Document oMy4gZ8VoY4Kbv0eDxdENMOer
11572-1000 MXY/dal
See Answer to Interrogatory No. 43, which is incorporated herein as iffully rewritten. Test results were very good and no design changes were recommended as a result ofthe tests.
INTERROGATORY NO. 46: If your Answer to Interrogatory No. 45 is "yes," with respect to each such recommended
design change: (a) State the product or products involved; (b) State the test or tests involved; (c) State the nature of the change recommended; (d) Identify the person(s) making the recommendation; (e) State the nature and effective date of any change made; and (f) Identify each and every person who participated in the decision to make or not make the recommended design change.
ANSWER: See Answers to Interrogatory Nos. 43,44 and 45, which are incorporated herein as if fully
rewritten. INTERROGATORY NO. 47:
Identify any and all persons employed by Defendant, its predecessor or related company at any time from 1940 to date as an industrial hygienist or in a similar position. ANSWER:
Warner Electric Brake & Clutch Company did not "employ" physicians, medical directors or industrial hygienists. Rather, Warner Electric Brake & Clutch Company used a private physician
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