Document ykzQ5R61aw4d9eMzEJ89zzGqE

0510102** 1 1.23 If the answer to the preceding interrogatory is 2 affirmative, state: 3 (a) Into which states of the United States of 4 American such product has been distributed; 3 (b) The quantity distributed into each state of the U. S. for every year of the Relevant Times; (c) The name and address of each company or other ' II 7/ i,1 business entity, in the states of Washington, and Oregon to which such product has been 8 distributed and the dates of the distribution- 9 ANSWER: (a) Irrelevant objection--however, S. K. Wellman believes its products were distributed in the state of Washington; 10 (b) Unknown; (c) Release of customer lists is objected to as privileged 11 and proprietary. There is, however, no record of any materials sold to the Western Brake Co. There is a recollection of sales of metallic 12 friction material to Western Brake ending some time in the early 1970s 13 14 15 16 17 18 Ii:: ij 19 !, 20 !Hl|! 21 i> i 22 December 1.24 During the time period from January 1, 31, 1978, have you, directly or indirectly, 1950 through sold. 0J\ I!! distributed, delivered, installed or consigned any asbestos !| 24 ! products for use in brake renovation and repair such as brake 25 ' 26 I PLAINTIFF'S FIRST INTERROGS, ETC. - 24