Document jNDmnpEdBD8zQn3v2Y3pBn0nQ

1 subparts (a) through (f) on the grounds that the information 2 requested has been provided in response to preceding interroga 3 tories, namely Interrogatory Nos. 3, 4, 9, 10, et seq. Addition 4 ally, defendant does not manufacture brake assemblies. 5 INTERROGATORY NO. 119; 6 At any time during the period 1948 to 1978, did defendant 7 distribute automobile brake linings or brake assemblies? If so, 8 please state: 9 v (a) The trade or brand name(s) under which the brake 10 linings or brake assemblies were marketed; 11 (b) The years during which the brake linings or brake 12 assemblies, under each trade or brand name, were manufactured; 13 (c) The date each product was withdrawn from the mar 14 ket, if such is the case; 15 (d) The quantitative percentage of each chemical com 16 ponent of the brake linings under each trade or brand name; 17 (e) If asbestos was included in the composition of the 18 brake linings which defendant manufactured under any trade or 19 brand name, please state: 20 (i) The type of asbestos fiber (i.e., amosite, 21 chrysotile, crocidolite) used in the brake linings under each 22 trade or brand name; 23 (ii) The quantitative percentage of asbestos fiber 24 used in the brake linings under each trade or brand name; 25 (iii) The years during which asbestos fiber was 26 included in the composition of the brake linings under each trade 27 or brand name; NZO 23 III 'AD 16-