and Health any United States congressional committee committee administrative hearing or investigative proceeding on the subjects of the human health consequences of exposure to asbestos dusts fibers and products and the setting modification feasibility and acceptance of allegedly safe or proper levels of exposure to said asbestos and asbestos products RESPONSE TO INTERROGATORY NO 52 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR further objects to the undefined term dust as overbroad vague and ambiguous PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects that this Interrogatory is confusing as drafted given Page 89 of 193 that it does not refer to any particular product PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture asbestos- containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR further objects that this Interrogatory lacks sufficient specificity regarding the type of asbestos level duration and manner of alleged exposure PACCAR also objects to this Interrogatory as argumentative because it inappropriately assumes that exposures to all asbestoscontaining products are equal and hazardous despite the abundance of epidemiological studies which demonstrate that mechanics are not at an increased risk of developing an asbestos disease Accordingly without more specificity regarding the type of product type of asbestos fiber amount of exposure duration of exposure and latency period PACCAR cannot fully answer this Interrogatory INTERROGATORY NO 53 Identify all documents presented to or utilized in the preparation of testimony before the organizations agencies or committees referred to in Interrogatory No. 52 specifying which documents were presented or utilized for each such body and the present custodian and location of each document RESPONSE TO INTERROGATORY NO 53 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof Page 90 of 193 PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR also objects to the extent this Interrogatory seeks information and documents protected from disclosure by the attorney privilege the work product doctrine or any other applicable protection INTERROGATORY NO 54 Interrogatory No. 52 identify For all testimony or presentations identified in your Answer to a The dates and descriptions of the hearings and proceedings b The relationship between the person who testified or responded and you and c All studies test results scientific and medical documents relied upon by each person as the basis for any recommendation made or testimony given RESPONSE TO INTERROGATORY NO 54 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on Page 91 of 193 the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR also objects to the extent this Interrogatory seeks information and documents protected from disclosure by the attorney privilege the work product doctrine or any other applicable protection INTERROGATORY NO State your knowledge relating to the meaning of threshold limit value as it pertains to asbestos exposure and disease RESPONSE TO INTERROGATORY NO 55 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company Page 92 of 193 Subject to and without waiver of the foregoing objections and as PACCAR understands this Interrogatory PACCAR does not currently know when it first received information about the potential dangers from breathing some forms of asbestos fibers PACCAR generally received information as early as 1973 on regulations promulgated by federal OSHA on topics of workplace safety Responding further in 1976 certain PACCAR employees attended a seminar on workplace health and safety This seminar consisted of over a dozen presentations including one regarding industrial hygiene That industrial hygiene presentation included a limited discussion on the development of OSHA regulations pertaining to permissible exposure limits To demonstrate how some of those standards were developed the presenter discussed certain epidemiological studies on asbestos disease among insulation workers Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 56 With reference to threshold limit value which for purposes of this interrogatory means how much asbestos dust and fibers one can safely inhale absorb or ingest without risk of disease or illness state a When and by what means you first obtained information related thereto b The substance of any information imparted to you regarding the same and c Whether and by what means you advised or warned anyone of details relating thereto RESPONSE TO INTERROGATORY NO 56 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR further objects to the undefined term dust as overbroad vague and ambiguous PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof Page 93 of 193 PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects on the basis that as a corporation it is extremely difficult to pinpoint a date when a corporate entity first obtained information about something PACCAR further objects that this Interrogatory lacks sufficient specificity regarding the type of asbestos level duration and manner of alleged exposure PACCAR also objects to this Interrogatory as argumentative because it inappropriately assumes that exposures to all asbestoscontaining products are equal and hazardous despite the abundance of epidemiological studies which demonstrate that mechanics are not at an increased risk of developing an asbestos disease Accordingly without more specificity regarding the type of product type of asbestos fiber amount of exposure duration of exposure and latency period PACCAR cannot fully answer this Interrogatory PACCAR further objects to the definition of the phrase threshold limit value as overbroad vague and ambiguous PACCAR also objects to the extent this Interrogatory seeks information and documents protected from disclosure by the attorney privilege the work product doctrine or any other applicable protection Subject to and without waiver of the foregoing objections PACCAR does not currently know when it first received information about the potential dangers from breathing some forms of asbestos fibers PACCAR generally received information as early as 1973 on regulations Page 94 of 193 promulgated by federal OSHA on topics of workplace safety Responding further in 1976 certain PACCAR employees attended a seminar on workplace health and safety This seminar consisted of over a dozen presentations including one regarding industrial hygiene That industrial hygiene presentation included a limited discussion on the development of OSHA regulations pertaining to permissible exposure limits To demonstrate how some of those standards were developed the presenter discussed certain epidemiological studies on asbestos disease among insulation workers Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 57 State whether you ever knew that any governmental private agency and other entity issued guidelines suggesting a threshold limit value as defined in Interrogatory No. 56 for exposure to asbestos dust and fibers If so state a The identity of the agency or other entity which issued said guidelines b The verbatim content of said guidelines (c) The date said guidelines were issued (d) The date you were first aware of the purpose of said guidelines and e The custodian location and identity of all documents related thereto RESPONSE TO INTERROGATORY NO 57 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR further objects to the undefined term dust as overbroad vague and ambiguous PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on Page 95 of 193 the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects on the basis that as a corporation it is extremely difficult to pinpoint a date when a corporate entity was first aware of something PACCAR further objects that this Interrogatory lacks sufficient specificity regarding the type of asbestos level duration and manner of alleged exposure PACCAR also objects to this Interrogatory as argumentative because it inappropriately assumes that exposures to all containing products are equal and hazardous despite the abundance of epidemiological studies which demonstrate that mechanics are not at an increased risk of developing an asbestos disease Accordingly without more specificity regarding the type of product type of asbestos fiber amount of exposure duration of exposure and latency period PACCAR cannot fully answer this Interrogatory PACCAR further objects to the definition of the phrase threshold limit value as overbroad vague and ambiguous PACCAR objects to the extent this Interrogatory requests information already in Plaintiff's counsel's possession and equally available to Plaintiff as a matter of public record Subject to and without waiver of the foregoing objections PACCAR directs Plaintiff to its Objections and Answer to Interrogatory No. 56 incorporated herein Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 58 State whether you ever possessed knowledge of documents indicating that existing or proposed threshold limit values as defined in Interrogatory No. 56 were not safe or proper or that lower threshold limit values were necessary in order to prevent diseases caused by exposure to asbestos If so identify Page 96 of 193 a The source of such knowledge b The persons who obtained such knowledge and when c All documents relating thereto and d The custodian and location of all documents identified in your Answer to Part c of this Interrogatory RESPONSE TO INTERROGATORY NO 58 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects that this Interrogatory lacks sufficient specificity regarding the type of asbestos level duration and manner of alleged exposure PACCAR also objects to this Interrogatory as argumentative because it inappropriately assumes that exposures to all containing products are equal and hazardous despite the abundance of epidemiological studies which demonstrate that mechanics are not at an increased risk of developing an asbestos disease Accordingly without more specificity regarding the type of product type of asbestos fiber amount of exposure duration of exposure and latency period Page 97 of 193 PACCAR cannot fully answer this Interrogatory PACCAR further objects to the definition of the phrase threshold limit value as overbroad vague and ambiguous PACCAR also objects to the extent this Interrogatory seeks information and documents protected from disclosure by the attorney privilege the work product doctrine or any other applicable protection Subject to and without waiver of the foregoing objections PACCAR directs Plaintiff to its Objections and Answer to Interrogatory No. 56 incorporated herein Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 59 State whether you were ever made aware that the proper method for determining safe levels of asbestos dust was to test concentrations of asbestos fibers in the air rather than the total number of asbestos particles in the air If so state a The source of such knowledge b The persons who obtained such knowledge (c) All documents relating thereto and d The custodian and location of all documents identified in your Answer to Part c of this Interrogatory RESPONSE TO INTERROGATORY NO 59 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not Page 98 of 193 involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects that this Interrogatory lacks sufficient specificity regarding the type of asbestos level duration and manner of alleged exposure PACCAR also objects to this Interrogatory as argumentative because it inappropriately assumes that exposures to all containing products are equal and hazardous despite the abundance of epidemiological studies which demonstrate that mechanics are not at an increased risk of developing an asbestos disease Accordingly without more specificity regarding the type of product type of asbestos fiber amount of exposure duration of exposure and latency period PACCAR cannot fully answer this Interrogatory PACCAR further objects to the definition of the phrase threshold limit value as overbroad vague and ambiguous PACCAR also objects to the extent this Interrogatory seeks information and documents protected from disclosure by the attorney privilege the work product doctrine or any other applicable protection Subject to and without waiver of the foregoing objections PACCAR directs Plaintiff to its Objections and Answer to Interrogatory No. 56 incorporated herein Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 60 State in detail what tests or studies if any you ever conducted or directed with regard to the quantity quality or threshold limit values as defined in Interrogatory No. 56 of asbestos dust fibers or particles to which insulators shipyard workers or others who use your asbestos products and other working the same vicinity are exposed RESPONSE TO INTERROGATORY NO 60 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR further objects to the Page 99 of 193 undefined term dust as overbroad vague and ambiguous PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects that this Interrogatory lacks sufficient specificity regarding the type of asbestos level duration and manner of alleged exposure PACCAR also objects to this Interrogatory as argumentative because it inappropriately assumes that exposures to all containing products are equal and hazardous despite the abundance of epidemiological studies which demonstrate that mechanics are not at an increased risk of developing an asbestos disease Accordingly without more specificity regarding the type of product type of asbestos fiber amount of exposure duration of exposure and latency period PACCAR cannot fully answer this Interrogatory PACCAR further objects to the definition of the phrase threshold limit value as overbroad vague and ambiguous PACCAR further objects that this Interrogatory is confusing as drafted given that it does not refer to any particular product PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did Page 100 of 193 not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR also objects to the extent that this Interrogatory implies that PACCAR had a duty to conduct or contribute to the conducting of any sampling analyses studies or testing of any product which allegedly contained asbestos and was manufactured by another company Subject to and without waiver of the foregoing objections PACCAR states this Interrogatory is inapplicable to PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company as such PACCAR objects Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 61 State in detail what research tests or studies if any you ever conducted or directed to determine whether the exposure of insulation workers or others to asbestos dust exceeded the American Conference of Governmental Industrial Hygienists A.C.G.I.H. recommended threshold limit values RESPONSE TO INTERROGATORY NO 61 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR further objects to the undefined term dust as overbroad vague and ambiguous PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not Page 101 of 193 reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects that this Interrogatory lacks sufficient specificity regarding the type of asbestos level duration and manner of alleged exposure PACCAR also objects to this Interrogatory as argumentative because it inappropriately assumes that exposures to all containing products are equal and hazardous despite the abundance of epidemiological studies which demonstrate that mechanics are not at an increased risk of developing an asbestos disease Accordingly without more specificity regarding the type of product type of asbestos fiber amount of exposure duration of exposure and latency period PACCAR cannot fully answer this Interrogatory PACCAR further objects that this Interrogatory is confusing as drafted given that it