Document gaMvY5JazZG8pX6DakN4ag5qe

os 10 t 024 I 1 (d) The dates (years) defendant or any of its 2 subsidiary companies purchased or obtained such brake lining(s) or brake pad(s) from each 3 manufacturer, distributor and/or seller, and the amounts expressed in pounds or tons which 4 defendant or any of its subsidiary companies purchased or otherwise obtained; 5 (e) The type and percentage of asbestos contained in 6 each trade or brand named brake lining or brake pad identified above which you obtained from 7 1950 through 1978; 8 (f) The physical characteristics of each kind of brake lining, brake pad or brake facing 9 purchased or used by defendant or defendant's subsidiaries for use in vehicles manufactured or 10 sold by you, including size, dimensions, weight, color, identifying tags, stamps or markings on 11 said brake liners, pads or facings; 12 (g) The name, last known address and telephone address of defendant's or defendant's 13 subsidiaries' purchasing agent(s) responsible for obtaining brake linings and brake pads for 14 use in any motor vehicles manufactured or sold by you from 1950 through 1978; 15 (h) During the time period 1950 through 1978, did 16 you maintain records relating to the purchase, sale and/or use of brake linings, brake pads or 17 disc brake pads, including, but not limited to, records which indicate what brake linings were 18 installed or to be installed on particular types or models of defendant's motor vehicles. 19 20 (i) Describe all such records referred to in subsection (h) above; 21 * (j) Identify (by manufacturer, trade name, number 22 and brand name) what brake linings, brake pads ^ or brake facings were installed, assembled, 23 placed in or otherwise used or furnished in each of the motor vehicles you manufactured, sold or 24 distributed for the period 1950 through 1978. 25 26 PLAINTIFF'S FIRST INTERROGS, ETC. 21