plaintiffs exhibit 1 2 3 4 5 6 7 8 CALIFORNIA SUPERIOR COURT 9 CITY AND COUNTY OF SAN FRANCISCO 10 11 IN RE: ) ) 12 COMPLEX ASBESTOS LITIGATION ) ) 13 ) -------------------------------------------------------------------------------- ) 14 NO. 828684 PLAINTIFFS' STANDARD INTERROGATORIES TO ALL DEFENDANTS 15 PREFACE 16 These Interrogatories are to be answered pursuant to San Francisco Superior Court General 17 Order No. 129. 18 Unless otherwise specifically set forth, the time frame for response to these Interrogatories is 19 from 1930 until 1985; except where otherwise specifically set forth, each Interrogatory and each 20 Response are intended and should be construed as including and being limited to such time frame. 21 Where expressly stated with reference to the date and circumstances justifying use of such date, the 22 responding party may limit any such response to dates subsequent to 1930, but which in no event 23 are later than the inception of the responding party, including the inception of any predecessor in 24 interest. 25 Unless otherwise specifically set forth, the geographic scope for response to these 26 Interrogatories by domestic corporations is the United States.

*' N WKR/TB/HOS/lff W3/TP 2nd October 1939 "Silicosis and Aabestosls" by various authors.

\ HOME OFFICE Feb., 1935 r 1 irr O EXHIBIT UC-1295 MEMORANDUM ON THE INDUSTRIAL DISEASES OF SILICOSIS AND ASBESTOSIS Crown Copyright Reserved \ \ LONDON PRINTED AND PUBLISHED BY HIS MAJESTY'S STATIONERY OFFICE To be purchased directly from H.M.

C r ' PTTLMONARY ASBESTOSIS HI: CARCINOMA OP LUNG W?

Progress report* - Xjlj 5, 1937 April 13, 1333 Dacasbar 3, 1333 D*c*aaor 14, 1339 Saveabar 30, 1940 Dacaobar 4, 1340 Proposed, tfaoogrtph. -- ?

(c) The method used to distribute the warning etc. to persons who are likely to use or be in contact with the products.

51.

c 0 5 I 0 I 02 8 * 1 VNSWER: 2 Irrelevant objection. 3 4 S 6 7 3.25 For each and every year from 1930 to the present, 8 state the number of such suits which were served upon you. 9 ANSWER: Ncyjg until 1981, and the number of suits after 1981, irrelevant objection. 10 11 12 13 14 3.26 When was defendant first served with a summons and 13 complaint in which it was then or later alleged that a plaintiff or 16 plaintiff's decedent sustained asbestosis as a result of exposure 17 to asbestos products manufactured, distributed or incorporated into 18 products manufactured or distributed by you?

ME 33fl THE BENDIX CORPORATION MARSHALL ECLIPSE DIVISION TROY, NEW YORK FORD WTR FIELD ACT P 0 hOX 20 LIVONIA MX 401^1 SHIPPED TO FORD MTft VAL Dl-.P SLRV OPCK RTE 130 RENNSAUKM hIJ OollO CLEVELAND, TENM, CUSTOMER ACCOUNT NO. ooioo PLEASE REMIT TO: P. 0.

1 (d) Review governmental publications of Great Britain to determine whether the Chief Inspector of Factories or any 2 other British Government agency had issued any regulations or published any findings relative to potential health hazards 3 incident to the use of products containing asbestos. 4 RESPONSE TO INTERROGATORY NO. 55: 5 No, to the best of Wagner's knowledge. 6 INTERROGATORY NO. 56: 7 Has the defendant sponsored, since 1930, any meetings, seminars, conferences, or conventions where the subject of occu 8 pational health and/or exposure to asbestos was discussed?

; j.

STATE OP FLORIDA COUNTY OP AFFIDAVIT OF PHILIP E.

Re: Industrial Medicine I've spent three days reviewing back issues from 1936, 1938, 1939,1942, 1949, and part of 1943, probably 3000-3500 pp. 1.

August 30, I960.

Dana Corporation - History Page 13 of 14 For years afterwards he remained deeply mistrustful of worker's organizations, often refusing to negotiate with them at all.