Party Discovery: HAROLD KOEPKE et al VS. FORD MOTOR COMPANY et al

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14

KAZAN, MCCLAIN,
SATTERLEY &
GreeNwo9o

|APROFESSIONAL LAW

‘CORPORATION

26

bx Leno
SB Hanrison Steeet, 27

28

Fax {510} 836-4913,

IRIVAMONTE/1910429.4,

Joseph D. Satterley, Esq. (C.S.B. #286890)
Ted W. Pelletier, Esq. (C.S.B. #172938}
an A. Rivamonte, Esq. (C.S.B. #232663)
irivamonte@kazanlaw.com

IKAZAN, McCLAIN, SATTERLEY & GREENWOOD

|A Professional Law Corporation
Jack London Market

55 Harrison Street, Suite 460
(Oakland, California 94607
Telephone: (510) 302-1000

Attorneys for Plaintiffs

ELECTRONICALLY
FILED

Superior Court of California,
County of San Francisco

MAY 19 2014

Clerk of the Court

BY: EDNALEEN JAVIER
Deputy Clerk

SUPERIOR COURT OF CALIFORNIA

COUNTY GF SAN FRANCISCO

tT
HAROLD KOEPKE and NANCY KARIDIS-
IKOEPKE,

Plaintiffs,

VS.

FORD MOTOR COMPANY, et al.,

Defendants.

No. CGC-13-276217

EXHIBITS 6 THROUGH 14 TO THE
DECLARATION OF IAN A. RIVAMONTE
iN SUPPORT OF PLAINTIFFS’ MOTION
TO COMPEL THE DEPOSITION OF
NON-PARTY WITNESS YVES LE COZ

Date: June 11, 2014

Time: 9:00 a.m.

Dept.: 503 (Hon. Teri L. Jackson)
Case Filed: December 3, 2013

Trial Date: June 16, 2014

Attached are Exhibits 6 through 14 to the Declaration of lan A. Rivamonte in Support of

Plaintiffs’ Motion to Compel the Deposition of Non-Party Witness Yves Le Coz.

Rivamonte Declaration Support of Plaintiffs’ Motion to Compel the Deposition of Yves Le CozExhibit 6Coen @ Ah ww a

2

a oo
aS

. —— PARA
Choriés B. Fi No. 160111 =u
CARROLL, BURDICK & McDONOUGH LLP Rec 7 HE
Attorneys at Law.
44 Montgomery Street, Suite 400 FEB 19 1999
San Francisco, CA 94104-4606
Telephone: (448) 988-5900 BRAYTON HARLEY CURTIS.
Facsimile: 418) 989-0932 HAND OVERNIGHT MAR

Attomeys for Defendant
Volkswagen of America, Inc.

SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OFISAN FRANCISCO

No. 828684

DEFENDANT VOLKSWAGEN OF
AMERICA'S RESPONSES TO
PLAINTIFFS’

STANDARD
INTERROGATORIES TO FRICTION
DEFENDANTS

Inre: :
COMPLEX ASBESTOS LITIGATION

Defendant Volkswagen of rica, Inc. ("VWeA"} provides these
Responses to Plaintiffst st xd Interrogatories to Friction

Defendants (*Plaintiffa’ inte: atories"}, pursuant to

California Code of Civil Proc section 2030 and San Prancisco
Superior Court General order wd, 129.

. 1, IDENTIFY the individua: verifying these answers on YOUR
behalf.

ANSWER: The responses are beecuea by Mr. Robert Cameron,

Manager, Product Liaison, Volkswagen of America, Inc. ("VWoA") .
2, State the date of First] employment with You and the dates
and titles of each job positior| the person who verified these
interrogatories has held while employed by You.
ANSWER: Mr. Robert Cameron began his employment with Vwea in

May, 1965 with the Customer S ce Relations Department as a

i WOA'S RESPONSES TO STANDARD :TOREES £0 FRICTION DEFENBANTS:
‘CARDO WADESRTOAN WII,correspondent. From 1963 to 1

From 1971 to 1978 he waa Produbt Liaison Manager.

re he was a Technical Analyst.

