Index ALIGNMENT EQUIPMENT/TOOLS nfS'.Tur'TON rACE'NU Adaptor X-Car .

D r 1. s Vane_=_Ry....M.r___HarVi ns 14:23:21: 1 8 Q You did not have those qualifications or 1 4:2 3:2 4: 1 2 training.

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PLAINTIFF'S EXHIBIT ft' LAM001441 SC 000244 o V LAM001442 000245

I.AM005096 HC-1-1 HC-2-1 HC-2-2 .

IN THE CIRCUIT COURT THIRD JUDICIAL CIRCUIT MADISON COUNTY, ILLINOIS IN RE: ASBESTOS LITIGATION ) FILED BY THE SIMMONS FIRM, L.L.C.)

INTERROGATORY NO. 29: Did Defendant, any related company or any predecessor ever stamp or otherwise place (including affixing tags or labels) a company name, initials, or any identifying logo on any of the products listed in response to Interrogatory No. 19?

INTERROGATORY NO. 56; Has Defendant, any predecessor or any related company, or any person or entity acting on behalf thereof, including but not limited to any insurance company, at any time, gone into any area where any product identified in response to Interrogatory Nos. 19 and 42 was being manufactured, used, applied or installed to perform a dust level count or similar test?

Page 32 1 That's not, you know, this is not something j 2 that is pertinent at this deposition.

1 Q Could we have that, please?

1 who live around the seven or eight different nuclear Page 145 2 arsenals as they are called that, were built during 3 the, right after World War II to make or handle nuclear 4 products and weapons.

PLAINTIFF'S EXHIBIT 4m ix.

1 mesothelioma to mechanics that work with brakes who Page 248 2 file the edges, who sand the faces like Joe Mallia did, ; 3 who use compressed air to blow it out and who clean in 4 the manner that Joe Mallia did, would you agree that 5 that risk would not show up in these studies?

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