Document veMYzNV3b7y6GEyqbKxnZJqR
05 I 0 I 0 2 3 *
1 ANSWERS
2
Yes.
3
4
3
6 1.11 If the answer to the preceding interrogatory is in
7 the affirmative, state the following:
8 (a) The names of the companies mining,
9 manufacturing, marketing, distributing, rebranding, assembling and/or selling each of
10 those products, and specify whether these companies mined, manufactured, marketed,
11 distributed and/or sold material containing asbestos fibers;
12 (b) The trade or brand name of each of those
13 products mined, manufactured, marketed, distributed and/or sold;
14 (c) The date each of the named products was placed
13 on the market;
16 (d) The date each of the named products was withdrawn from the market;
17 (e) A description of the physical (chemical)
18 composition of each of the named products, including the type and percentage of asbestos
19 contained in each product and the purpose of each ingredient for each year said product was
20 manufactured, sold, distributed, rebranded and/or sold;
21
(f) A description of the physical appearance of each 22 of the named products, including any identifying
color(s), stamp(s), stripe(s), texture, etc. for 23 each year said product was manufactured, sold,
distributed, rebranded and/or sold; 24
(g) The sources of the asbestos ingredients 25 contained in each product;
26 PLAINTIFF'S FIRST INTERROGS, ETC. - 12