From 1979 to

the present he is Manager, Product Liaison.

3.

state:

State whether or not YOU are a corporation and, if so,

YOUR correct corporate name;

YOUR state of incorporation;

The date of

YOUR incorporation;
The address of veoh principal place of business;

E Whether or not YOU
authority to do business in
the inclusive dates of any cert

F.

your company {is owned by anoth:

have ever held a certificate of
State of California and, if so,

ificate;

tf YOU are wholly owned or the majority interest of

business entity, state the

entity's name and principal pldee of business;

@. Whether YOU have any business offices in California

and, if so, YOUR principal plad

ANSWER: VWoA was incorpora’
New Jersey on October 27, 1955
business at 3800 Hamlin Road,
held a certificate of authorit:
since June 19, 1958.
VWoA are held by Volkswagen Be!
C*VPBG"} .
Federal Republic of Germany.
effice at 40 W. Cochran Bovlevi

4,

under any other name in the Sta}

YWOA'S RESPONSES TO STANDARD INT!

vWEG is owned by Vol

fe of business in California.

ed under the laws of the State of

has its principal Place of
Hills, Michigan. VWoA has

to conduct business in California

All of the issued and outstanding shares of

dligungs Gesellschaft-MbH.
gen AG, 38436 Wolfsburg,
iok haa its Southwest Region

rd, Simi Valley, Califomia.

Have YOU every been ee known or done business

2 of California?

SATORIES TO FRICTION DEFENDANTS “2-
CARWINDOWSIESKTORVW 1205,ANSWER: No.
5. I£ YOUR answer to Interrogatory No. 4 is im the

affirmative, please state such name or names and the time period
during which THIS DEFENDANT was so known or identified.

ANSWER: See VWoA'te response to interrogatory 4.
6, If YOU are not a corporation, what is YOUR business

structure (partnership, joint venture, sole proprietorship,
ete.) -

oe eH fe

ANSWER: VWoA is an incorporated entity.

S

7. If YOU are not a corporation, please IDENTIFY all persona

or other entities with an ownership interest in YOU.

Bb

ANSWER : VWoA is an incorporated entity.
8. If YOU are not a corporation, please state the following:
A. ‘The address where the HISTORICAL RECORDS of THIS
DEFENDANT are currently located; and
B, The name, job title and current address of the
custodian for THIS DEFENDANT'S HISTORICAL RECORDS.

As used herein, “HISTORICAL RECORDS shall include all
DOCUMENTS relating to the formation of THIS DEFENDANT, ml)
minutes of partners', general partners’ or other owners’ meetings
and all DOCUMENTS relating to THIS DEFENDANT'Smerger with,
acquisition of or purchage or sale of or by any other COMPANY.

ANSHER: ¥WoA is an incorporated entity.

gy. IDENTIFY YOUR custodian of Business Records.

ANSWER: VWoA does not employ a custodian of business records.

10, IDENTIFY the person or persons most knowledgeable about:

A, YOUR acquisition of RAW ASBESTOS and/or ASBESTOS~-
CONTAINING FRICTION PRODUCTS;

| ‘VWOA'S RESPONSES TO STANDARD INTERROGATORIES TO FRICTION DEFENDANTS -3-
CAWINDOWSOREXTORY WIZE,B. YOUR use of RAW ASBESTOS and/or ASRESTOS-CONTAINING
FRICTION PRODUCTS;
¢@. YOUR contracting with cthers toe do work involving use
ox handling of RAW ASBESTOS ox ASBESTOS-CONTAINING FRICTION
PRODUCTS.
ANSWER: VWoA does not contract with others te do work using

ox handling of brake shoes, pads and clutch plates. vwoa is

unable to identify which of its employees are most knowledgeable
regarding ‘the information sought in thia interregatory. an
individual having kmowledga is Mr. Yves Le Coz, Senior Engineer,
Product Analysis, c/o VWoA, 600 Syivan Avenue, Englewood Cliffs,
New Jersey.

