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
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lating to the effects of asbestos on human health. Articles and 11
other publications on this subject are among the materials main
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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