Document qdNL547132qJ8xXj6EK47OyKx
05101028'
1 ANSWER:
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irrelevant objection.
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7 3.23 For each and every year since 1930 to the present,
8 state the number of such suits which were served upon you.
9 * See answer to 3.16, and to years after 1981, irrelevant objection.
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14 3.29 Do you retain records of the worker's compensation or
13 third party claims described in the foregoing interrogatories?
16 ANSWER: yes>
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3.30 Identify with name and address the corporate 21
custodian of records concerning claims of workers. 22
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26 PLAINTIFF'S FIRST INTERROGS, ETC. - 63