I grounds that it is overly broad, vague, ambiguous and unintelli2 gible and this responding defendant does not know to which "use" 3 the plaintiff refers. 4 INTERROGATORY NO. 65: 5 Please state whether this defendant has distributed any 6 catalogs, brochures, pamphlets or other advertising materials 7 regarding its asbestos-containing products between 1930 and 1972. 8 RESPONSE: 9 Yes. 10 INTERROGATORY NO. 86: 11 Does defendant advertise its asbestos-containing products by 12 any media whatsoever. 13 RESPONSE: 14 Yes. 15 INTERROGATORY NO. 87: 16 Please state whether defendant sold any asbestos-containing 17 products to any United States governmental agency between 1930 to 18 1972.

PLAINTIFFS | EXHIBIT [j i^mi.o __ State the name, present business address, and capacity or title of the' individual signing these Interrogatories on behalf of the answerng defendant.

INTERIOR EXTERIOR DECORATION...PROTECTION Jnrerior. of Jewish Synagogue, Council Bluffs, Iowa, painted with Dutch Boy White- lead and Lead Mixing Oil by painting contractor, K.

m ka ttU i..*.

AREA B.

' ' HISTORY OF SHEKTCN-WILLIA1S PRODUCTS ..

/ March IS, 1938 Dr, A* iT* Lanza Assistant Nodical director iYetropolitan Life Insurance Co# He-/?

March 29# 1938 Mr.

January 6, 1938 accept my thanks for a lead In the urine and tissues and excreta* to me and I hope you es which come out on es * ?

Gr a h a m Ed g a r DIRECTOR OF RESEARCH Et h y l Ga s o l in e Co r p o r a t io n Ch k y s l t s r .

Gr a h a m Ed g a r .

April 20, 1932 Re: Employees of Standard Oil Co (Indiana) Detroit, Michigan On Friday April 15, 1932 a large empty storage tank was cleaned hy five employees.

December 2, 1938 Mr. 0. 3.

Cl a im Dk p a r t j ie s t XXXXXXXX E.

March 20, 1936 Dr.