Document ppmwrm94EX7pXGqyqKB982LKd

1 ery of admissible evidence, and seeks confidential business 2 information which consists of trade secrets. 3 INTERROGATORY NO. 88: 4 Please state whether or not defendant's automotive repair employees, in the course of reparing automobiles, use or 5 have used routers, saws, sanders, grinders, or any type device to shape, form, cut or fabricate asbestos-containing material. 6 RESPONSE TO INTERROGATORY NO. 98: 7 Wagner is not involved in providing automotive repair 8 services. 9 INTERROGATORY NO. 89: 10 If the answer to Interrogatory No. 88 above is affir 11 mative, please state whether any vacuum systems, dust control devices, watering-down systems, or any systems designated to 12 reduce dust m the air were at any time used by defendant's automobile repair employees. 13 RESPONSE TO INTERROGATORY NO. 89: 14 See Wagner's response to interrogatory No. 88. 15 INTERROGATORY NO. 90: 16 If the answer to Interrogatory No. 89 above is affir 17 mative, please state: 18 (a) The date that such a device was first list ed; 19 (b) The type of system or device used; 20 (c) Whether such a system is presently used by 21 defendants' automobile repair employees. 22 RESPONSE TO INTERROGATORY NO. 90: 23 See Wagner's response to Interrogatory No. 89. 24 INTERROGATORY NO. 91: 25 Please state the name and address of any brake and/or clutch repair facility owned and operated by defendant between 26 the years 1930 and 1983. 27 RESPONSE TO INTERROGATORY NO. 91: 28 None. 36