Document gzxXeokVYYN3zJ2zLZDrdmBJ

051010309 1 REQUEST FOR ADMISSION EE: You conducted or caused to be 2 conducted no tests before 1970 on your products containing asbestos 3 to determine whether asbestos or asbestos particles might be 4 harmful to human beings if inhaled. 9 : RESPONSE; Admitted. 6 7 8 9 10 4.16 State in detail when you first became aware of the 11 existence of articles on the subject of the relationship between 12 asbestos exposure and 13 (a) asbestosis; 14 (b) lung cancer; 15 (c) mesothelioma; 16 17 (d) forms of cancer other than lung cancer. 18 | ANSWER: s. K. Wellran is aware of such articles, but cannot identify when knowledge of such articles first came to the attention of its employees. 19 !. I' 20 1 i; 22 23 4.17 For each disease mentioned in subparts a through d of 24 | the preceding interrogatory, state in what manner you gained 25 awareness of each. 26 : PLAINTIFF'S FIRST INTERROGS, ETC. - 87