Document kMYNpwDMQezZyEJeEO73v7pb

''I 1 responds that it has records regarding sales dating back to 1976, 2 but no summary, compilation or abstract currently exists. Defen 3 dant is in the process of attempting to abstract the sales re 4 cords which do exist, which it contemplates will be accomplished 5 by late 1984. 6 INTERROGATORY NO. 22: 7 If the answer to Interrogatory No. 21 is affirmative, please 8 state: 9 v (a) The name, address and job classification of each 10 individual who currently has possession of such 11 records ; 12 (b) The names of each defendant named herein to whom 13 your products have been sold or distributed; 14 (c) The dates of each such sale; 15 (d) The amount and type of materials sold or distrib 16 uted; 17 (e) Whether defendant manufactured asbestos-containing 18 products for any other business entity but placed 19 labels or logos not belonging to said defendant on said 20 products; and 21 (f) If response to (e) above is in the affirmative, 22 list each such business entity referred to said subsec 23 tion (sic). 24 RESPONSE: 25 OBJECTION. Interrogatory No. 22 is objected to on the 26 grounds set forth in response to Interrogatory No. 21. The in 27 terrogatory is further objected to on the grounds that it seeks a NZO ON 28 compilation or abstract of records which does not exist. ARO Itoi -15-