does not refer to any particular product PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR also objects to the extent that this Interrogatory implies that PACCAR had a duty to conduct or contribute to the conducting of any sampling analyses studies or testing of any product which allegedly contained asbestos and was manufactured by another company Page 102 of 193 Subject to and without waiver of the foregoing objections PACCAR states this Interrogatory is inapplicable to PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company as such PACCAR objects To the extent responsive PACCAR responds that it was not a member of the ACGIH and therefore does not have any documents or information responsive to this Interrogatory Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 62 State in detail what steps if any you ever took to determine whether the American Conference of Governmental Industrial Hygienists A.C.G.I.H. recommended threshold limit values for exposure to asbestos dust were accurate or reliable RESPONSE TO INTERROGATORY NO 62 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR further objects to the undefined term dust as overbroad vague and ambiguous PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Page 103 of 193 Motors Company PACCAR further objects that this Interrogatory lacks sufficient specificity regarding the type of asbestos level duration and manner of alleged exposure PACCAR also objects to this Interrogatory as argumentative because it inappropriately assumes that exposures to all containing products are equal and hazardous despite the abundance of epidemiological studies which demonstrate that mechanics are not at an increased risk of developing an asbestos disease Accordingly without more specificity regarding the type of product type of asbestos fiber amount of exposure duration of exposure and latency period PACCAR cannot fully answer this Interrogatory PACCAR further objects that this Interrogatory is confusing as drafted given that it does not refer to any particular product PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR also objects to the extent that this Interrogatory implies that PACCAR had a duty to conduct or contribute to the conducting of any sampling analyses studies or testing of any product which allegedly contained asbestos and was manufactured by another company Subject to and without waiving the foregoing objections PACCAR responds that it was not a member of the ACGIH and therefore does not have any documents or information responsive to this Interrogatory Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 63 State your knowledge relating to the meaning of dose response relationship as it pertains to exposure to asbestos dusts fibers and products and the contracting Page 104 of 193 of disease including asbestosis pneumoconiosis mesothelioma lung cancer and other cancers RESPONSE TO INTERROGATORY NO 63 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR further objects to the undefined term dust as overbroad vague and ambiguous PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects that this Interrogatory lacks sufficient specificity regarding the type of asbestos level duration and manner of alleged exposure PACCAR also objects to this Interrogatory as argumentative because it inappropriately assumes that exposures to all containing products are equal and hazardous despite the abundance of epidemiological studies which demonstrate that mechanics are not at an increased risk of developing an asbestos disease Accordingly without more specificity regarding the type of product type of asbestos fiber amount of exposure duration of exposure and latency period PACCAR cannot fully answer this Interrogatory PACCAR further objects that this Interrogatory Page 105 of 193 is confusing as drafted given that it does not refer to any particular product PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR also objects to the extent that this Interrogatory implies that PACCAR had a duty to conduct or contribute to the conducting of any sampling analyses studies or testing of any product which allegedly contained asbestos and was manufactured by another company PACCAR further objects to the undefined phrase dose response relationship as overbroad vague and ambiguous INTERROGATORY NO 64 State whether you have ever placed any warranties guarantees or other such representations on any asbestos products identified in your Answers to Interrogatory Nos 8 and 19 and on or in the containers or packages in which said products were sold distributed or otherwise placed in the stream of commerce RESPONSE TO INTERROGATORY NO 64 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not Page 106 of 193 involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects on the basis that its Kenworth and Peterbilt divisions have assembled hundreds of thousands of trucks during their histories that those trucks were custom at the direction request and specification of the purchaser that certain information regarding those trucks is maintained by Vehicle Identification Number that Plaintiff has not identified the Vehicle Identification Number of any Kenworth or Peterbilt truck and therefore the location and identification of information responsive to this Interrogatory is unduly burdensome and oppressive and obtainable through less expensive and burdensome means INTERROGATORY NO 65 If your Answer to Interrogatory No. 64 is in the affirmative for each such product and container or package identify a The inclusive dates on which each such warranty guarantee or other representation appeared on or with the product and on or in the container or package b A verbatim description of each such warranty guarantee or other representation c A description of the location on the product and container where each such warranty guarantee or other representation was placed d Each of your present or former highest supervisory employees with knowledge of the decision to place any such warranties guarantees or other representations on or with the product and on or in the container or package and e The custodian of all documents in your custody possession or control which relate to or describe any such warranties guarantees or other representations or the decision to place any of these on or with the product and on or in the container or package RESPONSE TO INTERROGATORY NO 65 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered Page 107 of 193 by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects on the basis that its Kenworth and Peterbilt divisions have assembled hundreds of thousands of trucks during their histories that those trucks were custom at the direction request and specification of the purchaser that certain information regarding those trucks is maintained by Vehicle Identification Number that Plaintiff has not identified the Vehicle Identification Number of any Kenworth or Peterbilt truck and therefore the location and identification of information responsive to this Interrogatory is unduly burdensome and oppressive and obtainable through less expensive and burdensome means INTERROGATORY NO 66 State whether the content and placement of any warranty guarantee or other representation described in your Answer to Interrogatory Nos 64 and 65 was ever changed If so for each such change identify a The nature of the change including a verbatim description if applicable b The date when the change was made and the inclusive dates during which such change appeared on or with the product and on or in the container or package c The persons with personal knowledge of the reasons for making the change and d The custodian of documents in your custody possession or control which relate to the decision and process of making the change RESPONSE TO INTERROGATORY NO 66 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague Page 108 of 193 ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects on the basis that its Kenworth and Peterbilt divisions have assembled hundreds of thousands of trucks during their histories that those trucks were custom at the direction request and specification of the purchaser that certain information regarding those trucks is maintained by Vehicle Identification Number that Plaintiff has not identified the Vehicle Identification Number of any Kenworth or Peterbilt truck and therefore the location and identification of information responsive to this Interrogatory is unduly burdensome and oppressive and obtainable through less expensive and burdensome means INTERROGATORY NO 67 State when and by what means you became aware of the alleged hazards of exposure to asbestos dusts fibers and products to the health of persons coming into contact with handling or using asbestos products RESPONSE TO INTERROGATORY NO 67 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR further objects to the Page 109 of 193 undefined term dust as overbroad vague and ambiguous PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects that this Interrogatory lacks sufficient specificity regarding the type of asbestos level duration and manner of alleged exposure PACCAR further objects that this Interrogatory is confusing as drafted given that it does not refer to any particular product PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR also objects to this Interrogatory as argumentative because it inappropriately assumes that exposures to all asbestoscontaining products are equal and hazardous despite the abundance of epidemiological studies which demonstrate that mechanics are not at an increased risk of developing an asbestos Page 110 of 193 disease Accordingly without more specificity regarding the type of product type of asbestos fiber amount of exposure duration of exposure and latency period PACCAR cannot fully answer this Interrogatory PACCAR further objects on the basis that as a corporation it is extremely difficult to pinpoint a date when a corporate entity first became aware about something Subject to and without waiver of the foregoing objections PACCAR does not currently know when it first received information about the potential dangers from breathing some forms of asbestos fibers PACCAR generally received information as early as 1973 on regulations promulgated by federal OSHA on topics of workplace safety Responding further in 1976 certain PACCAR employees attended a seminar on workplace health and safety This seminar consisted of over a dozen presentations including one regarding industrial hygiene That industrial hygiene presentation included a limited discussion on the development of OSHA regulations pertaining to permissible exposure limits To demonstrate how some of those standards were developed the presenter discussed certain epidemiological studies on asbestos disease among insulation workers Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 68 State when and by what means you became aware that exposure to asbestos dusts fibers and products was acknowledged to be or alleged to be hazardous to the health of persons coming in contact with handling or using asbestos products RESPONSE TO INTERROGATORY NO 68 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR further objects to the undefined term dust as overbroad vague and ambiguous PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered Page 111 of 193 by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects that this Interrogatory lacks sufficient specificity regarding the type of asbestos level duration and manner of alleged exposure PACCAR further objects that this Interrogatory is confusing as drafted given that it does not refer to any particular product PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR also objects to this Interrogatory as argumentative because it inappropriately assumes that exposures to all asbestoscontaining products are equal and hazardous despite the abundance of epidemiological studies which demonstrate that mechanics are not at an increased risk of developing an asbestos disease Accordingly without more specificity regarding the type of product type of asbestos fiber amount of exposure duration of exposure and latency period PACCAR cannot fully answer Page 112 of 193 this Interrogatory PACCAR further objects on the basis that as a corporation it is extremely difficult to pinpoint a date when a corporate entity first became aware about something PACCAR objects that this Interrogatory assumes facts not in evidence Subject to and without waiver of the foregoing objections PACCAR does not currently know when it first received information about the potential dangers from breathing some forms of asbestos fibers PACCAR generally received information as early as 1973 on regulations promulgated by federal OSHA on topics of workplace safety Responding further in 1976 certain PACCAR employees attended a seminar on workplace health and safety This seminar consisted of over a dozen presentations including one regarding industrial hygiene That industrial hygiene presentation included a limited discussion on the development of OSHA regulations pertaining to permissible exposure limits To demonstrate how some of those standards were developed the presenter discussed certain epidemiological studies on asbestos disease among insulation workers Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 69 State whether you ever learned that there is or may be a causal connection between exposure to asbestos dust and a Asbestosis b Pneumoconiosis c Lung Cancer d Mesothelioma and e Other cancers RESPONSE TO INTERROGATORY NO 69 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR further objects to the undefined term dust as overbroad vague and ambiguous PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered Page 113 of 193 by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects that this Interrogatory lacks sufficient specificity regarding the type of asbestos level duration and manner of alleged exposure PACCAR further objects that this Interrogatory is confusing as drafted given that it does not refer to any particular product PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR also objects to this Interrogatory as argumentative because it inappropriately assumes that exposures to all asbestoscontaining products are equal and hazardous despite the abundance of epidemiological studies which demonstrate that mechanics are not at an increased risk of developing an asbestos disease Accordingly without more specificity regarding the type of product type of asbestos fiber amount of exposure duration of exposure and latency period PACCAR cannot fully answer Page 114 of 193 this Interrogatory PACCAR further objects on the basis that as a corporation it is extremely difficult to pinpoint a date when a corporate entity first became aware about something PACCAR further objects that this Interrogatory assumes facts not in evidence and calls for speculation PACCAR objects to the extent that this Interrogatory calls for a medical and expert opinion Subject to and without waiver of the foregoing objections PACCAR does not currently know when it first received information about the potential dangers from breathing some forms of asbestos fibers PACCAR generally received information as early as 1973 on regulations promulgated by federal OSHA on topics of workplace safety Responding further in 1976 certain PACCAR employees attended a seminar on workplace health and safety This seminar consisted of over a dozen presentations including one regarding industrial hygiene That industrial hygiene presentation included a limited discussion on the development of OSHA regulations pertaining to permissible exposure limits To demonstrate how some of those standards were developed the presenter discussed certain epidemiological studies on asbestos