Document kaEyx3pLVOavO5xo1pBVb7ZZB

INTERROGATORY NO. 49: Does your company have, or has it ever had, or have your predecessors) or subsidiaries ever had, a Medical Department? If so, state: (a) The year such Medical Department was established; (b) Whether or not such Medical Department has operated continuously since being established; (c) The name of each director, chief, or head of your Medical Department year by year, beginning with the first year you had a Medical Director or Medical Department, and the last known address and phone number of each; (d) State die duties and responsibilities of such Medical Department. 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 die pending action nor reasonably calculated to lead to the discovery of admissible evidence as it relates to Dana. Subject to and without waiving objections, Dana does not know whether Smith & Kanzler Company has or ever had or whether its predecessors) or subsidiaries ever had a Medical Department. INTERROGATORY NO. 50: Did your company or its predecessors) or subsidiaries ever place any warning direedy on any of its asbestos-containing product or on their packaging. If so, identify the product(s) and year said warning was first applied. ANSWER: & 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 discovery of admissible evidence as it relates to Dana. Subject to and without waiving objections, Dana does not know whether Smith & Kanzler Company has or ever had or whether its predecessors) or subsidiaries ever placed any warning direedy on any of its asbestos-containing products or on their packaging. DEFENDANTS RESPONSES TO PLAINTIFFy MASTER INTERROGATORIES F:\KELLY\D1SC\DANA.INT PAGE -38-