Document joO9rLe53OeaeoJdKVp9vaZQ
1 RESPONSE:
2 Not applicable. 3 INTERROGATORY NO. 104:
4 Please state whether the defendant entered into any agree
5 ments with any British or German concerns which manufactured
6 asbestos-containing products from 1930 to 1972.
7 RESPONSE:
8
OBJECTION
Interrogatory No. 104 is objected to on the
9 grounds..that it is overly broad, vague, ambiguous and unintelli
10 gible with respect to the use of the undefined term "agreements."
11 As presently framed, this defendant cannot respond to the inter
12 rogatory. 13 INTERROGATORY NO. 105:
14 If the answer to the above interrogatory is affirmative,
15 please list:
16 (a) The name, address and phone number of each such
17 British or German concern;
18 (b) The year the agreement was entered into and the
19 date said agreement terminated;
20 (c) The products exchanged or involved in said agree
21 ment, including:
22
(i)
The percent composition of asbestos;
23
(ii)
The intended use of the product;
24 (iii) Whether the products were marketed in the
25 United States.
26 RESPONSE:
27 Not applicable, given the objection to Interrogatory No.
NZO
28 104.
ARO l*6i
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