Document zbQJm18LxwqGBazRdkwxBKKV6

Automotive Parts Division 11045 Gage Avenue Franklin Park, IL (1965-1981) and 1130 S. Canal Street and 6 North Michigan Ave Chicago, IL (1965) < INTERROGATORY NO. 6 For each facility identified in your Answer to Interrogatory No. 5, identify all officers, employees or agents (corporate level or plant level) employed by you or any predecessor/related entity from 1920 to date in a management or upper-level supervisory position (including upperlevel assistants or associates) having responsibility in the following areas, and identify die dates which each person served in the following capacities: (a) occupational health or safety; (b) construction health or safety; (c) compliance with federal, state, or local safety regulations (including but not limited to OSHA); (d) compliance with federal, state, or local environmental regulations; (e) compliance with federal, state, or local health regulations (including but not limited to OSHA); (f) industrial hygiene; (g) insurance or risk management; (h) worker's compensation; medical director, (i) physician, nurse, health technician; (j) personnel/human resources; (k) the manufacture, sale, distribution, purchase, possession, application, installation, or use of asbestos (including raw asbestos) or asbestos-containing products/materials; (l) purchasing of supplies, tools, equipment; and (m) the design, or preparation of manufacturing specifications for asbestos-containing products/materials. ANSWER TO INTERROGATORY NO. 6: Borg-Wamer objects to this Interrogatory as overly broad and burdensome, dealing with extensive and varied operations covering a broad period oftime. 7