Document pmRRGpdyY4LK4g0bM3x8yOGkE

1 INTERROGATORY NO. 73: 2 Please state whether or not defendant ever maintained a library or collection of medical information pertaining to 3 effects of asbestos upon human health. If so please state: 4 (a) The location of said library or collection, 5 (b) The person(s) who maintained it; 6 (c) The bibliography of medical articles, materials, and ocher reports that are or were a part of said library on 7 said subject, including journals, publications, reports and all memoranda published and received by defendant since 1930. 8 RESPONSE TO INTERROGATORY NO. 73: 9 Wagner has not maintained a library specifically re 10 lating to the effects of asbestos on human health. Articles and 11 other publications on this subject are among the materials main 12 tained by Wagner's labor relations department relating to em 13 ployee health and safety. 14 INTERROGATORY NO. 74: 15 Please state whether or not any governmental agency 16 has ever written letters of warning to defendant pertaining to the likelihood of injury to persons being exposed to asbestos 17 and asbestos-containing products. 18 RESPONSE TO INTERROGATORY NO. 74: 19 No. 20 INTERROGATORY NO. 75: 21 If the answer to the preceding Interrogatory is affir mative, please state the name and address of the agency, the 22 date of the letters of warning and who possesses a copy of said documents. 23 RESPONSE TO INTERROGATORY NO. 75: 24 See Wagner's response to Interrogatory No. 74. 25 INTERROGATORY NO. 76: *26 Please state the date defendant received information 27 pertaining to the association between inhalation of asbestos fibers and the development of cancer and asbestosis. Include in 28 your answer to the preceding the source of said information. 31