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NEG.

April 25, 1933.

T Air Hygiene Foundation of Amerioa, Ino., 4400 Fifth Avenue, Pittsburgh, Fa,, January 10, 1938 / s a 'REFERENCES TO RECENT LITERATURE ON INDUSTRIAL DISEASES -------------------------------------------------------------------------------------- - yews Items f; flOOD HOUSEKEEPING A D SAFETY IN FOUNDRIES AND INDUSTRIAL CODES AND OCCUPATIONAL DISEASE LEGISLATION.

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THE BULLETIN OF THE AMERICAN CERAMIC SOCIETY Volume 16 SEPTEMBER, 1937 Number 9 PLAINTIFFS is EXHIBIT IS See page 384 for story of Who Began Vitrified Porcelain CeramicWare?

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(b) Installed in vehicles which were repaired at any of the facilities listed in plaintiff's complaint as places of *employment; Please set forth in detail the facts which support that contention, as well as the names and addresses of persons who have any information.

asbestos; * (c) in the product.

1 RESPONSE: 2 Not applicable. 3 INTERROGATORY NO. 104: 4 Please state whether the defendant entered into any agree 5 ments with any British or German concerns which manufactured 6 asbestos-containing products from 1930 to 1972. 7 RESPONSE: 8 OBJECTION Interrogatory No. 104 is objected to on the 9 grounds..that it is overly broad, vague, ambiguous and unintelli 10 gible with respect to the use of the undefined term "agreements." 11 As presently framed, this defendant cannot respond to the inter 12 rogatory. 13 INTERROGATORY NO. 105: 14 If the answer to the above interrogatory is affirmative, 15 please list: 16 (a) The name, address and phone number of each such 17 British or German concern; 18 (b) The year the agreement was entered into and the 19 date said agreement terminated; 20 (c) The products exchanged or involved in said agree 21 ment, including: 22 (i) The percent composition of asbestos; 23 (ii) The intended use of the product; 24 (iii) Whether the products were marketed in the 25 United States. 26 RESPONSE: 27 Not applicable, given the objection to Interrogatory No.

P-NSC-32 Health Practices Pamphlet No. 4 Industrial Dust Published by National Safety Council, Inc 20 North Wacker Drive, Chicago 6 Industrial Dust 1.

objections are explicitly incorporated into each of the answers set forth herein.

Da t e o k Fil in g .............................

FREDERICK LAI ST VICE-PRESIDENT 26 BROADWAY Ne w Yo r k November 26, 1937.