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UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI
EASTERN DIVISION
2> PLAINTIFFS EXHIBIT
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GLORIA VAUGHN, ET AL,
Plaintiffs,
vs.
RAYMARK INDUSTRIES,INC., ET AL,
Defendants.
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No. 82-1655-C(A)
ABEX-001.005
ANSWERS AND OBJECTIONS TO PLAINTIFFS' INTERROGATORIES PROPOUNDED TO DEFENDANT,
ABEX CORPORATION
Come now Plaintiffs and submit the following Interrogatories
to Defendant,
Abex Corporation,
to be answered in
writing and signed under oath, in accordance with the Laws in such
cases made and provided: 1. Has Defendant, at any time, engaged in the manufacture
of brakelinings and clutches containing asbestos or asbestos
fibers, and if your answer is in the affirmative, state:
a) Where the brake linings or clutches were manufactured.
b) How long Defendant has manufactured same (give
inclusive dates).
c) Whether Defendant has supplied these brake linings
or clutches to any of the other Defendants since 1960, and when
these transactions took place, where, and the-compensation paid for
the manufactured asbestos containing brake linings or clutches.
d) Whether any warnings, cautions, caveats or directions SCF-ABEX-0050
20. Please state whether or not you ever obtained any knowledge
concerning the likelihood of asbestos inhalation being hazardous
to health, and if so, state when the corporation first became
aware of the hazardous potential of asbestos and its products.-
State how the Defendant first obtained this knowledge and became
so aware of said hazards and from what source this information was
obtained.
ANSWER:
Knowledge of potential asbestos hazards from industrial
type processing of asbestos was basic to the Abex Occupational
Health Program since 1941, upon formation of the Medical Department.
See Response to Interrogatory No. 13.
21. Please state the date when you first notified mechanics
engaged in the application or removal of asbestos containing brake
linings as to the need to wear respirators.
ANSWER:
Abex objects to this Interrogatory on the grounds that
said Interrogatory seeks irrelevant and immaterial information and is
not reasonably calculated to lead to the discoveyr of admissible
evidence. Further, Abex objects on the grounds that said Interrogatory
assumes certain facts not presently in evidence.
22. State whether Defendant has ever published and/or distributed
any brochures, sales literature, pamphlets, bulletins, or other
written materials (aside from any caution labels on containers) of
^ny kind or character that contained any warnings, cautions,
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