Document zzawQjxm2qd5OeGwEOxwVyBZ3

INTERROGATORY NO. 22; Have printed sales materials been prepared by Defendant or any of its subsidiary' or predecessor companies or their agents for purposes of marketing or advertising products containing asbestos? If so, state: (a) The name, address, and job title of each person or entity who prepared such materials. (b) The name, address, and job title of each person who currently has possession of such materials and their present location. (c) The date the materials were prepared. (d) The media used to disseminate the sales materials. ANSWER: See Preliminary Statement and General Objections, which are incorporated herein as if fully rewritten. Subject to and without waiving objections, sales material has been prepared by Dana. The sales material covers a broad range of years. Sales material is available for review by Plaintiffs at the offices of Cooper & Walinski in Toledo, Ohio at a mutually convenient time, and have been inspected by Plaintiffs' counsel. INTERROGATORY NO. 23: *4 Have any written or printed materials or instructions of any kind or character been prepared by Defendant or any of its subsidiary or predecessor companies or their agents indicating how asbestos products should be used and maintained? If so, state: (a) The name, address, and job title of each person who prepared such materials or instructions or assisted in their preparation. (b) The name, address and job title of each person who currently has possession of such materials or instructions and their present location. (c) The dates of distribution or use and the manner in which such materials or instructions were distributed to purchasers of Defendant's products or those of its subsidiaries or predecessors. 19 DEFENDANT'S ANSWERS TO PLAINTIFFS' MASTER INTERROGATORIES AND REQUESTS FOR PRODUCTION