Document mBKe5jmnnOjE40RYjYaMV8kBk

(c) Please produce all documents upon which your responses above are based; (d) Please identify the nazne(s) and address(es) of any person(s) who can verify your above response; (e) Did Defendant ever rely on the Fleischer-Drinker Report in whole or in part as a basis that Defendant's asbestos products could be used in the workplace without risk of asbestos-related health impacts to the consumer and/or bystander; (0 If so, please produce every document which evidences in any way that Defendant relied on the Fleischer-Drinker Report in whole or in part for the proposition stated in Interrogatory No. 63(a) above; (g) If your answer to 63(e) is yes, when was the first date Defendant relied on the Fleischer-Drinker report in whole or in part for the proposition stated in 63(e) above? iKOa. 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 die 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 when, if ever. Smith & Kanzler Company or any of its predecessors-in-interest first received a copy of the article entitled "A Health Survey of Pipe Covering Operations in Constructing Naval Vessels", published in January, 1946 in the Journal of Industrial Hygiene & Toxicology, and authored by W. Fleischer and P. Drinker, et al. ("the Fleischer-Drinker Report"). INTERROGATORY NO. 64: When, if ever, did Defendant or any of its predecessors-in-interest first receive a copy of the article entitled "A Study of Asbestos in the Asbestos Textile Industry", published in 1938 in Public Health Bill, No. 241, U.S. Public Health Service and authored by W. (c) Dreessen ("the Dreessen Report")? (a) Identify the name and position of the employee or officer who received same; (b) Please produce all documents generated by Defendant which discuss or in any way reference the "Dreessen" study prior to 1968; DEFENDANTS RESPONSES TO PLAINTIFFS* MASTER INTERROGATORIES F:\KELLY\DISC\DANA.INT PAGE -46-