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: 6 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 17 18 19 20 21 REQUEST FOR PRODUCTION M: Pursuant to CR 34, attach or 22 produce according to the above instructions a copy of each such 23 document or test. 24 25 26 PLAINTIFF'S FIRST INTERROGS, ETC 46