Document gB5XzGJqOOnN7dpk8kovb6QV

1 INTERROGATORY NO. 9; 2 Has defendant, at any time from 1930 to the present, engaged 3 in the processing, marketing and/or sale of products containing 4 asbestos fibers? ' 5 RESPONSE; 6 Yes 7 INTERROGATORY NO. 10: 8 If the answer to Interrogatory No. 3, No. 6 or No. 9 is 9 affirmative, please state as to each affirmative answer; 10 (a) The trade or brand name of each product mined, 11 manufactured, and/or marketed; 12 (b) The dates each product was placed on the market; 13 (c) The dates each product was withdrawn from the 14 market; 15 (d) A description of the chemical composition of each 16 product, including the type of asbestos contained in each such 17 product (i.e., amosite, chrysotile, crocidolite) and the quanti 18 tative percentage of asbestos in each product; 19 (e) A description of the physical appearance of each 20 product r 21 (f) A detailed description of the intended uses of 22 each product; 23 (g) The name of the manufacturers of each product; 24 (h) The mining or milling concern from which the raw 25 asbestos was obtained. 26 RESPONSE: 27 nz O 28 /// ii6> (a), (b) and (c): 60 -a-