Document npYx5Qd0v4zV8LGkmzJb3dr2G

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 or any of its subsidiary or predecessor companies or their agents prepared any written or printed material* or instructions of any kind or character indicating how asbestos products should be used and maintained. INTERROGATORY NO. 24: Does Defendant have insurance policies that might cover, the claims made by Plaintiffs in these cases? If so, list the name of each insurance carrier, the amount of initial coverage, amount of coverage remaining at the present time, and the effective dates of each policy. (If property answered, this Interrogatory need not be supplemented as to the remaining amount of coverage). 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. Dana further objects to responding to this interrogatory and relies upon the privilege between an insurer and insured in discussions regarding the defense of any claim or category of claims. Subject to and without waiving objections, Dana is a member of the Center for Claims Resolution. iiiiaIROGATORY NO. 25: As to the disease asbestosis, state: (a) The date on which Defendant or its subsidiary or predecessor first learned that such disease was caused by inhalation of asbestos fibers by humans. (b) How Defendant became aware of the existence of the disease. (c) Who within the company first discovered, recognized or understood the adverse consequences or effects of the disease and/or of asbestos exposure. (d) What information was disseminated within Defendant's company or its subsidiary or predecessor regarding such adverse consequences or effects. DEFENDANT'S RESPONSES TO PLAINTIFFS* MASTER T F:\KELLY\DISC\DANA.INT .ROGATORIES PAGE -20-