Document jNzBY2nXjxV7Q81O45eq2JmKQ
1 (g) Volkswagon;
(h) British Leyland;
2 (i) Sears & Roebuck.
3 RESPONSE TO INTERROGATORY NO. 123:
4 No.
5 INTERROGATORYNO. 124:
6 If the answer to any part of Interrogatory No. 123 is
affirmative, please state:
7
(a) the identities of each manufacturer or dis
8 tributor and the above-named entity which received the
automobile brake linings or brake assemblies;
9
(b) the date(s) of each shipment, sale or dis 10 tribution of automobile brake linings or brake assem
blies for which defendant has data or information; 11
<c) the quantity and type, including trade or
12 brand name, of the automobile brake linings or brake
assemblies shipped, sold or distributed to each of the
13 above-named entities;
14 (d) identify each person within defendant's
company having knowledge of sales and distributions to
15 each entity.
16 RESPONSE TO INTERROGATORY NO. 124:
17 See Wagner's response to Interrogatory No. 123.
18 INTERROGATORY NO. 125:
19 At any time during the period 1948 to 1978, did defen
dant manufacture automobile body filler. If so, please state:
20
(a) the trade or brand name(s) under which the
21 automobile body filler were marketed;
22 (b) the years during which the automobile body
filler, under each trade or brand name, was manufac
23 tured;
24 (c) the date each product was withdrawn from the
market, if such is the case;
25
(d) the quantitative percentage of each chemical
26 component of the automobile body filler manufactured
under each trade or brand name;
27
28
48