Document zQVbG3V6bYyKQbJB48m7RmOQg
c 051010268 C
1 2.14 Do any documents, including written memoranda,
2 specifications, recommendations, blueprints or other written
3 terials of any kind or character relating to the potential health
4 zards of the products listed in Interrogatory No. 1.11 now exist?
5 fVNSWER:
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Yes.
7
e
9 2.15 If the answer to the preceding interrogatory is in
10 the affirmative, state:
11 (a) Name each product;
12 (b) List each document;
13 (c) State the name, address and job title of each
14 person who currently has possession of each document and where it is presently located.
15
ANSWER: See response to Request for Production M. 16
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21 REQUEST FOR PRODUCTION M: Pursuant to CR 34, attach or
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produce according to the above instructions a copy of each such 23
document or test. 24
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26 PLAINTIFF'S FIRST INTERROGS, ETC
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