Document jyXgX0bJ69j1LQy86QNbGoa5R
11572-1000 MXY/dal
See Answer to Interrogatory No. 89, which is incorporated herein as iffully rewritten. Buyer considers employee medical information to be (or may be) confidential under federal law. Defendant currently is aware ofone unconfirmed statement by a former employee, onNovember 15, 1989, that he thought he had asbestosis. INTERROGATORY NO. 92:
For each employee referenced in your Answer to Interrogatoiy No. 91, state the date that Defendant first knew, or had notice or information, that such past or present employee [who claims he/she] was suffering, or had suffered from:
(a) asbestosis; (b) lung cancer; (c) mesothelioma. ANSWER: See Answer to Interrogatory No. 91, which is incorporated herein as if fully rewritten.
INTERROGATORY NO. 93: Identify any and all material safety data sheets concerning the products listed in response to
Interrogatory Nos. 19 and 42 prepared, at any time, by, or on behalfof, Defendant, any predecessor or any related company. ANSWER:
See Answer to Interrogatory No. 63, which is incorporated herein as if fully rewritten. MSDS's were provided to customers upon request. One document suggests that, in the mid-1980's,
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