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os 10 t 024 I 1 (d) The dates (years) defendant or any of its 2 subsidiary companies purchased or obtained such brake lining(s) or brake pad(s) from each 3 manufacturer, distributor and/or seller, and the amounts expressed in pounds or tons which 4 defendant or any of its subsidiary companies purchased or otherwise obtained; 5 (e) The type and percentage of asbestos contained in 6 each trade or brand named brake lining or brake pad identified above which you obtained from 7 1950 through 1978; 8 (f) The physical characteristics of each kind of brake lining, brake pad or brake facing 9 purchased or used by defendant or defendant's subsidiaries for use in vehicles manufactured or 10 sold by you, including size, dimensions, weight, color, identifying tags, stamps or markings on 11 said brake liners, pads or facings; 12 (g) The name, last known address and telephone address of defendant's or defendant's 13 subsidiaries' purchasing agent(s) responsible for obtaining brake linings and brake pads for 14 use in any motor vehicles manufactured or sold by you from 1950 through 1978; 15 (h) During the time period 1950 through 1978, did 16 you maintain records relating to the purchase, sale and/or use of brake linings, brake pads or 17 disc brake pads, including, but not limited to, records which indicate what brake linings were 18 installed or to be installed on particular types or models of defendant's motor vehicles. 19 20 (i) Describe all such records referred to in subsection (h) above; 21 * (j) Identify (by manufacturer, trade name, number 22 and brand name) what brake linings, brake pads ^ or brake facings were installed, assembled, 23 placed in or otherwise used or furnished in each of the motor vehicles you manufactured, sold or 24 distributed for the period 1950 through 1978. 25 26 PLAINTIFF'S FIRST INTERROGS, ETC. 21

Capital Close-Ups By Bert Mills Washington Editor of MOTOR Talk Election Year Tax Cut Headlines about prospective tax cuts are almost daily occurrences these days as Congress chops away at the Eisenhower budget.

10 THE WALL STREET JOURNAL, Monday, March 16, IVtH Asbestos-Poisoning Claims Are Settled, Possibly Setting Precedent for Industry |-> * , : - :'v?

The Toxicity of the Vapors of Aroclor 1242*and Arochr 1254* J.

General Offices lr.

-o r*# BOUBl RIRCRRFT COMPRRK /.

VINYL CHLORIDE - 1950-1969 AS I 0 0 0 0 1 5 6 5 4

UNIVERSITY OF CINCINNATI COLLEGE OF MEDICINE CINCINNATI 19, OHIO KETTERING LABORATORY OP APPLIED PHYSIOLOGY June ll|_, 1950 ' / /-A / a; c.

March 13, 1957 Mr.

April 25, 1957 Ur. 1?.

HILL and KNOWLTON, Inc.

102 Summary While the dangers of asbestos have been well recognized for over five decades, the industry was able to largely ignore or suppress these until studies in the 1950s by Doll in England and by SelikofI in the U.S.

COPY The B.

-35- certain circumstances.(54) The Soviet experience must have been similar, as Remonstrated by a 1957 report which quotes exposure levels ranging from 8 to over 16,000 parts per million with average exposures of 20 to 300 ppm.