Document yr8yQ5ZDEoMNZ3bZJYKj3dwb2
(a) State the dates such library existed;
(b) Identify the person(s) within the corporate structure to whom library employees reported throughout the existence of the library; and,
(c) State the present location of any and all books, documents, and/or materials that were at any time part of said library.
ANSWER: - Gleason objects to this Interrogatory as overly broad, burdensome, harassing, excessive in scope and time and incorrectly implying that its products were a health hazard.
INTERROGATORY NO. 32
Omitted as duplicative of Standing Order #1
Interrogatories
ANSWER:
INTERROGATORY NO. 33 Omitted as duplicative of Standing Order #1
Interrogatories ANSWER:
INTERROGATORY NO. 34
State
the
year
that
Defendant
and/or
any
predecessor/related entity was first advised of either
threshold limit values or maximum allowable concentrations
of both asbestos dust and total dust, promulgated by the
American Conference of Governmental Industrial Hygienists,
and identify the specific person(s) receiving such advise,
and any and all documents communicating such advise. State
whether such threshold limit values or maximum allowable
concentrations referred involved TOTAL dust or just asbestos
GLEASON-000029