Document qRgD51R8d8dMaK9N56Zw37eG
c 05 I 0 I 03 I I C
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REQUEST FOR ADMISSION FF: You were aware as early as 1900
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of research, studies and/or articles indicating a causal connection
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between asbestos exposure and
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(a) asbestosis;
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(b) lung cancer;
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(c) mesothelioma;
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(d) forms of cancer other than lung cancer.
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;i RESPONSE:
Denied.
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REQUEST FOR research, studies
ADMISSION GG: You were aware as early as 1910 and/or articles indicating a causal connection
between asbestos exposure and 15
(a) asbestosis; 16
17 (b) lung cancer;
18 (c) mesothelioma;
19 (d) forms of cancer other than lung cancer.
20 RESPONSE s Denied.
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26 PLAINTIFF'S FIRST INTERROGS, ETC. - 89