Document r6qOnowvpQm6j9Gj21NNM8L8a

"a 1 INTERROGATORY NO. 122: 2 If the answer to any part of Interrogatory No. 123 is af 3 firmative, please: 4 (a) State the date(s) during which defendant's automo 5 bile brake linings or brake assemblies were sold or distributed 6 to each entity; 7 (b) State the quantity and type, including trade or 8 brand name, of defendant's automobile brake linings or brake 9 assemblies sold or distributed to each entity; 10 (c) Identify and produce all documents relating to the 11 sale of defendant's automobile brake linings or brake assemblies 12 to each entity; 13 (d) Identify each person within defendant's company 14 having knowledge of sales and distributions to each entity. 15 RESPONSE: 16 Initially defendant assumes for purposes of this respoonse 17 that a typographical error exists in referencing Interrogatory 18 No- "123" rather than "121." Assuming No. "121" was meant to be 19 referenced, defendant objects to the interrogatory on the grounds 20 that it is overly broad, burdensome, oppressive, vexatious and 21 harassing and seeks a compilation of records which does not 22 exist. This defendant has records pertaining to sales dating 23 back only to 1976. Without waiving said objection, and in the 24 spirit of liberal discovery, defendant responds that at the 25 present time, based upon the data that it has been able to 26 reconstruct from past years, it supplied original equipment brake 27 linings as- indicated below. The information provided is subject 28 to revision as further information should become available. oO -59-