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The Assistant Secretary for Health 2.

SCF-ABEX-2010 While centralized cash management programs may yield some benefits to the holding company group, the potential for abuse also exists.

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Country Name of Affiliate Relationship Italy Societa Italiana Per L'Amianto S.p.A. i SIA j Via Latina 1?

Industry and EPA Hazardous Haste No.

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C 051010252 c I ANSWER: s.

c 051010268 C 1 2.14 Do any documents, including written memoranda, 2 specifications, recommendations, blueprints or other written 3 terials of any kind or character relating to the potential health 4 zards of the products listed in Interrogatory No. 1.11 now exist?

r re duct Guide The oroducts listed below are manufactured to meet the mghest Quality standards set by Koopers Comoany.

1 (in) The years during which asbestos fiber was included m the composition of the brake linings 2 under each trade or brand name; 3 RESPONSE TO INTERROGATORY NO. 119. 4 (a)-(b) See Wagner's response to Interrogatory No. 5 10(a)-(b). 6 (c) See Wagner's response to Interrogatory No. 10(c). 7 (d) -(e) See Wagner's response to Interrogatory No. 8 10(d)-(e). 9 (f) Wagner brake products have been assembled at 10 various bonding shops throughout the country. 11 INTERROGATORY NO. 120: 12 Identify all distributors of defendant's automobile brake linings or brake assemblies in and for the State of Cali 13 fornia, and for each distributor, state: * 14 (a) the date(s) defendant's automobile brake linings or brake assemblies were sold or delivered to 15 said distributor; 16 (b) the quantity and type, including trade or brand name(s), of defendant's automobile brake linings 17 and brake assemblies sold or delivered to said dis tributor. 18 RESPONSE TO INTERROGATORY NO. 120: 19 Wagner objects to this interrogatory on the grounds 20 that it is overly broad, unduly burdensome and not calculated to 21 lead to the discovery of admissible evidence and seeps propri 22 etary business information. 23 INTERROGATORY NO. 121: 24 Has defendant directly or indirectly sold or distrib 25 uted its automobile brake linings or brake assemblies to any of the following: 26 (a) Chrysler-Plymouth Corp.; 27 (b) Ford Motor Company; (c) General Motors; 28 (d) American Motors; 46

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E.1 Notes to Appendix E . :: The need for collecting most of the information on this form is discussed in Chapter 3 (Section 3.3.1).