Document ppwRwJVZvBO1MVgyRe0Vw7pja

K8895DIA058 INTERROGATORY NO. 103: If your answer to Interrogatory No. 102 is "Yes": (a) Identify any and all documents received by Defendant, its predecessors), or a related company referring to, relating to or reflecting any findings or results ofthose studies or tests, and state the date upon which each was first received; (b) Identify any and all communications (oral or written), between Defendant, its predecessor(s) or a related company and Saranac personnel, including but not limited to Gerrit W.H. Schepers, M.D.; (c) Identify any and all documents referring to, relating to or reflecting the Saranac studies received or submitted by Defendant, its predecessor(s) or a related company either directly, through related or predecessor companies, through other companies, or through any trade associations, organizations or other entities; and (d) Identify any and all documents referring to, relating to or reflecting recommendations or findings of such studies relating to: (1) Adequacy or inadequacy of threshold limit values; (2) Substitution of materials other than asbestos to be used in the insulation process. ANSWER TO INTERROGATORY 103. Not applicable. INTERROGATORY NO. 104: With respect to each subject listed below, state whether said subject was, at any time, discussed at a meeting of the board of directors of Defendant, any predecessor or any related company: (a) The sale and/or marketing ofany asbestos-containing product, including, but not limited to, the products listed in response to Interrogatory Nos. 19 and 42; (b) The health hazards resulting from exposure to asbestos, including, but not limited to, exposure resulting from the use, application or removal of asbestos-containing products; (c) The placement or possible placement ofwarning labels on asbestos containing products or their packages, or in sales literature, therefore including, but not limited to, the products listed in response to Interrogatory Nos. 19 and 42; and (d) Any test, survey, study or similar matter concerning asbestos or asbestos containing products, including, but not limited to, the products listed in response to Interrogatory Nos. 19 and 42. ANSWER TO INTERROGATORY 104.