disease among insulation workers Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 70 If your Answer to Interrogatory No. 69 is in the affirmative identify the following as to each such disease listed therein a When and by what means you first became aware of such causal connection b If your awareness of such causal connection was obtained at any conference lecture convention symposium or other such meeting identify the event its date the person who attended on your behalf and any documents obtained from such event and c If your awareness of such causal connection was obtained from a medical or scientific study or from any other published works identify the same RESPONSE TO INTERROGATORY NO 70 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague Page 115 of 193 ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects that this Interrogatory is confusing as drafted given that it does not refer to any particular product PACCAR further objects on the basis that as a corporation it is extremely difficult to pinpoint a date when a corporate entity first became aware about something PACCAR further objects that this Interrogatory assumes facts not in evidence and calls for speculation PACCAR objects to the extent that this Interrogatory calls for a medical and expert opinion Subject to and without waiver of the foregoing objections PACCAR directs Plaintiff to its objections and response to Interrogatory No. 69 above which are incorporated herein by reference Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 71 State whether you ever specifically informed the purchasers and users of the asbestos products identified in your Answer to Interrogatory Nos 8 and 19 that exposure to asbestos dust could cause asbestosis pneumoconiosis lung cancer mesothelioma and other cancers If so state Page 116 of 193 390 The date of such notice to purchasers or users 390 The means used for transmittal of such notice 390 The custodian identity and location of each document which refers to or contains information relevant to such notice and d The identity of each person who made decisions regarding the furnishing of such notice to purchasers and users RESPONSE TO INTERROGATORY NO 71 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR further objects to the undefined term dust as overbroad vague and ambiguous PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects that this Interrogatory lacks sufficient specificity regarding the type of asbestos level duration and manner of alleged exposure PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty Page 117 of 193 trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR also objects to this Interrogatory as argumentative because it inappropriately assumes that exposures to all containing products are equal and hazardous despite the abundance of epidemiological studies which demonstrate that mechanics are not at an increased risk of developing an asbestos disease Accordingly without more specificity regarding the type of product type of asbestos fiber amount of exposure duration of exposure and latency period PACCAR cannot fully answer this Interrogatory PACCAR further objects on the basis that its Kenworth and Peterbilt divisions have assembled hundreds of thousands of trucks during their histories that those trucks were custom at the direction request and specification of the purchaser that certain information regarding those trucks is maintained by Vehicle Identification Number that Plaintiff has not identified the Vehicle Identification Number of any Kenworth or Peterbilt truck and therefore the location and identification of information responsive to this Interrogatory is unduly burdensome and oppressive and obtainable through less expensive and burdensome means PACCAR further objects that this Interrogatory assumes facts not in evidence and calls for speculation PACCAR objects to the extent that this Interrogatory calls for a medical and expert opinion Subject to and without waiver of the foregoing objections PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks These vehicles included among other components axles transmissions and engines that were manufactured by various component suppliers PACCAR is informed and believes that some of these assembled component parts did at Page 118 of 193 various points in time incorporate brakes clutches and gaskets that contained some form of encapsulated chrysotile These products were at all times manufactured by and obtained from various component part suppliers that are unrelated to PACCAR PACCAR did not specify the use of asbestos in these brakes clutches and engine gaskets and did not know the exact formulation or exact chemical composition of the components manufactured by unrelated entities When those products contained asbestos at some point in time it was because the component manufacturers independently determined that asbestos was a necessary part of the formulation to achieve mandated performance specifications Those other entities would be considered the manufacturers and distributors of containing automotive friction products As such this Interrogatory should be directed to those entities Kenworth and Peterbilt provided service literature authored by component suppliers to dealers and customers Specifically Kenworth and Peterbilt provided their dealers with master shop manuals that were comprised of a series of three binders which included component supplier service manuals Kenworth and Peterbilt also made these master shop manuals available to users for purchase Customers could also purchase custom maintenance manuals that include only specific information for their specific truck Additionally Kenworth and Peterbilt provided individual component supplier manuals inside the glove compartments or sleeper compartments of their trucks These manuals would correspond to the particular components specified by the user for a given truck Upon information and belief some of these component service manuals would have contained asbestos warnings starting in the 1970s Responsibility of the content of those manuals would lie with the respective component part supplier Discovery is Page 119 of 193 ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 72 State whether you ever specifically informed the distributors identified in your Answer to Interrogatory No. 20 and those identified in your Answer to Interrogatory No. 21 who resold or redistributed your asbestos products that exposure to asbestos dust could cause asbestosis pneumoconiosis lung cancer mesothelioma and other cancers If So state a The date of such notice b The means used for transmittal of such notice c The custodian identity and location of each document which refers to or contains information relevant to such notice and d The identity of each person who made decisions regarding the furnishing of such notice to distributors and those engaged in the resale or redistribution of the asbestos products RESPONSE TO INTERROGATORY NO 72 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR further objects to the undefined term dust as overbroad vague and ambiguous PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Page 120 of 193 Motors Company PACCAR further objects that this Interrogatory lacks sufficient specificity regarding the type of asbestos level duration and manner of alleged exposure PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR also objects to this Interrogatory as argumentative because it inappropriately assumes that exposures to all containing products are equal and hazardous despite the abundance of epidemiological studies which demonstrate that mechanics are not at an increased risk of developing an asbestos disease Accordingly without more specificity regarding the type of product type of asbestos fiber amount of exposure duration of exposure and latency period PACCAR cannot fully answer this Interrogatory PACCAR further objects on the basis that its Kenworth and Peterbilt divisions have assembled hundreds of thousands of trucks during their histories that those trucks were custom at the direction request and specification of the purchaser that certain information regarding those trucks is maintained by Vehicle Identification Number that Plaintiff has not identified the Vehicle Identification Number of any Kenworth or Peterbilt truck and therefore the location and identification of information responsive to this Interrogatory is unduly burdensome and oppressive and obtainable through less expensive and burdensome means PACCAR further objects that this Interrogatory assumes facts not in evidence and calls for speculation PACCAR objects to the extent that this Interrogatory calls for a medical and expert opinion Page 121 of 193 Subject to and without waiver of the foregoing objections PACCAR directs Plaintiff to its Objections and Answer to Interrogatory No. 71 incorporated herein Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 73 State whether you ever provided any caution notice warning or other statement or explanation of the potential health hazards of exposure to asbestos on or with the asbestos products identified in your Answers to Interrogatories Nos 8 and 19 RESPONSE TO INTERROGATORY NO 73 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects that this Interrogatory lacks sufficient specificity regarding the type of asbestos level duration and manner of alleged exposure PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw Page 122 of 193 asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR also objects to this Interrogatory as argumentative because it inappropriately assumes that exposures to all containing products are equal and hazardous despite the abundance of epidemiological studies which demonstrate that mechanics are not at an increased risk of developing an asbestos disease Accordingly without more specificity regarding the type of product type of asbestos fiber amount of exposure duration of exposure and latency period PACCAR cannot fully answer this Interrogatory PACCAR further objects on the basis that its Kenworth and Peterbilt divisions have assembled hundreds of thousands of trucks during their histories that those trucks were custom at the direction request and specification of the purchaser that certain information regarding those trucks is maintained by Vehicle Identification Number that Plaintiff has not identified the Vehicle Identification Number of any Kenworth or Peterbilt truck and therefore the location and identification of information responsive to this Interrogatory is unduly burdensome and oppressive and obtainable through less expensive and burdensome means PACCAR further objects that this Interrogatory assumes facts not in evidence and calls for speculation PACCAR objects to the extent that this Interrogatory calls for a medical and expert opinion Subject to and without waiver of the foregoing objections PACCAR directs Plaintiff to its Objections and Answer to Interrogatory No. 71 incorporated herein Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 74 If your Answer to Interrogatory No. 73 is in the affirmative state as to each product identified in your Answers to Interrogatory Nos 8 and 19 Page 123 of 193 a The date on which such caution notice warning or other statement or explanation first appeared b The identity of each person with knowledge of decisions made regarding the use of such caution notice warning or other statement of explanation c The verbatim content of each caution notice warning or other statement or explanation when it was first used d Whether the caution notice warning or other statement or explanation was ever altered amended or changed If so how when and why was it altered amended or changed and e The location of the caution notice warning or other statement or explanation on each such product and its container or package RESPONSE TO INTERROGATORY NO 74 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence.PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects that this Interrogatory lacks sufficient specificity regarding the type of asbestos level duration and manner of alleged exposure PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw Page 124 of 193 asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR also objects to this Interrogatory as argumentative because it inappropriately assumes that exposures to all containing products are equal and hazardous despite the abundance of epidemiological studies which demonstrate that mechanics are not at an increased risk of developing an asbestos disease Accordingly without more specificity regarding the type of product type of asbestos fiber amount of exposure duration of exposure and latency period PACCAR cannot fully answer this Interrogatory PACCAR further objects on the basis that its Kenworth and Peterbilt divisions have assembled hundreds of thousands of trucks during their histories that those trucks were custom at the direction request and specification of the purchaser that certain information regarding those trucks is maintained by Vehicle Identification Number that Plaintiff has not identified the Vehicle Identification Number of any Kenworth or Peterbilt truck and therefore the location and identification of information responsive to this Interrogatory is unduly burdensome and oppressive and obtainable through less expensive and burdensome means Subject to and without waiver of the foregoing objections PACCAR directs Plaintiff to its Objections and Answer to Interrogatory No. 71 incorporated herein Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 75 State when you first became aware that asbestos products were being labeled with a caution warning notice or other statement or explanation concerning the potential health hazards resulting from the use of asbestos products and exposure to asbestos dust or fibers and identify the product and manufacturer with which such label was connected Page 125 of 193 RESPONSE TO INTERROGATORY NO 75 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR further objects to the undefined term dust as overbroad vague and ambiguous PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects that this Interrogatory lacks sufficient specificity regarding the type of asbestos level duration and manner of alleged exposure PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR also objects to this Interrogatory as argumentative because it inappropriately assumes that exposures to all containing products are equal Page 126 of 193 and hazardous despite the abundance of epidemiological studies which demonstrate that mechanics are not at an increased risk of developing an asbestos disease Accordingly without more specificity regarding the type of product type of asbestos fiber amount of exposure duration of exposure and latency period PACCAR cannot fully answer this Interrogatory PACCAR further objects on the basis that its Kenworth and Peterbilt divisions have assembled hundreds of thousands of trucks during their histories that those trucks were custom at the direction request and specification of the purchaser that certain information regarding those trucks is maintained by Vehicle Identification Number that Plaintiff has not identified the Vehicle Identification Number of any Kenworth or Peterbilt truck and therefore the location and identification of information responsive to this Interrogatory is unduly burdensome and oppressive and obtainable through less expensive and burdensome means PACCAR further objects on the basis that as a corporation it is extremely difficult to pinpoint a date when a corporate entity first became aware about something PACCAR further objects that this Interrogatory is confusing as drafted given that it does not refer to any particular product INTERROGATORY NO 76 Identify the