Document w8BbN7D8jmj6YZ0EgQvvjDGB

K8895DIA058 hygiene division thereof, subscribed from 1940 to the present, and for each periodical state the dates of such subscriptions. ANSWER TO INTERROGATORY 51. Borg-Wamer has no documents responsive to this interrogatory. INTERROGATORY NO. 52: Has Defendant, any predecessor or any related company, at any time since 1940: (a) been a member of a medical and/or scientific library or library association? (b) been a member ofany organization or association which maintained a medical and/or scientific library? (c) been a member of any organization or association through which members obtained the use of, or access to, a medical and/or scientific library? ANSWER TO INTERROGATORY 52. Not to this defendant's knowledge. INTERROGATORY NO. 53: Ifyour answer to any subpart ofInterrogatory No. 52 is "Yes" (a) Identify the library(ies) involved and state the years during which Defendant, its predecessor or related company was a member of, or otherwise had use of or access to said library; and (b) If applicable, identify the organization or association through which Defendant, its predecessor or related company, obtained the use of or access to, such library(ies). ANSWER TO INTERROGATORY 53. Not applicable. INTERROGATORY NO. 54: Has Defendant, any predecessor or any related company, or any person or entity acting on behalf thereof, including but not limited to, any insurance company, at any time, conducted any industrial hygiene surveys concerning any product identified in response to Interrogatory No. 19, including, but not limited to, surveys concerning the manufacture, processing, application, installation, use and/or removal ofsaid products? ANSWER TO INTERROGATORY 54.