Document zQo21mbY9BLxQJyxNn4jmN8eg

C 05 I 0 I 0237 C X 2 ANSWER! (a) By or under the direction of The S. K. Wellman Corp. or Lts predecessors; 3 (b) See response to Request for Production D; (c) See response to Request for Production D; 4 (d) Sales# staff, trade shows, mailings; (e) Unknown. S 6 7 8 9 10 REQUEST FOR PRODUCTION D; Pursuant to CR 34, attach or 11 produce according to the above instructions a copy of each such 12 item of sales or marketing information, including but not limited 13 to books, movies, sales literature, training and/or marketing aids, 14 and an index thereto. 15 RESPONSE: See answer to Request for Production C above, including attachments. 16 17 18 19 1.17 State whether any of your agents, employees, 20 manufacturers, representatives or dealers during the Relevant Tines 21 were instructed to advertise, solicit, sell or otherwise encourage 22 the purchase of your asbestos products or asbestos-containing 23 products for use in motor vehicle brake linings, brake pads or 24 brake facings. 25 26 PLAINTIFF'S FIRST INTERROGS, ETC. - 17