officer agent servant employee or other representative of yours who first obtained an awareness that asbestos products were being labeled as described in Interrogatory No. 75 RESPONSE TO INTERROGATORY NO 76 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof Page 127 of 193 PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR further objects on the basis that as a corporation it is extremely difficult to pinpoint a date when a corporate entity or one of its employees first became aware about something PACCAR further objects that this Interrogatory is confusing as drafted given that it does not refer to any particular product INTERROGATORY NO 77 Identify the custodian identity and location of all documents related to the knowledge obtained by you regarding the labeling of asbestos products as described in Interrogatory No. 75 RESPONSE TO INTERROGATORY NO 77 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered Page 128 of 193 by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR further objects on the basis that its Kenworth and Peterbilt divisions have assembled hundreds of thousands of trucks during their histories that those trucks were custom at the direction request and specification of the purchaser that certain information regarding those trucks is maintained by Vehicle Identification Number that Plaintiff has not identified the Vehicle Identification Number of any Kenworth or Peterbilt truck and therefore the location and identification of information responsive to this Interrogatory is unduly burdensome and oppressive and obtainable through less expensive and burdensome means INTERROGATORY NO 78 State when and by what means you first became aware that JohnsManville Corporation or any of its affiliated companies placed on its asbestos products a caution Page 129 of 193 warning notice other statement or representation concerning the potential health hazards resulting from the use of asbestos products and exposure to asbestos dust or fibers RESPONSE TO INTERROGATORY NO 78 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR further objects to the undefined term dust as overbroad vague and ambiguous PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR further objects on the basis that as a corporation it is extremely difficult to pinpoint a date when a corporate Page 130 of 193 entity first became aware about something PACCAR further objects that this Interrogatory is confusing as drafted given that it does not refer to any particular product INTERROGATORY NO 79 Identify the officer agent servant employee or other representative of yours who first became aware that asbestos products of Manville Corporation or its affiliated companies were being labeled as described in Interrogatory No. 78 RESPONSE TO INTERROGATORY NO 79 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR further objects Page 131 of 193 on the basis that as a corporation it is extremely difficult to pinpoint a date when a corporate entity or one of its employes first became aware about something PACCAR further objects that this Interrogatory is confusing as drafted given that it does not refer to any particular product INTERROGATORY NO 80 Identify the custodian identity and location of all documents related to the knowledge obtained by you regarding the labeling of asbestos products by JohnsManville Corporation or its affiliated companies as described in Interrogatory No. 78 RESPONSE TO INTERROGATORY NO 80 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a Page 132 of 193 better position to respond regarding their containing products PACCAR further objects that this Interrogatory is confusing as drafted given that it does not refer to any particular product INTERROGATORY NO 81 If upon learning that Manville Corporation or its affiliated companies labeled its asbestos products as described in Interrogatory No. 78 you did not apply such labels to the products identified in your Answer to Interrogatory Nos 8 and 19 state a The reason for such a decision b The identity of any agent servant employee officer or representative of yours involved in discussions and decisions regarding the same and c The custodian identity and location of all documents pertaining to such a decision RESPONSE TO INTERROGATORY NO 81 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to Page 133 of 193 PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR further objects that this Interrogatory is confusing as drafted given that it does not refer to any particular product PACCAR further objects that this Interrogatory assumes facts not in evidence INTERROGATORY NO 82 State whether you specifically informed your employees agents and servants that use of asbestos products and exposure to asbestos dust or fibers was either actually or alleged to be hazardous to their health RESPONSE TO INTERROGATORY NO 82 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR further objects to the undefined term dust as overbroad vague and ambiguous PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects that this Interrogatory lacks sufficient specificity regarding the type of asbestos level duration and manner of alleged exposure PACCAR further objects that this Interrogatory is confusing as drafted given that it does not refer to any particular Page 134 of 193 product PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products In addition PACCAR notes that to the best of its knowledge Plaintiff has not alleged that Decedent was employed by PACCAR worked at a PACCAR facility or was otherwise involved in the assembly of its trucks To the extent this Interrogatory seeks information about PACCAR facilities and employment practices that are not at issue it has no legitimate purpose other than to harass PACCAR and confuse the issues PACCAR also objects to this Interrogatory as argumentative because it inappropriately assumes that exposures to all containing products are equal and hazardous despite the abundance of epidemiological studies which demonstrate that mechanics are not at an increased risk of developing an asbestos disease Accordingly without more specificity regarding the type of product type of asbestos fiber amount of exposure duration of exposure and latency period PACCAR cannot fully answer this Interrogatory INTERROGATORY NO.83 NO.83 If your Answer to Interrogatory No. 82 is in the affirmative state 39 When and in what manner you first provided such information to these persons 39 The identity of any agent servant employee officer or representative of yours involved in discussions and decisions regarding providing information to these persons c The verbatim content of any written documents and communications containing such information and d The custodian identity and location of all documents which relate or pertain to providing such information to these persons RESPONSE TO INTERROGATORY NO 83 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague Page 135 of 193 ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company In addition PACCAR notes that to the best of its knowledge Plaintiff has not alleged that Decedent was employed by PACCAR worked at a PACCAR facility or was otherwise involved in the assembly of its trucks To the extent this Interrogatory seeks information about PACCAR facilities and employment practices that are not at issue it has no legitimate purpose other than to harass PACCAR and confuse the issues INTERROGATORY NO 84 Describe in detail any precautionary procedures which you urged or required your employees agents servants and contract unites to follow so as to reduce and avoid the potential hazards or dangers associated with use of asbestos products and exposure to asbestos dust or fibers and state when and how each such procedure was introduced to these individuals RESPONSE TO INTERROGATORY NO 84 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR further objects to the undefined term dust as overbroad vague and ambiguous PACCAR objects that this Page 136 of 193 Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects that this Interrogatory lacks sufficient specificity regarding the type of asbestos level duration and manner of alleged exposure PACCAR further objects that this Interrogatory is confusing as drafted given that it does not refer to any particular product PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products In addition PACCAR notes that to the best of its knowledge Plaintiff has not alleged that Decedent was employed by PACCAR worked at a PACCAR facility or was otherwise involved in the assembly of its trucks To the extent this Interrogatory seeks information about PACCAR facilities and employment practices that are not at issue it has no legitimate purpose other than to harass PACCAR and confuse the issues Page 137 of 193 PACCAR also objects to this Interrogatory as argumentative because it inappropriately assumes that exposures to all containing products are equal and hazardous despite the abundance of epidemiological studies which demonstrate that mechanics are not at an increased risk of developing an asbestos disease Accordingly without more specificity regarding the type of product type of asbestos fiber amount of exposure duration of exposure and latency period PACCAR cannot fully answer this Interrogatory INTERROGATORY NO 85 State whether you ever required your employees agents servants and contract units who worked with and around asbestos and asbestos products to wear respirators gas masks protective clothing and other protective devices If so state a Which employees agents and servants by type of employment and department were required to use each such protective device b The date on which the directive relative to each such protective device was issued for each type of employee and each department c Which type of protective device was required to be used or worn by each type of employee and each department d The identity of any agent servant employee officer or representative of yours involved in discussions and decisions regarding the same and e The custodian identity and location of all documents pertaining to protective devices RESPONSE TO INTERROGATORY NO 85 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not Page 138 of 193 involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects that this Interrogatory lacks sufficient specificity regarding the type of asbestos level duration and manner of alleged exposure PACCAR further objects that this Interrogatory is confusing as drafted given that it does not refer to any particular product PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products In addition PACCAR notes that to the best of its knowledge Plaintiff has not alleged that Decedent was employed by PACCAR worked at a PACCAR facility or was otherwise involved in the assembly of its trucks To the extent this Interrogatory seeks information about PACCAR facilities and employment practices that are not at issue it has no legitimate purpose other than to harass PACCAR and confuse the issues PACCAR also objects to this Interrogatory as argumentative because it inappropriately assumes that exposures to all containing products are equal and hazardous despite the abundance of epidemiological studies which demonstrate that mechanics are not at an increased risk of developing an asbestos disease Accordingly without more specificity regarding the type of product type of asbestos fiber amount of exposure duration of exposure and latency period PACCAR cannot fully answer this Interrogatory Page 139 of 193 INTERROGATORY NO 86 State whether at the commencement of an individual's employment with you from 1930 to the present you informed that person as to possible health ramifications of working with and around asbestos fibers dust and products If so set forth a The nature of the warning b The manner in which said information is communicated and if the communication is in writing attach a copy hereto c When such practice was initiated and d By whom such information is communicated RESPONSE TO INTERROGATORY NO 86 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR further objects to the undefined term dust as overbroad vague and ambiguous PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects that this Interrogatory lacks sufficient specificity regarding the type of asbestos level duration and manner of alleged exposure PACCAR further objects that this Interrogatory is confusing as drafted given that it does not refer to any particular product PACCAR further objects on the basis that this Interrogatory appears to be directed Page 140 of 193 towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products In addition PACCAR notes that to the best of its knowledge Plaintiff has not alleged that Decedent was employed by PACCAR worked at a PACCAR facility or was otherwise involved in the assembly of its trucks To the extent this Interrogatory seeks information about PACCAR facilities and employment practices that are not at issue it has no legitimate purpose other than to harass PACCAR and confuse the issues PACCAR also objects to this Interrogatory as argumentative because it inappropriately assumes that exposures to all containing products are equal and hazardous despite the abundance of epidemiological studies which demonstrate that mechanics are not at an increased risk of developing an asbestos disease Accordingly without more specificity regarding the type of product type of asbestos fiber amount of exposure duration of exposure and latency period PACCAR cannot fully answer this Interrogatory INTERROGATORY NO 87 State whether based upon the material contents the manufacturing methods and the methods of application or installation of your asbestos products your asbestos products can generally be applied by the insulator or others without liberating asbestos fibers RESPONSE TO INTERROGATORY NO 87 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof Page 141 of 193 PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects that this Interrogatory is confusing as drafted given that it does not refer to any particular product PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture asbestos- containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR objects that this Interrogatory mischaracterizes it as a miner or manufacturer of asbestos insulation which is inaccurate misleading and argumentative Subject to and without waiver of the foregoing objections PACCAR states this Interrogatory is inapplicable to PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company as such PACCAR objects Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 88 State whether it was foreseeable to you that your asbestos- containing insulation products would have to be removed stripped or replaced at any time after installation Page 142 of 193 RESPONSE TO INTERROGATORY NO 88 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects that this Interrogatory is confusing as drafted given that it does not refer to any particular product PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture asbestos- containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products Subject to and without waiver of the foregoing objections PACCAR states this Interrogatory is inapplicable to PACCAR's unincorporated truck divisions Kenworth Truck Page 143 of 193 Company and Peterbilt Motors Company as such PACCAR objects Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 89 State whether you ever provided insulators and others who would be applying or removing your asbestos products instructions concerning safety precautions to use during use of or exposure to such products RESPONSE TO INTERROGATORY NO 89 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects that this Interrogatory is confusing as drafted given that it does not refer