Document zQ2mE2XRaOX14GrZEoZM7Q2R7

ANSWER: See Preliminary Statement and General Objections, which are incorporated herein as if fully rewritten. Further objecting, the interrogatory is overly broad given the parameters and subject matter of this case. Further objecting, the information sought is neither relevant to the subject matter of the pending action nor reasonably calculated to lead to the discovery of admissible evidence as it relates to Dana. Subject to and without waiving objections, Dana does not know whether Smith & Kanzler Company or its subsidiaries or predecessors ever conducted or caused to be conducted any studies designed to assist in minimizing or eliminating the inhalation of asbestos dust and fibers by those exposed to the use of its products. INTERROGATORY NO. 48: Does your company have, has it ever had, or have your predecessor^) or subsidiaries ever bad, a Research Department? If so, give the year such Research Department was established, and whether or not such Research Department has operated continuously since being established. State also: (a) The amount of time and money expended-each year on research concerning asbestos or asbestos-containing products? s (b) What percentage of gross sales did your company or its predecessors) spend on research concerning the health effects of asbestos? (c) State in detail the purposes, duties, and responsibilities of such Research Department. ANSWER: See Preliminary Statement and General Objections, which are incorporated herein as if fully rewritten. Further objecting, the interrogatory is overly broad given the parameters and subject matter of this case. Further objecting, the information sought is neither relevant to the subject matter of the pending action nor reasonably calculated to lead to the discovery of admissible evidence as it relates to Dana. Subject to and without waiving objections, Dana does not know whether Smith & Kanzler Company has or ever had or whether its predecessors) or subsidiaries ever had a Research Department. However, Dana also believes that Smith & Kanzler Company did employ an individual known as the director of research, that being Maurice Lieff. Dana also believes that Mr. Lieff is now deceased. DEFENDANT'S RESPONSES TO PLAINTIFFS* MASTER HkiMalSGATORIES F:\KELLY\DISC\DANA-INT PAGE -37-