11, For DEFENDANTS involved in the MARKETING of ASBESTOS-
CONTAINING FRICTION PRODUCTS, state the IDENTITY of physicians,
medical directors and/or industrial hygienists employed by THIS
DEFENDANT, All other DEFENDANTS need only respond as to wedical
directors and/or industrial. hygienists or physicians employed in
the area of employee health end safety. PREMISES owners and
domestic coxporations need only respond as to the United States
only.

ANSWER: My. Michael Brian was employed by VWoA as an
industrial hygienist.

12, Has any employee of THIS DEFENDANT testified by
deposition or at trial on behalf of THIS DEFENDANT in a third~
party case, in which THIS DEPENDANT was a.party, wherein the
Plaintiff has alleged an asbestos-related injury? I€ se, for
each such third-party case please state:

A. The caption and case number;

VWOA'S RESPONSES TO STANDARD INTERROGATORIES TO FRICTION DEFENDANTS. 4
CAWINDOWSDESITORVTHIDNST.ecm a Ah hw NY

nos

The court:filing including state and county;

c. The date of deposition or trial testimony;
D. The name and address of plaintiff's counsel of
record;

E, The name and address of the court reporter.

ANSWER: VWoA has not testified aa described in thie
interrogatory.

13. For each of the following, please state whether THIS
DEFENDANT has ever been a member or paid dues for any
representative of THIS DEFENDANT to be a member of the following
(please answer to the present);

A. American Conference of Governmental Industrial
Hygienists;
American Industrial Hygiene Association;
American Petroleum Institute;
American Railroad Association;
Asbestos Cement Producers Association;
Asbestos Information Association {AIA);
Asbestos Information Associaticn/North America
(ATA/NA} 5
H, Asbestos Textile Institute (ATI);
Z, Industrial Hygiene Foundation and/or Induetrial
Health Foundation (IHF);
gd, Industrial Mineral Insulation Manufacturera
Institute;
K. Mangesia Insulation Manufacturers' Association;

L. Magnesia Silica Insulation Manufacturers Association;

M. Mineral Wool Institute;

YWOA'S RESPONSES TO STANDARD INTERROGATORIES TO FRICTION DEFENDANTS: -i-
CAWNDOWSDESKTOPW WISE,Coe IA & WD oe

Boe Ss

National Insulation Manufacturers Association {NIMA);
National Safety Council;-

New York Academy of Sciences;

Quebec Aghestos Mining Association (QAMA);
Refractories Institute;

Safe Building Alliance;

Thermal Insulation Manufacturers Association {TIMA};
U.S. Maritime Commission;

Vv. IDENTIFY any other organizations, associations or
groups of manufacturers, miners, distributors, importers,
labelers, suppliers and/or sellera of RAW ASBESTOS and/or
ASBESTOS-CONTAINING FRICTION PRODUCTS oF which THIS DEFENDANT was
a member;

W. IDENTIFY any such representative of THIS DEFENDANT.

ANSWER: VWoA is without information which would permit it to
respond to this interrogatoxy.

14. For each organization, association or other entity
identified in YOUR response to Interrogatory Ne. 13, please
atate:

A. The dates during which THIS DEFENDANT was a member;

B, The name(s} of any publ ication(s} received by THIS

DEFENDANT from such association or organization;
C. The name of any committee or subcommittee of which
THIS DEFENDANT was a member and the dates of such committee or
subcommittee membership,

ANSWER: See VWoA's response to interrogatory 13, incorporated
herein by reference.