to any particular product PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture asbestos- containing products rather they assembled and sold heavy duty trucks This Interrogatory is Page 144 of 193 inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR objects that this Interrogatory mischaracterizes it as a miner or manufacturer of asbestos insulation which is inaccurate misleading and argumentative PACCAR further objects on the basis that its Kenworth and Peterbilt divisions have assembled hundreds of thousands of trucks during their histories that those trucks were custom at the direction request and specification of the purchaser that certain information regarding those trucks is maintained by Vehicle Identification Number that Plaintiff has not identified the Vehicle Identification Number of any Kenworth or Peterbilt truck and therefore the location and identification of information responsive to this Interrogatory is unduly burdensome and oppressive and obtainable through less expensive and burdensome means Subject to and without waiver of the foregoing objections PACCAR states this Interrogatory is inapplicable to PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company as such PACCAR objects Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 90 State when you first received notice that any person was claiming injury as a result of use of and exposure to asbestos products identified in your Answers to Interrogatory Nos 8 and 19 RESPONSE TO INTERROGATORY NO 90 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered Page 145 of 193 by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects that this Interrogatory is confusing as drafted given that it does not refer to any particular product PACCAR further objects on the basis that as a corporation it is extremely difficult to pinpoint a date when a corporate entity pinpoint when it first received notice about something PACCAR objects to the extent this information is equally available to Plaintiff as a matter of public record INTERROGATORY NO.91 NO.91 With regard to the first notice of claim of injury described in your Answer to Interrogatory No. 90 and regarding all claims filed prior to 1970 for injury resulting from use of and exposure to asbestos products state (a) The identity of each claimant b The date of notice of each claim c A description of each claim d The type of injury allegedly sustained by each claimant e The identity of each attorney representing the individuals making such claims f The style case number and court applicable to each claim g The resolution of each claim and h The custodian identity and location of all documents which relate or pertain to each claim RESPONSE TO INTERROGATORY NO 91 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague Page 146 of 193 ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects that this Interrogatory is confusing as drafted given that it does not refer to any particular product PACCAR objects to the extent this information is equally available to Plaintiff as a matter of public record PACCAR also objects to this Interrogatory as oppressive harassing and burdensome as it would require PACCAR to undertake a massive and extraordinary document search the results of which would have little to no demonstrable bearing on this litigation in light of the alleged exposure PACCAR also objects to the extent Plaintiff seeks information protected by Health Insurance Portability and Accountability Act HIPAA INTERROGATORY NO 92 State whether at any time prior to the present any person filed a claim against any worker's compensation insurance carrier which provided coverage for you alleging that he or she contracted a disease as a result of use of and exposure to asbestos products identified in your Answers to Interrogatory No. 90 RESPONSE TO INTERROGATORY NO 92 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague Page 147 of 193 ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company In addition PACCAR notes that to the best of its knowledge Plaintiff has not alleged that Decedent was employed by PACCAR worked at a PACCAR facility or was otherwise involved in the assembly of its trucks To the extent this Interrogatory seeks information about PACCAR facilities and employment practices that are not at issue it has no legitimate purpose other than to harass PACCAR and confuse the issues INTERROGATORY NO 93 If your Answer to Interrogatory No. 92 is in the affirmative provide the following information a A list of each such claim by claimant's name date claim filed and jurisdiction and b A brief summary of the disposition of each such claim RESPONSE TO INTERROGATORY NO 93 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered Page 148 of 193 by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company In addition PACCAR notes that to the best of its knowledge Plaintiff has not alleged that Decedent was employed by PACCAR worked at a PACCAR facility or was otherwise involved in the assembly of its trucks INTERROGATORY NO 94 State whether you ever received any reports or communications from your worker's compensation insurance carrier or products liability insurance carrier with regard to potential health hazards incident to use of asbestos products and exposure to asbestos fibers or dust RESPONSE TO INTERROGATORY NO 94 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR further objects to the undefined term dust as overbroad vague and ambiguous PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not Page 149 of 193 reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR also objects to the extent this Interrogatory seeks information and documents protected from disclosure by the attorney privilege the work product doctrine or any other applicable protection PACCAR further objects that this Interrogatory lacks sufficient specificity regarding the type of asbestos level duration and manner of alleged exposure PACCAR further objects that this Interrogatory is confusing as drafted given that it does not refer to any particular product In addition PACCAR notes that to the best of its knowledge Plaintiff has not alleged that Decedent was employed by PACCAR worked at a PACCAR facility or was otherwise involved in the assembly of its trucks To the extent this Interrogatory seeks information about PACCAR facilities and employment practices that are not at issue it has no legitimate purpose other than to harass PACCAR and confuse the issues PACCAR also objects to this Interrogatory as argumentative because it inappropriately assumes that exposures to all asbestos- containing products are equal and hazardous despite the abundance of epidemiological studies which demonstrate that mechanics are not at an increased risk of developing an asbestos disease Accordingly without more specificity regarding the type of product type of asbestos fiber amount of exposure duration of exposure and latency period PACCAR cannot fully answer this Interrogatory INTERROGATORY NO.95 NO.95 If your Answer to Interrogatory No. 94 is in the affirmative state a The substance of the contents of such reports or communications Page 150 of 193 b The identity of the insurance carrier from which you received each report or communication c The dates of each such report or communications and d The custodian identity and location of all documents which relate or pertain to such reports or communications RESPONSE TO INTERROGATORY NO 95 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR also objects to the extent this Interrogatory seeks information and documents protected from disclosure by the attorney privilege the work product doctrine or any other applicable protection INTERROGATORY NO 96 State whether you ever maintained or operated a unit or units of your corporation including but not limited to divisions subsidiaries or any other entity which were under contract to apply or install the asbestos products described in your Answers to Interrogatory Nos 8 and 19 RESPONSE TO INTERROGATORY NO 96 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague Page 151 of 193 ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR further objects on the basis that its Kenworth and Peterbilt divisions have assembled hundreds of thousands of trucks during their histories that those trucks were custom at the direction request and specification of the purchaser that certain information regarding those trucks is maintained by Vehicle Identification Number that Plaintiff has not identified the Vehicle Identification Number of any Kenworth or Peterbilt truck and therefore the location and identification of information responsive to this Interrogatory is unduly burdensome and oppressive and obtainable through less Page 152 of 193 expensive and burdensome means PACCAR further objects on the basis that its Kenworth and Peterbilt divisions have assembled hundreds of thousands of trucks during their histories that those trucks were custom at the direction request and specification of the purchaser that certain information regarding those trucks is maintained by Vehicle Identification Number that Plaintiff has not identified the Vehicle Identification Number of any Kenworth or Peterbilt truck and therefore the location and identification of information responsive to this Interrogatory is unduly burdensome and oppressive and obtainable through less expensive and burdensome means INTERROGATORY NO 97 If your Answer to Interrogatory No. 96 is in the affirmative identify any and all claims filed by workers in such contract units for disease arising out of use of asbestos products and exposure to asbestos fibers or dust and as to each such claim state a The date on which you first received notice b The identity of the claimant c The nature of the claim d The style case number and jurisdiction (e) The resolution of the claim and f The custodian identity and location of all documents which relate or pertain to each claim RESPONSE TO INTERROGATORY NO 97 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR further objects to the undefined term dust as overbroad vague and ambiguous PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on Page 153 of 193 the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects that this Interrogatory lacks sufficient specificity regarding the type of asbestos level duration and manner of alleged exposure PACCAR further objects that this Interrogatory is confusing as drafted given that it does not refer to any particular product PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products In addition PACCAR notes that to the best of its knowledge Plaintiff has not alleged that Decedent was employed by PACCAR worked at a PACCAR facility or was otherwise involved in the assembly of its trucks To the extent this Interrogatory seeks information about PACCAR facilities and employment practices that are not at issue it has no legitimate purpose other than to harass PACCAR and confuse the issues PACCAR also objects to this Interrogatory as argumentative because it inappropriately assumes that exposures to all containing products are equal and hazardous despite the abundance of epidemiological studies which demonstrate that mechanics are not at an increased risk of developing an asbestos disease Accordingly without more specificity regarding the type of product type of asbestos fiber amount of exposure duration of exposure and latency period PACCAR cannot fully answer this Interrogatory PACCAR objects that this Interrogatory Page 154 of 193 requests information that is equally available to Plaintiff as a matter of public record PACCAR further objects on the basis that as a corporation it is extremely difficult to pinpoint a date when a corporate entity first received notice about something PACCAR also objects to the extent Plaintiff seeks information protected by Health Insurance Portability and Accountability Act HIPAA INTERROGATORY NO 98 Identify any and all insurance agreements entered into by and between any person carrying on an insurance business and you which may be available to satisfy part or all of a judgment that might be entered in this action or to indemnify or reimburse you for payments made to satisfy the judgment As to each such agreement identify the insurance carrier the amount of coverage and the applicable dates of coverage RESPONSE TO INTERROGATORY NO 98 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company Additionally over the years PACCAR has carried various types of insurance Determining whether any such policies would cover the claims asserted herein calls for a legal Page 155 of 193 conclusion as well as factual details regarding dates of exposure which have not been provided Accordingly PACCAR objects to this Interrogatory PACCAR objects that this Interrogatory calls for speculation INTERROGATORY NO 99 Describe the method by which you have maintained records concerning the manufacture sale advertising distribution delivery and installation of each of the asbestos products identified in your Answer to Interrogatory Nos 8 and 19 RESPONSE TO INTERROGATORY NO 99 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a Page 156 of 193 better position to respond regarding their containing products PACCAR further objects on the basis that its Kenworth and Peterbilt divisions have assembled hundreds of thousands of trucks during their histories that those trucks were custom at the direction request and specification of the purchaser that certain information regarding those trucks is maintained by Vehicle Identification Number that Plaintiff has not identified the Vehicle Identification Number of any Kenworth or Peterbilt truck and therefore the location and identification of information responsive to this Interrogatory is unduly burdensome and oppressive and obtainable through less expensive and burdensome means Subject to and without waiving the foregoing objections PACCAR's retention policy is 7 years save for documents that fall under specific categories Answering further and to the extent responsive documents exist for the products at issue and the relevant time frame PACCAR directs Plaintiff to the documents produced bates labeled PACCAR000001 - PACCAR002248 as it contains the oldest document retention policy found Additionally PACCAR can make additional more recent policies available upon request at a mutually agreeable time and place Answering further PACCAR possesses the following documents that may be responsive to Plaintiff's Request 1. Build Sheets for trucks assembled prior to 1988 are on microfiche and microfilm For those microfiche and microfilm in PACCAR's possession PACCAR stores the aforementioned microfiche related to Kenworth trucks in Washington and microfiche related to Peterbilt trucks in Texas PACCAR also possesses Peterbilt Build Sheets on microfilm for trucks assembled prior to 1972. These files are indexed by chassis number so with that information documents specific to a particular truck can be identified PACCAR can make Page 157 of 193 these microfiche and microfilm available for physical review and copying at a mutually convenient time at Plaintiff's expense 2. Build Sheets previously kept on microfiche and converted to electronic format for Kenworth and Peterbilt trucks assembled prior to 1988 are stored as TIFF tagged image file format files For Kenworth vehicles these digitized Build Sheets are for trucks assembled from the late 1960s to 1987. For Peterbilt vehicles these digitized Build Sheets are for trucks assembled from the early 1970s to 1987. PACCAR can make all TIFF files available to Plaintiff at Plaintiff's expense upon reasonable notice These files are indexed by chassis number so with that information documents specific to a particular truck can be identified and 3. Build Sheets for trucks