Document zQV8dDzBGz1b0mJnYDoaLdkkz

1 RESPONSE TO INTERROGATORY NO. 82: 2 No. 3 INTERROGATORY NO. 83; 4 Please state the names and addresses of all distribu tors and companies to which the defendant sold or distributed 5 asbestos or asbestos-containing products for the years 1930 to 1972. 6 RESPONSE TO INTERROGATORY NO. 83: 7 Wagner objects to this interrogatory on the grounds 8 that it is overly broad, unduly burdensome, and not calculated 9 to lead to the discovery of admissible evidence and seeks pro 10 prietary business information. 11 INTERROGATORY NO. 84; 12 Please state whether defendant has knowledge of any 13 material which could be or is being used for the same purpose as asbestos. Include in your answer when defendant discovered that 14 said material could be used as a substitute for asbestos. 15 RESPONSE TO INTERROGATORY NO. 84: 16 Metallic and other substances, most combined with 17 asbestos-containing substances, are now being used in brake 18 linings for front disc brake applications on some new vehicles. 19 It was first determined in 1978 that these materials could be 20 used safely for some of the same purposes as asbestos-containing 21 brake lining. However, despite a continuing effort by Wagner, 22 its suppliers, and the friction materials industry to find a 23 substance for asbestos in friction materials, no substance other 24 than asbestos-containing brake lining was available during 25 plaintiff's period of exposure which could produce friction 26 materials that would be safe and conform to applicable safety 27 standards governing brake performance for any drum brake appli- 28 34