15. Had THIS DEFENDANT prior to 1573 received any DOCUMENTS

YWOA'S RESPONSES TO STANDARD INTERROGATORIES TO FRICTION DEFENDANTS -6-
CRW ERDOWSDESETORVW 2950,wet Ah eww

= 5

-asbestos?

containing results ox

aabestos exposure in

AL
data, evidencing the

its subparts to YOUR

made the subject of
B. State 61
received such
G. State the
DOCUMENTS ;
D. This int
contained in a libra:

DEFENDANT's library p)

conclusions of any studies and/or tests

conducted by Bonsib for Standard 041 of New Jersey relating to

the workplace or the human health

consequences of expodure to asbestos? If so:

Either attach all DOCUMENTS or disks containing such

information sought in this interrogatory and

jangswers to these interrogatories or describe

such DOCUMENTS with sufficient particularity that they may be

vequest for production of docvuments.
date upon which THIS DEFENDANT first
3;

IDENTITY of the custodian of such

jatory does not apply to DOCUMENTS
maintained by a DEFENDANT hospital or a

oviding access to the general public.

ANSWER: VWoA did

16, Had THIS DEF
portion of any studi:
company, including
Company and Aetna In:
workplace or the hur
If sor
A. Either at
data, evidencing the
its subparts to YOUR
describe such

may be made the subj;

VWOA'S RESPONSES TO STA!

yc receive any such materials.

2 prior to 1573 received a copy or any
and/or testa conducted by any insurance
mot limited to Metropolitan Life Insurance
ance relating to asbeatoa exposure in the

health consequences of exposure to

bach all DOCUMENTS or disks containing such
information sought in this interrogatory and
answers to these interrogatories, or

‘S with sufficient particularity that they
& of a request for production of documents;

y-

AND INTERROGATORIES TO FRICTION DEFENDANTS:
CAWTIDOWSIDESKTOAVW 1295,B. State thd

date upon which THIS DEFENDANT first

received such DOCUMENTS;

c.

DOCUMENTS

D. This intd

contained in a libr.
DEFENDANT'S library
ANSWER: VWea did
iy.
eontaining results o:
conducted by any 1:
Saranac Laboratory
er the human health
A. Bither ai
data, evidencing the
its subparts to YOUR
such DOCUMENTS with
made the subject of

B. State the

State rhe

Has THIS DEF

IDENTITY of the custodian of auch

rfogatories dees net apply to DOCUMENTS

¥y maintained by a DEFENDANT hospital or a
woviding access to the general public.

not receive any such materials, .

INDANT priox to 1373 received any DOCUMENTS
conclusions of any studies and/or tests
ratory, including but not limited to the
ating ta asbestos exposure in the workplace
msequences ef exposure te asbestos? If so:
tach all DOCUMENTS or disks containing such
information sought in this interrogatory and
answers to these interrogatories or deacribe
ufficient particularity that they may be
request for production of Gocumenrs;

date upon which THIS DEFENDANT first

received such DOCUMENTS;

c.
DOCUMENTS ;
D. This int
contained in a libra:
DEFENDANT's Library
18. State whethe:

library (or Librarie

YWOA'S RESPONSES TO STA

State the

IDENTITY of the custodian of such

irrogatoxy does not apply to DOCUMENTS
maintained by a DEFENDANT hospital er a

Providing access to the general public.
ot receive any such materials.
THIS DEFENDANT has ever maintained a

) which containg books, articles,

DARD INTERROGATORIES TO FRICTION DEFENDANTS 3.
CAWINDOWSDESKTOAVWI2957F,oe BD nH ke we

= 5

periodicals, Journals dn@/or reference materiala that relate to

the subjects of asbe:

and/or occupational

igease.

i
5, industrial hygiene,medicine, safety

Tf eo, state:

A. The date bdch such library was established;

B. The Locati
c. The ID!
charge of such libr.

‘of each such library;

,of each librarian or other person in

ANSWER: VWoA has hot maintained a library for the purpose of

housing materials rel ce te the subject of asbestos.

maintained a general

to 1973, ite genexal

VWoA has
brary. VWoA is unable to state if, prior

dbrary contained materials related to the

subjects described in| thie interrogatory.

19. With the exception
prior to 1980 exchan
individual or other
tests and/or studies Fé
workplace or the human
asbestos? If so, stal
A. Bach indi]

was exchanged or to wi

of OSHA compliance, had THIS DEFENDANT
DOCUMENTS or communicated with any
ANY expressly regarding the vesulte of
dating to asbestos exposure in the
health consequences of exposure to

val or COMPANY with whom the information

iit was coomunicated;

B. The date(s)

Cc, The IDENT!