assembled from 1988 to the present are available electronically in vertical bar delimited text files PACCAR can make these vertical bar delimited text files available to Plaintiff at Plaintiff's expense upon reasonable notice Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 100 With regard to the keeping method described in your Answer to Interrogatory No. 99 identify a Each present and former corporate department division or subdivision responsible for maintaining the records b How the records are kept e.g. in boxes files on microfilm microfiche or computer tape or disk c The inclusive dates of manufacture sale advertising distribution delivery and installation that the record keeping system covers d The location where such records are maintained and e The identity of each person employed by you at any time from 1930 to the present in the highest supervisory capacity who is or was directly responsible for the collection and maintenance of such records Page 158 of 193 RESPONSE TO INTERROGATORY NO 100 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects on the basis that its Kenworth and Peterbilt divisions have assembled hundreds of thousands of trucks during their histories that those trucks were custom at the direction request and specification of the purchaser that certain information regarding those trucks is maintained by Vehicle Identification Number that Plaintiff has not identified the Vehicle Identification Number of any Kenworth or Peterbilt truck and therefore the location and identification of information responsive to this Interrogatory is unduly burdensome and oppressive and obtainable through less expensive and burdensome means Subject to and without waiver of the foregoing objections PACCAR directs Plaintiff to its Objections and Response to Interrogatory No. 99 incorporated herein by reference Discovery is Page 159 of 193 ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 101 If the record keeping system described in your Answer to Interrogatory No. 99 includes use of microfilm microfiche computer tape or disk or any other system in which data is taken from other records state whether you have retained the documents or other material from which the information entered into these modes of storage was obtained If not indicate a The date when and location where the original records were destroyed or discarded b The custodian and location of the records prior to their destruction and c The identity of each employee representative official or agent of yours who ordered authorized or supervised said destruction RESPONSE TO INTERROGATORY NO 101 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects on the basis that its Kenworth and Peterbilt divisions have assembled hundreds of thousands of trucks during their histories that those trucks were custom at the direction request and specification of the purchaser that certain information Page 160 of 193 regarding those trucks is maintained by Vehicle Identification Number that Plaintiff has not identified the Vehicle Identification Number of any Kenworth or Peterbilt truck and therefore the location and identification of information responsive to this Interrogatory is unduly burdensome and oppressive and obtainable through less expensive and burdensome means Subject to and without waiver of the foregoing objections PACCAR directs Plaintiff to its Objections and Response to Interrogatory No. 99 incorporated herein by reference Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 102 State whether at any time from 1930 to the present you made any representations that the presence of asbestos in the products identified in your Answer to Interrogatory Nos 8 and 19 made these products superior in any way to any asbestos product or material intended for the same or similar use RESPONSE TO INTERROGATORY NO 102 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Page 161 of 193 Motors Company PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR further objects on the basis that its Kenworth and Peterbilt divisions have assembled hundreds of thousands of trucks during their histories that those trucks were custom at the direction request and specification of the purchaser that certain information regarding those trucks is maintained by Vehicle Identification Number that Plaintiff has not identified the Vehicle Identification Number of any Kenworth or Peterbilt truck and therefore the location and identification of information responsive to this Interrogatory is unduly burdensome and oppressive and obtainable through less expensive and burdensome means INTERROGATORY NO 103 If your Answer to Interrogatory No. 102 is in the affirmative indicate with respect to each such representation a The date on which the representation was made b Its exact content and c The manner in which it was communicated RESPONSE TO INTERROGATORY NO 103 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof Page 162 of 193 PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects on the basis that its Kenworth and Peterbilt divisions have assembled hundreds of thousands of trucks during their histories that those trucks were custom at the direction request and specification of the purchaser that certain information regarding those trucks is maintained by Vehicle Identification Number that Plaintiff has not identified the Vehicle Identification Number of any Kenworth or Peterbilt truck and therefore the location and identification of information responsive to this Interrogatory is unduly burdensome and oppressive and obtainable through less expensive and burdensome means INTERROGATORY NO 104 State whether at any time from 1930 to the present you made any representations that the use of asbestos or their use of the asbestos products identified in your Answer to Interrogatory Nos 8 and 19 was safe harmless or not dangerous RESPONSE TO INTERROGATORY NO 104 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof Page 163 of 193 PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects that this Interrogatory lacks sufficient specificity regarding the type of asbestos level duration and manner of alleged exposure PACCAR further objects that this Interrogatory is confusing as drafted given that it does not refer to any particular product PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR also objects to this Interrogatory as argumentative because it inappropriately assumes that exposures to all asbestoscontaining products are equal and hazardous despite the abundance of epidemiological studies which demonstrate that mechanics are not at an increased risk of developing an asbestos disease Accordingly without more specificity regarding the type of product type of asbestos fiber amount of exposure duration of exposure and latency period PACCAR cannot fully answer this Interrogatory PACCAR further objects on the basis that its Kenworth and Peterbilt divisions have assembled hundreds of thousands of trucks during their histories that those trucks were Page 164 of 193 custom at the direction request and specification of the purchaser that certain information regarding those trucks is maintained by Vehicle Identification Number that Plaintiff has not identified the Vehicle Identification Number of any Kenworth or Peterbilt truck and therefore the location and identification of information responsive to this Interrogatory is unduly burdensome and oppressive and obtainable through less expensive and burdensome means INTERROGATORY NO 105 If your Answer to Interrogatory No. 104 is in the affirmative indicate as to each such representation a The date on which the representation was made b Its exact content and c The manner in which it was communicated RESPONSE TO INTERROGATORY NO 105 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects on the basis that its Kenworth and Peterbilt divisions have assembled hundreds of thousands of trucks during their histories that those trucks were Page 165 of 193 custom at the direction request and specification of the purchaser that certain information regarding those trucks is maintained by Vehicle Identification Number that Plaintiff has not identified the Vehicle Identification Number of any Kenworth or Peterbilt truck and therefore the location and identification of information responsive to this Interrogatory is unduly burdensome and oppressive and obtainable through less expensive and burdensome means INTERROGATORY NO 106 State whether any of the asbestos products identified in your Answers to Interrogatory Nos 8 and 19 were ever stored or warehoused by you in Maryland at any time from 1930 to the present RESPONSE TO INTERROGATORY NO 106 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather Page 166 of 193 they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR further objects on the basis that its Kenworth and Peterbilt divisions have assembled hundreds of thousands of trucks during their histories that those trucks were custom at the direction request and specification of the purchaser that certain information regarding those trucks is maintained by Vehicle Identification Number that Plaintiff has not identified the Vehicle Identification Number of any Kenworth or Peterbilt truck and therefore the location and identification of information responsive to this Interrogatory is unduly burdensome and oppressive and obtainable through less expensive and burdensome means INTERROGATORY NO 107 identify If your Answer to Interrogatory No. 106 is in the affirmative a The address of each warehouse or storage facility b The asbestos products stored or warehoused at each warehouse or storage facility identified in your Answer to part A of this Interrogatory c The year of such storage or warehousing and d The custodian identity and location of each document in your custody Possession or control which describes or relates to such storage or warehousing RESPONSE TO INTERROGATORY NO 107 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not Page 167 of 193 reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR further objects on the basis that its Kenworth and Peterbilt divisions have assembled hundreds of thousands of trucks during their histories that those trucks were custom at the direction request and specification of the purchaser that certain information regarding those trucks is maintained by Vehicle Identification Number that Plaintiff has not identified the Vehicle Identification Number of any Kenworth or Peterbilt truck and therefore the location and identification of information responsive to this Interrogatory is unduly burdensome and oppressive and obtainable through less expensive and burdensome means INTERROGATORY NO 108 Identify the means by which the asbestos products identified in your Answers to Interrogatory Nos 8 and 19 were transported to Maryland at any time from 1930 to the present and state a If the asbestos products were transported by rail identify the name of the railroad company providing that service and the year during which such service was used b If the asbestos products were transported by truck identify the name of the carrier providing that service and the year during which such service was used Page 168 of 193 c If the asbestos products were transported by vessel identify the name of the shipping line providing that service and the year during which such service was used d The identity of each employee of yours responsible for coordinating the transport or delivery of such products to Maryland e The identity of each employee officer agent or representative of yours with personal knowledge of the transport or delivery of such products to Maryland and f The custodian identity and location of each document which describes or relates to the transport or delivery of such products to Maryland RESPONSE TO INTERROGATORY NO 108 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a Page 169 of 193 better position to respond regarding their containing products PACCAR further objects on the basis that its Kenworth and Peterbilt divisions have assembled hundreds of thousands of trucks during their histories that those trucks were custom at the direction request and specification of the purchaser that certain information regarding those trucks is maintained by Vehicle Identification Number that Plaintiff has not identified the Vehicle Identification Number of any Kenworth or Peterbilt truck and therefore the location and identification of information responsive to this Interrogatory is unduly burdensome and oppressive and obtainable through less expensive and burdensome means INTERROGATORY NO 109 Identify each person whom you expect to call as an expert witness at trial state the subject matter on which each expert is expected to testify state the substance of the findings and opinions to which each expert is expected to testify and a summary of the grounds for each opinion and produce any written report made by each expert concerning those findings and opinions RESPONSE TO INTERROGATORY NO 109 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR also objects to the extent this Interrogatory seeks information and documents protected from disclosure by the attorney privilege the work product doctrine or any other applicable protection PACCAR objects to this Interrogatory as premature Subject to and without waiving the foregoing objections PACCAR states that it will designate its witnesses in accordance with the applicable rules and case management order Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 110 With regard to expert witnesses identified in your Answer to Interrogatory No. 109 identify by case name date court and case number any deposition or testimony given by each such expert and state the custodian and location of transcripts thereof Page 170 of 193 RESPONSE TO INTERROGATORY NO 110 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR also objects to the extent this Interrogatory seeks information and documents protected from disclosure by the attorney privilege the work product doctrine or any other applicable protection PACCAR objects to this Interrogatory as premature Subject to and without waiving the foregoing objections PACCAR states that it will designate its witnesses in accordance with the applicable rules and case management order Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 111 Identify each person who has testified on your behalf at trial or by deposition in a case alleging asbestos injury state the custodian and location of transcripts thereof and set forth the case name number court and date with respect to each proceeding in which the witness testified RESPONSE TO INTERROGATORY NO 111 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly Page 171 of 193 PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects that this Interrogatory lacks sufficient specificity regarding the type of asbestos level duration and manner of alleged exposure PACCAR also objects to this Interrogatory as argumentative because it inappropriately assumes that exposures to all containing products are equal and hazardous despite the abundance of epidemiological studies which demonstrate that mechanics are not at an increased risk of developing an asbestos disease Accordingly without more specificity regarding the type of product type of asbestos fiber amount of exposure duration of exposure and latency period PACCAR cannot fully answer this Interrogatory PACCAR objects to the extent this information is either already in Plaintiff's counsel's possession and is equally available to Plaintiff as a matter of public record Subject to and without waiving the foregoing objections PACCAR states a Malvin Rivenbark & Mary Ann Rivenbark v Fireboard Corp et al b Alameda County CA Case No. 711462-9 (c) August 26 1993 (d) Kazan McClain Edises & Simon 171 12th