Document vVdLxY7xJK4p5J5qZajzq29E9

?ftO<?ATQRXm 41; Was each of your asbestos products generally expected to reach, or packaged to reach, the consumer or user, without substantial change in the condition in which it was sold? If not, with respect to any such product, explain in what way the Defendant claims its products were altered or substantially changed after sale or distribution and before reaching the user. ANSWER: See Preliminary Statement and General Objections, which are incorporated herein as if fully rewritten. Further objecting, the interrogatory is overly broad given the parameters and subject matter of this case. Further objecting, the information sought is neither relevant to the subject matter of the pending action nor reasonably calculated to lead to the discovery of admissible evidence as it relates to Dana. Subject to and without waiving objections, Dana does not know whether each of Smith & Kanzler Company's asbestos products generally were expected to reach, or packaged to reach, the consumer or user, without substantial change in the condition in which it was sold, except to the extent identified in response to Interrogatory 6(e). INTERROGATORYJMO._42: For each asbestos-containing product identified in response to Interrogatory No. 6, identify all foreseeable users such as insulators, helpers, pipefitters, welders, machinists, plasterers, drywall finishers, carpenters, boilermakers, shipwrights and riggers, etc. of any of Defendant's asbestos-containing products. ANSWER: See Preliminary Statement and General Objections, which are incorporated herein as if fully rewritten. Further objecting, the interrogatory is overly broad given the parameters and subject matter of this case. Further objecting, the information sought is neither relevant to the subject matter of the pending action nor reasonably calculated to lead to the discovery of admissible evidence as it relates to Dana. Subject to and without waiving objections, Dana does not know who were Smith & Kanzler Company's foreseeable users such as insulators, helpers, pipefitters, welders, machinists, plasterers, drywall finishers, carpenters, boilermakers, shipwright and riggers, etc. of any of its asbestos-containing products. Dana does know a product and its use, responses to Interrogatory Nos. 4, and 6(i). DEFENDANT'S RESPONSES TO PLAINTIFFS' MASTER INTERROGATORIES F:\KELLYVDISCVDANA.INT PAGE -34-