Document zQvQM8Ovwq174Voa0kpmg6B23

05 I 0 I 026? C 1 2.04 Do any documents, including written memoranda, 2 ipecifications, recommendations, blueprints or other written 3 laterials of any kind or character relating to the design and 4 >reparation of the asbestos products listed in Interrogatory No. S ..11 now exist? 6 ANSWER: 7 Yes. a 9 2.05 If the answer to the preceding interrogatory is in 10 affirmative: 11 (a) List each document; 12 (b) State the name, address and job title of each 13 person who currently has possession of each document, and where the documents are presently 14 located. 15 NSWER: (a) irrelevant objection--overly broad, vague, burdensome; (b) J. E. Mencini is designated custodian in Bedford, Ohio; 16 Ed Stanek is designated custodian in Nashville, Tennessee. 17 18 19 20 21 NTIFF'S FIRST INTERROGS, ETC 41