Document reNxyrngq5ooBod36a08rNBdG

(a) The date on which Defendant or its subsidiary or predecessor first learned that such disease was caused by inhalation of asbestos fibers by humans. (b) How Defendant became aware of the existence of the disease. (c) Who within the company first discovered, recognized or understood the adverse consequences or effects of the disease and/or of asbestos exposure. (d) What information was disseminated within Defendant's company or its subsidiary or predecessor regarding such adverse consequences or effects. (e) Whether any such information is still maintained by Defendant or its subsidiary or predecessor in any written form. (f) Who is the custodian of such information. (g) The date on which you first received knowledge or information that asbestosis was caused by inhalation of asbestos fibers. ANSWER: Defendant objects to Interrogatory No. 25 to the extent it refers to and inquires of a "predecessor" without identifying such or providing a definition of such. -Further,-for Defendant to identify a predecessor would involve a legal conclusion for which there is no factual basis or foundation. Further, the interrogatory is argumentative, implying that the asbestos-containing products pose the same risk as free asbestos fibers and assumes facts not in evidence regarding asbestos. Moreover, the interrogatory calls for medical conclusions, seeks irrelevant and immaterial information and is not reasonably calculated to lead to the discovery of admissible evidence. The interrogatory also inquires of the knowledge of several hundreds of thousands employees, past and current and, therefore, imposes an undue burden upon Defendant. Further, the interrogatory requests information which goes well beyond the standard of knowledge or care required of GM under Texas law in that it requests information regarding circumstances which have no applicability to the types of products manufactured by this Defendant or the circumstances reasonably anticipated for users of this Defendant's product. Finally, the interrogatory seeks information which is protected by the attorney work product. MM\CABU00M3.J 1/21/9$ 29