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.
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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.
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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