Document pVEYd3Z4Jkn9wRknzbx9rkbD

c osmoao.'C 1j RESPONSE: Adiutted. 5 6 4.12 Was defendant ever involved in a suit or claim by an 7 individual (or a union on behalf of an individual) instituted to 8 gain access to the medical or exposure records of defendant's 91 j employees? 10 ii ANSWER: 11 ------------- 1 No. 12'! is!! it 14 15 4.13 If the answer to the foregoing interrogatory is in 16 the affirmative, state: 17 18 , l: 19 1' ii 20 'i (a) When such a suit occurred; (b) The attorneys involved in representing each party, together with the cause number and court where filed; (o4 The individual and/or union involved; 21 22 I1 Ii 23 ! 24 I. (d) The nature of the medical records in question; (e) Identify the custodian (by name, address and position) of records relating to the above subject. 25 26 1 PLAINTIFF'S FIRST INTERROGS. ETC. - 81