Street 3rd Floor Oakland CA 94607 (e) Aiken & Welch Inc. One Kaiser Plaza Suite 505 Oakland CA 94612 a Richard Johnston v Bondex International Inc. b King County Washington Case No. 08-2-03325-2SEA c December 23 2008 d Simon Eddins & Greenstone LLP 301 East Ocean Blvd. Suite 1950 Long Beach CA 90802 e Legal Eyes Inc. 1701 N. Locust St. Denton TX 3000 Willie and Betty Martin v A.W. Chesterton Company et al 3000 Los Angeles County CA Case No. BC378790 3000 April 28 2009 3000 Keller Fishback & Jackson LLP 18425 Burbank Blvd. Suite 610 Tarzana CA 91356 e Advantage Court Reporters 18401 Burbank Blvd. Tarzana CA 91356 Page 172 of 193 a Marlene Goebel et al v Bondex International Inc. et al b Los Angeles County CA Case No. BC390954 (c) June 25 2009 d Waters Kraus & Paul 3219 McKinney Avenue Dallas TX 75204 e Byers & Anderson Inc. One Union Square 600 University St. Suite 2300 Seattle WA 98101 a Billy Johnson v Advocate Mines b San Francisco County CA Case No. 10-275528 (c) October 1 2010 and November 9 2010 d The Farisse Law Firm 11900 W. Olympic Blvd. Suite 580 Los Angeles CA 90064 e Byers & Anderson Inc. One Union Square 600 University St. Suite 2300 Seattle WA 98101 3999 Chester E. Morrison and Dianne Morrison v Alfa Laval Inc. et al 3999 Los Angeles County CA Case No. BC441029 3999 February 24 2011 3999 The Lanier Law Firm 2049 Century Park East Suite 1940 Los Angeles CA 90067 e HG Litigation Services 2501 Oak Lawn Avenue Suite 600 Dallas TX 75219 (a) Terrance Obney v AK Steel Corporation et al b Allegheny County PA Case No. 10-017444 c August 30 2011 d Savinis D'Amico & Kane LLP Suite 3626 Gulf Tower Pittsburgh PA 15219 e Network Deposition Services Suite 1101 Gulf Tower Pittsburgh PA 15219 a Michael Otis and Cheryl Otis v Air & Liquid Systems Corp. et al b Multnomah County OR Case No. 1307-10088 c April 9 2014 and April 23 2014 d Waters Kraus & Paul 3219 McKinney Avenue Dallas TX 75204 e HG Litigation Services 2501 Oak Lawn Avenue Dallas TX 75219 a Felicitas Salas et al .AGCO Corp. et al b Los Angeles County CA Case No. BC 531832 c June 16 2014 and June 17 2014 d Keller Fishback & Jackson LLP 28720 Canwood St. Suite 200 Agoura Hills CA 91301 e Advantage Court Reporters 445 S. Figueroa St. 23rd Floor Los Angeles CA 90017 Page 173 of 193 a Robert Weiner & Leona Weiner v 3M Company et al (b} Middlesex County Commonwealth of Massachusetts C.A. No. 14-6723 (c) March 19 2015 d The Deaton Law Firm 450 N. Broadway East Providence RI 02914 (e) Eppley Court Reporting LLC P.O. Box 382 Hopedale MA 01747 a Warren T. Doyle v 3M Company et al b Ramsey County MN Court File No 15-6382 (c) September 29 2016 d Karst & Von Oiste LLP 19500 State Highway 249 Suite 420 Houston TX 77070 e Infinity Reporting Group LLC 1502 Park Harbor Estates Drive Houston TX 77084 a Barbara J. Ogg as Surviving Spouse and as Administratix of the Estate of Charles Ogg deceased and Darrell E. Ogg and Cindy L. Spence as Surviving Children v The Ford Motor Company et al b New Castle County DE Case No. 07-160 ASB c May 1 2018 d Cappolino Dodd Krebs LLP 312 S Houston Ave. Cameron TX 76520 (e) Infinity Reporting Group LLC 1502 Park Harbor Estates Dr. Houston TX 77084 a Charles French and Victoria French v ArvinMeritor Inc. et al b McLean County IL Case No. 00067 c July 25 2018 d Wylder Corwin & Kelly 207 E. Washington St. Suite 102 Bloomington IL 61701 e Anchor Reporting Inc. P.O. Box 25471 Decatur IL 62525 a Pearl Tart Crystal Booker Cynthia Wilson Wesley Wilson as individuals and legal heirs at law of John Tart v Warner Corporation by its successor in interest BorgWarner Morse Tec Inc. et al b Los Angeles County CA Case No. JCCP4674 c October 18 2018 d Robins Cloud LLP 808 Wilshire Blvd. Suite 450 Santa Monica CA 90401 e HG Litigation Services 2501 Oak Lawn Ave. Suite 600 Dallas TX 75219 a Steven Donovan and Brenda Donovan Lyle Staley and Susan Staley v ArvinMeritor Inc. et al a McLean County IL Case No. 64 b February 26 2019 c Wylder Corwin Kelly LLP 207 East Washington St. Suite 102 Bloomington Page 174 of 193 IL 61701 d Anchor Reporting Inc. P.O. Box 25471 Decatur IL 62525 a Jeffrey Richard Henry Individually and as Trustee for the next for Richard Henry Deceased v Ford Motor Company et al b Ramsey County MN Court File No 15-7775 (c) July 31 2019 (d) Dean Omar Branham Shirley 302 North Market St. Suite 300 Dallas TX 75202 (e) U.S. Legal Support 5910 North Central Expressway Suite 100 Dallas TX 75206 a Robert Skelton Individually and as Successor in Interest to Wanda Skelton Deceased and Gary Skelton an Individual Jerry Skelton an Individually v Allied Fluid Products Corp. et al (b} Alameda County CA Case No. 17868697 (c) October 3 2019 d Weitz & Luxenburg PC 1880 Century Park East Suite 700 Los Angeles CA 90067 e Priority Court Reporting Services Inc. 290 West Mt. Pleasant Ave. Suite 3200 Livingston NJ 07039 a Donald Dysart and Nancy Dysart v ArvinMeritor Inc. et al 18-130 Roger Soverns and Veronica Soverns v ArvinMeritor Inc. et al 19CV38303 and Gilbert John Puffinberger and Francis Puffinberger v 3M Company et al 03- 9600 b Cumberland County ME Multnomah County OR and Kanawha WV respectively c Maune Raichle Hartley French & Mudd LLC 1015 Locust Street Suite 1200 St. Louis MO 63101 d January 28 2020 e Veritext Legal Solutions Atlantic Region 1801 Market Street Suite 1800 Philadelphia PA 19103 a William Clark and Stephanie Clark v Arrow Machinery Inc. et al 19-2-26061- SEA b King County WA c Bergman Draper Oslund Udo 821 2nd Ave. Suite 2100 Seattle WA 98104 d June 30 2020 e Rebecca Graziano of Graziano Reporting Services LLC a Gary Finn v American Honda Motor Co. Inc. et al 11-107 b New Castle County DE (c) Weitz & Luzenberg 700 Broadway New York NY 10003 (d) August 7 2020 (e) Cheryl Nicholas HG Litigation Services 2777 N. Stemmons Freeway Suite Page 175 of 193 1025 Dallas TX 75207 <Regina Pawlik Individually and as the Special Administrator to the Estate of Adam Pawlik Deceased v 3M Company et al 19 L 008784 9000 Cook County IL 9000 Vogelzang Law 401 N. Michigan Ave. Suite 350 Chicago IL 60611 9000 August 2020 9000 Roselind C. Pisano <Laura Walls Individually and as Executor of the Estate of Robie Walls v Ford Motor Company et al 00098 90 North Carolina US District Court Middle District 90 Dean Omar Branham Shirley LLP 302 N. Market Street Suite 300 Dallas TX 75202 / Wallace & Graham P.A. North Main Street Salisbury NC 28144 <October 30 2020 e Deborah Renee Quarles 8144 Walnut Hill Lane Suite 350 Dallas TX 75231 a David Settlemyer and Jan Settlemyer v Warner Morse Tec LLC successor to Warner Corporation et al 00344 WCM b North Carolina US District Court Western District c Wallace & Graham P.A. North Main Street Salisbury NC 28144 / Simmons Hanly Conroy One Court Street Alton IL 62002 d November 4 2020 e Kevin J. Weichman Paszkiewicz Records Retrieval 26 Ginger Creek Parkway Glen Carbon IL 62034 39000 Wayne K. Maust and Lisa L. Maust v ArvinMeritor Inc. et al 20-2-05906-0 39000 Pierce County WA 39000 Maune Raichle Hartley French & Mudd LLC 1015 Locust St. Suite 1200 St. Louis MO 63101 39000 February 10 2021 February 24,2021 March 2 2021 39000 Pohlman Court Reporting 39000 Carole Colvin et al v Autozone Inc. et al 24X12000713 39000 Baltimore County MD 39000 Napoli Shkolnik 919 N Market Street Suite 1801 Wilmington DE 19801 39000 March 30 2021 39000 Magna Legal Services 1635 Market St. Philadelphia PA 19103 a Gaynor Austin Individually and as Personal Representative of the Estate of Allen Austin Deceased v BNSF Railway Company et al 18-2-15054-0 SEA ee King County WA ee Waters & Kraus Iola Galerston LLP 3838 Oak Lawn Ave Suite 840 Dallas TX 75219 d June 22 2021 & June 23 2021 Page 176 of 193 e Advances One Legal 2777 N Stemmons Freeway Suite 1025 Dallas TX 75207 a Case Name Randall Bose and Etta Bose his wife v 84 Lumber Company et al 1759 - Rodney Curbo b Madison County IL c SWMW Law LLC 701 Market St Unit 1000 St. Louis MO 63101 d September 9 2021 @ Paszkiewicz Litigation Services 26 Ginger Creek Parkway Glen Carbon Illinois 62034 a Ann Chapman & Gary Chapman v Avon Products Inc. et al b Los Angeles County CA Case No. 22STCV05968 (c) August 5 2022 d Dean Omar Branham Shirley LLP 302 N. Market Street Suite 300 Dallas TX 75202 e Adam D. Miller Asbestos Reporters GPS partner a Ronald LeRoy Carpenter and Patricia Ann Carpenter v 3M Company k Minnesota Mining & Manufacturing Company et al b Los Angeles County CA Case No. 20STCV46727 c September 19 2023 and September 26 2023 d Jones & Bendon LLP 2251 Hidalgo Avenue Los Angeles CA 90039 e Kimberly Byrns Buchanan Asbestos Reporters GPS affiliate a Bruce S. Wright and Louise K. Wright v Cummins Inc. et al b United States District Court District of Massachusetts Civil Action No cv- N10495 c April 19 2024 d Dean Omar Branham Shirley LLP 302 N. Market Street Suite 300 Dallas TX 75202 e Darlene Caizzo Sousa Lexitas a David Rosedale and Kimberly Rosedale v AGCO Corporation et al b Los Angeles County CA Case No. 23STCV15864 c May 7 2024 d Simmons Hanly Conroy One Court Street Alton IL 62002 e Shirley Koch Asbestos Reporters GPS affiliate a John Doomey and Elizabeth Doomey v Albertsons Companies Inc. et al b Los Angeles County CA Case No. 21STCV47286 c May 23 2024 d Dean Omar Branham Shirley 302 North Market Street Suite 300 Dallas TX 75202 e Shirley Koch Asbestos Reporters GPS affiliate Page 177 of 193 Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 112 State whether you contend that asbestos products have been or can be manufactured or treated so as to eliminate all potential health hazards to workers who use asbestos products and are exposed to asbestos fibers or dust If so explain in detail the factual basis for this contention RESPONSE TO INTERROGATORY NO 112 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR further objects to the undefined term dust as overbroad vague and ambiguous PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects that this Interrogatory lacks sufficient specificity regarding the type of asbestos level duration and manner of alleged exposure PACCAR further objects that this Interrogatory is confusing as drafted given that it does not refer to any particular product PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt Page 178 of 193 divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR also objects to this Interrogatory as argumentative because it inappropriately assumes that exposures to all asbestoscontaining products are equal and hazardous despite the abundance of epidemiological studies which demonstrate that mechanics are not at an increased risk of developing an asbestos disease Accordingly without more specificity regarding the type of product type of asbestos fiber amount of exposure duration of exposure and latency period PACCAR cannot fully answer this Interrogatory PACCAR further objects on the basis that its Kenworth and Peterbilt divisions have assembled hundreds of thousands of trucks during their histories that those trucks were custom at the direction request and specification of the purchaser that certain information regarding those trucks is maintained by Vehicle Identification Number that Plaintiff has not identified the Vehicle Identification Number of any Kenworth or Peterbilt truck and therefore the location and identification of information responsive to this Interrogatory is unduly burdensome and oppressive and obtainable through less expensive and burdensome means PACCAR objects that this Interrogatory is calling for speculation and calling for an expert opinion Subject to and without waiving the foregoing objections PACCAR is unable to answer this Interrogatory as it calls for an expert opinion which PACCAR is unable and unqualified to make Answering further PACCAR reserves the right to rely upon its experts opinions which will be disclosed pursuant to the applicable rules and case management order Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained Page 179 of 193 INTERROGATORY NO 113 State whether you contend that any person or business entity not presently a party to this action is responsible in whole or in part for any of the plaintiffs damages If so identify each such person or business entity and state the facts which form the basis for each such contention RESPONSE TO INTERROGATORY NO 113 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR also objects to the extent this Interrogatory seeks information and documents protected from disclosure by the attorney privilege the work product doctrine or any other applicable protection PACCAR objects that this Interrogatory is calling for speculation and calling for an expert opinion Subject to and without waiving the foregoing objections PACCAR is unable to answer this Interrogatory as it calls for an expert opinion which PACCAR is unable and unqualified to make Answering further PACCAR reserves the right to rely upon its experts opinions which will be disclosed pursuant to the applicable rules and case management order PACCAR further directs Plaintiff to its Answer and Affirmative Defenses incorporated herein Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 114 inherently dangerous If so state contention State whether you contend that asbestos all facts and documents which form the products are not basis for such a RESPONSE TO INTERROGATORY NO 114 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof Page 180 of 193 PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects that this Interrogatory lacks sufficient specificity regarding the type of asbestos level duration and manner of alleged exposure PACCAR further objects that this Interrogatory is confusing as drafted given that it does not refer to any particular product PACCAR also objects to this Interrogatory as argumentative because it inappropriately assumes that exposures to all containing products are equal and hazardous despite the abundance of epidemiological studies which demonstrate that mechanics are not at an increased risk of developing an asbestos disease Accordingly without more specificity regarding the type of product type of asbestos fiber amount of exposure duration of exposure and latency period PACCAR cannot fully answer this Interrogatory PACCAR objects that this Interrogatory is calling for speculation and calling for an expert opinion PACCAR also objects to the extent this Interrogatory seeks information and documents protected from disclosure by the attorneyclient privilege the work product doctrine or any other applicable protection Subject to and without waiving the foregoing objections PACCAR is unable to answer this Interrogatory as it calls for an expert opinion which PACCAR is unable and unqualified to make Answering further PACCAR reserves the right to rely upon its experts opinions which will be disclosed pursuant to the applicable rules and case management order Discovery is ongoing Page 181 of 193 and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 115 State whether you contend that you did not have a duty to warn users of the asbestos products identified in your Answer to Interrogatory Nos 8 and 19 of the hazards and risks of use of and exposure thereto If so state all facts and identify all documents which form the basis for such a contention RESPONSE TO INTERROGATORY NO 115 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR also objects to the extent this Interrogatory seeks information and documents protected from disclosure by the attorney privilege the work product doctrine or any other applicable protection PACCAR further objects that this Interrogatory lacks sufficient specificity regarding the type of asbestos level duration and manner of alleged exposure PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did Page 182 of 193 not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR also objects to this Interrogatory