Document k9w5NgjB43MMNqJNJ4xBNnaYB

051010270 1 REQUEST FOR PRODUCTION N: Pursuant to CR 34, you are 2 hereby requested to produce according to the above instructions a 3 copy of all documents pertaining to design changes as identified in 4 your response to the preceding interrogatory. 5 RESPONSE: N/A 6 7 8 9 SECTION 3.0 10 11 3.01 Did you provide instructions and/or warnings 12 concerning the potential health hazards of asbestos exposure to 13 plaintiff's employer Stewart-Western, Inc. or Western Brake Ind. 14 Company at any time? 15 16 A--N--S--W---E--R- ' No. S. K. Wellman has no record of any sale of products to the listed companies. 17 18 19 20 3.02 If the answer to the preceding interrogatory is in 21 the affirmative,- state the following: 22 (a) Whether the employer was expected or requested to transfer the instructions and/or warnings to 23 its employees such as plaintiff; 24 (b) The date(s) you provided instructions and/or warnings to plaintiff's employer; 25 26 PLAINTIFF'S FIRST INTERROGS, ETC. 48