Document zow68gooX70mGNy7YjJj8wp0z

Interrogatory for any products not claimed to have contributed to the alleged injuries of the Plaintiffs. Without waiving its objections, Westingbouse states that upon information and belief; it has never rebranded any product for sale. Westingbouse further states that many of its products were sold to distributors. If the plaintiffs will identify the distributors, Westingbouse will investigate any distribution arrangements it may have had with those entities. 14. What is the name, address and job title of each individual who participated in the design and preparation of manufacturing specifications for each such products listed above in answer to Interrogatory No. 5? ANSWER: Westingbouse incorporates by reference its Preliminary Statement and General Objections. Westingbouse further objects to responding to this Interrogatory concerning any products not alleged to have contributed to the alleged injuries of plaintiffs), on the grounds that the Interrogatory, as applied to Westingbouse, is overly broad and unduly burdensome and seeks information which is irrelevant and immaterial to these proceedings and is not reasonably calculated to lead to the discovery of admissible evidence. If a particular plaintiff will specifically and credibly identify the Westingbouse product(s) alleged to have given off respirable asbestos fibers in his or her presence, Westingbouse will endeavor to answer this Interrogatory for such produces), if any, to the extent Westingbouse reasonably can do so. 15. As to each product listed in response to Interrogatory No. 5, please describe how each product was to be cut, shaped, scribed, mixed and applied on the job. (In answering this question, give particular reference as to whether or not the materials were to be sawed or cut on the job, blown into confined areas, mixed with water in a cement or paste.) ANSWER: Westingbouse incorporates by reference its Preliminary Statement and General Objections. Westingbouse further objects to responding to this 18