Document k685xkkZNkEErkykdmG8b6nQV

subject matter of the pending action nor reasonably calculated to lead to the discoveiy of admissible evidence as it relates to Dana. Subject to and without waiving objections, Dana does not know whether Smith & Kanzler Company ever had any distributors or sales representatives of asbestos products in the States of Alabama, Florida, Mississippi, Oregon, Washington, Georgia, Tennessee, Arkansas, Texas and Virginia. INTERROGATORY NO. 18: List each employee (including only physicians and/or hygienists) who has acted in a medical advisory capacity to your company at any time during the past 40 years, including, but not limited to, physicians and industrial hygienists, and the current address, telephone number and job title of each of those individuals and who has, had or may have had any knowledge regarding the hazards of asbestos. ANSWER: See Preliminary Statement and General Objections, which are incorporated herein as if fully rewritten. Further objecting, the interrogatory is overly broad given the parameters and subject matter of this case. Further objecting, the information sought is neither relevant to the subject matter of the pending action nor reasonably calculated to lead to the discoveiy of admissible evidence as it relates to Dana. Further objecting, the phrase "medical advisory capacity" is vague, ambiguous and argumentative. Subject to and without waiving objections, Dana does not know what employees of Smith & Kanzler Company, if any, who acted in a medical advisory, capacity to it at any time during the past 40 years, has, had or may have had any knowledge regarding the hazards of asbestos. INTERROGATORY NO. 19: Does Defendant have in its possession any books, pamphlets, memoranda, or written materials of any kind or character that would indicate that asbestos fibers, when inhaled, can be hazardous to the health of human beings? If so, state: (a) The name of each such publication. (b) The date of publication and the names of the author and publisher (if any). (c) The date received by Defendant, if known. (d) The name, job title, and address of each person who currently has possession of each publication and its present location. DEFENDANTS RESPONSES TO PLAINTIFFS* MASTER INTERROGATORIES F:\KELLY\DISC\DANA.INT PAGE -16-