Document vVyDoZjm3MVGyjrGE7RDRJM5m
c 05 I 0 I 028eC
' : irrelevant objection.
3.28 For each and every year since 1930 to the present,
j| state the number of such suits which were served upon you.
9 <; !i ANSWER: See
10 j|
i
p
11 ]
answer to
3.16,
and
to years
after
1981,
irrelevant objection.
I
12 :
i
13
14 t,*! 3.29 Do you retain records of the worker's compensation or
15 third party claims described in the foregoing interrogatories?
16 ANSWER: Yes
17
18 19
20
3.30 Identify with name and address the corporate 21
custodian of records concerning claims of workers. 22
23
24
25 1
26 "PLAINTIFF'S FIRST INTERROGS, ETC. - 63