as argumentative because it inappropriately assumes that exposures to all containing products are equal and hazardous despite the abundance of epidemiological studies which demonstrate that mechanics are not at an increased risk of developing an asbestos disease Accordingly without more specificity regarding the type of product type of asbestos fiber amount of exposure duration of exposure and latency period PACCAR cannot fully answer this Interrogatory PACCAR objects that this Interrogatory is calling for speculation and calling for an expert opinion PACCAR objects that this Interrogatory is calling for a legal conclusion INTERROGATORY NO 116 State whether you contend that you performed adequate tests of the safety of the asbestos products identified in your Answer to Interrogatory Nos 8 and 19. If so state all facts and identify all documents which form the basis for such a contention RESPONSE TO INTERROGATORY NO 116 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not Page 183 of 193 involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects that this Interrogatory lacks sufficient specificity regarding the type of asbestos level duration and manner of alleged exposure PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR also objects to this Interrogatory as argumentative because it inappropriately assumes that exposures to all containing products are equal and hazardous despite the abundance of epidemiological studies which demonstrate that mechanics are not at an increased risk of developing an asbestos disease Accordingly without more specificity regarding the type of product type of asbestos fiber amount of exposure duration of exposure and latency period PACCAR cannot fully answer this Interrogatory PACCAR objects that this Interrogatory is calling for speculation and calling for an expert opinion PACCAR objects that this Interrogatory is calling for a legal conclusion PACCAR also objects to the extent that this Interrogatory implies that PACCAR had a duty to conduct or contribute to the conducting of any sampling analyses studies or testing of any product which allegedly contained asbestos and was manufactured by another company Subject to and without waiving the foregoing objections David Bissonette CIH was hired in 1974 and in 1976 Mr. Bissonette enumerated a three testing process in a 1976 Page 184 of 193 presentation 1 identify a possible hazard 2 evaluate the possible hazard and 3 if the evaluation shows that there is a hazard put controls in place Mr. Bissonnette's testing revealed that there were no health hazards to mechanics performing brake work Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 117 State whether you contend that you did not conspire with others to allow asbestos products to be used without adequate warnings or without any warnings regarding the hazards or risks of use of and exposure thereto If so state all facts and identify all documents which form the basis for such a contention RESPONSE TO INTERROGATORY NO 117 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound harassing argumentative and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects that this Interrogatory lacks sufficient specificity regarding the type of asbestos level duration and manner of alleged exposure PACCAR further Page 185 of 193 objects that this Interrogatory is confusing as drafted given that it does not refer to any particular product PACCAR further objects on the basis that this Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR also objects to this Interrogatory as argumentative because it inappropriately assumes that exposures to all asbestoscontaining products are equal and hazardous despite the abundance of epidemiological studies which demonstrate that mechanics are not at an increased risk of developing an asbestos disease Accordingly without more specificity regarding the type of product type of asbestos fiber amount of exposure duration of exposure and latency period PACCAR cannot fully answer this Interrogatory This Interrogatory serves no purpose other than to create a response which may be taken out of context by Plaintiff's counsel to create allegations against PACCAR where none may legitimately exist INTERROGATORY NO 118 State whether you contend that there are circumstances under which asbestos products can safely be handled and used If so state all facts and identify all documents which form the basis for such a contention RESPONSE TO INTERROGATORY NO 118 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof Page 186 of 193 PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects that this Interrogatory lacks sufficient specificity regarding the type of asbestos level duration and manner of alleged exposure PACCAR further objects that this Interrogatory is confusing as drafted given that it does not refer to any particular product PACCAR also objects to this Interrogatory as argumentative because it inappropriately assumes that exposures to all containing products are equal and hazardous despite the abundance of epidemiological studies which demonstrate that mechanics are not at an increased risk of developing an asbestos disease Accordingly without more specificity regarding the type of product type of asbestos fiber amount of exposure duration of exposure and latency period PACCAR cannot fully answer this Interrogatory PACCAR objects that this Interrogatory is calling for speculation and calling for an expert opinion PACCAR also objects to the extent this Interrogatory seeks information and documents protected from disclosure by the attorneyclient privilege the work product doctrine or any other applicable protection Subject to and without waiving the foregoing objections PACCAR is unable to answer this Interrogatory as it calls for an expert opinion which PACCAR is unable and unqualified to make Answering further PACCAR reserves the right to rely upon its experts opinions which will be disclosed pursuant to the applicable rules and case management order Discovery is ongoing Page 187 of 193 and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 119 State whether you contend that there is now or has ever been a distinction between one or more of the following with respect to use of and exposure to asbestos products and the health hazards or risks relating thereto miners millers textile workers asbestos plant workers insulators shipyard workers steel plant workers building tradesmen industrial workers auto mechanics and brake lining mechanics If so state all facts and identify all documents which form the basis for such a contention RESPONSE TO INTERROGATORY NO 119 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects that this Interrogatory lacks sufficient specificity regarding the type of asbestos level duration and manner of alleged exposure PACCAR further objects that this Interrogatory is confusing as drafted given that it does not refer to any particular product PACCAR also objects to this Interrogatory as argumentative because it inappropriately assumes that exposures to all containing products are equal and hazardous despite the Page 188 of 193 abundance of epidemiological studies which demonstrate that mechanics are not at an increased risk of developing an asbestos disease Accordingly without more specificity regarding the type of product type of asbestos fiber amount of exposure duration of exposure and latency period PACCAR cannot fully answer this Interrogatory PACCAR objects that this Interrogatory is calling for speculation and calling for an expert opinion PACCAR also objects to the extent this Interrogatory seeks information and documents protected from disclosure by the attorneyclient privilege the work product doctrine or any other applicable protection Subject to and without waiving the foregoing objections PACCAR is unable to answer this Interrogatory as it calls for an expert opinion which PACCAR is unable and unqualified to make Answering further PACCAR reserves the right to rely upon its experts opinions which will be disclosed pursuant to the applicable rules and case management order Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 120 State whether you contend that there are differences between asbestos fiber types chrysotile amosite crocidolite actinolite anthophyllite or tremolite with regard to diseases they may be capable of causing If so state all facts and identify all documents which form the basis for such a contention RESPONSE TO INTERROGATORY NO 120 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not Page 189 of 193 reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects that this Interrogatory is confusing as drafted given that it does not refer to any particular product PACCAR also objects to this Interrogatory as argumentative because it inappropriately assumes that exposures to all containing products are equal and hazardous despite the abundance of epidemiological studies which demonstrate that mechanics are not at an increased risk of developing an asbestos disease Accordingly without more specificity regarding the type of product type of asbestos fiber amount of exposure duration of exposure and latency period PACCAR cannot fully answer this Interrogatory PACCAR objects that this Interrogatory is calling for speculation and calling for an expert opinion PACCAR also objects to the extent this Interrogatory seeks information and documents protected from disclosure by the attorney privilege the work product doctrine or any other applicable protection Subject to and without waiving the foregoing objections PACCAR is unable to answer this Interrogatory as it calls for an expert opinion which PACCAR is unable and unqualified to make Answering further PACCAR reserves the right to rely upon its experts opinions which will be disclosed pursuant to the applicable rules and case management order Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained Page 190 of 193 INTERROGATORY NO 121 you are an insulation contractor identify all job sites at which you undertook the performance of work within the State of Maryland from the date of the inception of your company to the present and include as to each such job site a The identity of employees including foremen and helpers b Dates c Location d Asbestos products used e The identity of the general contractor and all subcontractors f Contracts g Bids h Specifications i Work orders ) Estimates k Reports and 1 Job books RESPONSE TO INTERROGATORY NO 121 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR objects that this Interrogatory is overbroad in scope and time as there has been no fact witness testimony offered by Plaintiff in this matter As a result PACCAR objects that this Interrogatory is a prohibited fishing expedition impermissibly designed to shift the burden of proof PACCAR also objects to this Interrogatory as not relevant to this Plaintiff or any facilities time period locations and circumstances at issue in this litigation and seeking information not reasonably calculated to lead to the discovery of admissible evidence PACCAR also objects on the basis that it has owned several businesses over the course of its long history which are not involved in the instant litigation and whose products are not at issue in this litigation Accordingly PACCAR objects to the extent that this Interrogatory seeks any information regarding entities other than PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company PACCAR further objects that this Interrogatory is confusing as drafted given that it does not refer to any particular product PACCAR further objects on the basis that this Page 191 of 193 Interrogatory appears to be directed towards manufacturers of containing products PACCAR's Kenworth and Peterbilt divisions did not use raw asbestos or manufacture asbestos- containing products rather they assembled and sold heavy duty trucks This Interrogatory is inappropriately directed to PACCAR and should instead be addressed to the component part manufacturers who are in a better position to respond regarding their containing products PACCAR further objects on the basis that its Kenworth and Peterbilt divisions have assembled hundreds of thousands of trucks during their histories that those trucks were custombuilt at the direction request and specification of the purchaser that certain information regarding those trucks is maintained by Vehicle Identification Number that Plaintiff has not identified the Vehicle Identification Number of any Kenworth or Peterbilt truck and therefore the location and identification of information responsive to this Interrogatory is unduly burdensome and oppressive and obtainable through less expensive and burdensome means PACCAR objects that this Interrogatory mischaracterizes it as a miner or manufacturer of asbestos products insulation which is inaccurate misleading and argumentative Subject to and without waiving the foregoing objections and as PACCAR understands this Interrogatory this Interrogatory is not directed to PACCAR and therefore does not required a response from PACCAR Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained INTERROGATORY NO 122 Name any person not heretofore mentioned having personal knowledge of the facts material to this case RESPONSE TO INTERROGATORY NO 122 PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR also objects to the extent this Interrogatory seeks information and documents protected from disclosure by the attorney privilege the work product doctrine or any other applicable protection PACCAR Page 192 of 193 objects to this Interrogatory as premature PACCAR objects to the extent that this Interrogatory requests information that is already in Plaintiff's counsel's possession and is equally available to Plaintiff and their counsel Subject to and without waiving the foregoing objections PACCAR states that it will designate its witnesses in accordance with the applicable rules and case management order Discovery is ongoing and PACCAR reserves the right to supplement or amend its Answer to this Interrogatory if new or additional information is obtained Dated July 5 2024 As to Objections s Scott J. McDowell Thomas P. Bernier CPF 8312010042 Scott J. McDowell CPF 0606130209 DeHay & Elliston LLP 36 South Charles Street Suite 1400 Baltimore Maryland 21201 Telephone 410.783.7225 Facsimile 410.783.7221 tbernier@dehay.com smcdowell@dehay.com Attorneys for Defendant PACCAR Inc. Page 193 of 193 THE CIRCUIT COURT FOR BALTIMORE CITY F IN RE BALTIMORE CITY * ASBESTOS LITIGATION HE * * * * * * * HH HE ROSALIND MORRIS Individually and as Personal Representative of the Estate of John Alan Morris et al He CASE NO 23-000029 HEH April 8 2025 Trial Date * Plaintiffs He He VS. HH &# BEL AIR AUTO PARTS INC et al * &< Defendants * + * * * * * * * * a * * * * VERIFICATION I Rod Curbo hereby declare I am an authorized representative of PACCAR Inc in this case I verify the Objections and Responses to Plaintiff Morris Master Interrogatories to Defendants in the case of Rosalind Morris et al v Bel Air Auto Parts Inc. et al NO 24X23000029 The matters stated in the foregoing responses are not all within my personal knowledge but I am informed and believe that there is no representative of PACCAR Inc who has personal knowledge of all such matters The facts stated in the attached responses have been assembled from employees former employees records representatives and counsel for PACCAR Inc and I am informed by said employees former employees and representatives that the facts stated in the attached responses are true and correct I declare under penalty of perjury under the laws of the State of Maryland that the foregoing is true and correct Executed on the 27th day of June 2024 Corporate Representative Pre GR WP eere s0-oer - 2S emp ctmene ge ee e