ANSWER: Vitoa did ad
described in this inte
20. Has any enipio}

on behalf of THIS DEFER
Health Administration
Health and Safety ox 4

YWOA'S RESPONSES TO STAND

ee any such exchanges or communications;
106 the custodian of euch DOCUMENTS.

i
it jpossess such tests or atudies as

ogatory.

jor designee of THIS DEFENDANT testified
DANT before the Occupational Safety and
the National Institute of Occupational

ty lcommittee oz subcommittee of tha United

RDINTERROGATORIES TO FRICTION DEFENDANTS a
: CAWINDOWSDESK TOP HIS,CO my An ew we

eo ee ee ie moe
oS URGE ORB ES

the human health cons

please state:

The date

Whether
before which testim
B. Whether
by THIS DEFENDANT an
of such DOCUMENTS,
ANSWER: VWoA has.

interrogatery.

States Congresa relat

The entit:

g te asbestos exposure in the workplace or
ences of exposure to asbestos? If so,

}
hefore whom such testimony was given;

is} and location(s} ef such testimony;

The IDENTIFY of the individual(s} who so testified);

DOCUMENTS wexe presented to the entity

was given;
] jes of DOCUMENTS presented were retained

if ao, state the IDENTITY of the custodian

?

ppt testified as described in this

21. Has THIS DE:

c. The indivi
and/ or study;
D. Whether

the results and/or co

sale brake shoes, padi

have conducted such ¢!

YWOA’S RESPONSESTO STAND

conducted or caused to he conducted,

tent asbestos dust created during the
a/or assembling for sale of ASBESTOS-

S? If so, state:

turing facility, including location and
pub test and/or study was conducted:

pach such test and/or study;

Rdu&l(s) of entity conducting each such test

i
S DEFENDANT has any DOCUMENTS containing
¢lisions ef each such study;

jof the custodian of such DOCUMENTS.

jot wanufacture, process or assemble for
;

ip lor clutch plates and did not conduct or
bdt ox study as desoribed in this

~10-
k29SIP.

AREA INTERROGATORIES TO FRICTION DEFENDANTSoe Ao PF OD

eo
=_S

interrogatory.

22. Has THIS DEFENDANT condlucted,or caused to be conducted,
any tests and/or studies on ambient asbestos dust levels at any
location or job site where ASBRSTOS-CONTAINING FRICTION PRODUCTS
ware installed, utilized or removed? If so, for the first five
teets and/or studies, state:

A. The location, including name and address, at which
each such test and/or study was conducted;

B. The individhatis) or entity conducting each such test
and/or study;

Cc. The date of] each such test and/or atudy;

D. Whether thib DEFENDANT has any DOCUMENTS containing
the results and/or conclusions of each such teat and/or study;

EB. The IDENTITY of the custodian ef such DOCUMENTS,

ANSWER: VRoA does install, utilize or remove brake shoes,
pads ox clutch plates and did not conduct or have conducted such
test or study described] in thia interrogatory.

23, Did THIS DEFENDANT have any lahoratory or othex similar

type of facility anywhefe in the United States at which it

conducted or caused to be conducted, any tests and/or studies of

ON PRODUCTS or RAW ASBESTOS relating to

state:

A. The location, including name and address, at which
each test and/or study vas conducted;

B. The individdal(s) or entity conducting each such test

and/or study;

VWOA'S RESPONSES TO STANDARD INTERROGATORIES TO FRICTION DEFENDANTS: -ii-
CAWINDQWSDESKTOAVW SSP.OP WA RF YR

Ss

Bs

BG

ah

17

y
ee FE

c, The date of each such test and/or study;

D. Whether FHT

the results and/or

ANSWER; VWoA di;

conduct ar have con

interrogatory.
24. Hag THIS DI

medical examination

A. Whether

DEFENDANT baa any DOCUMENTS containing
clusions of each such test and/or atudy;

have a such a facility, and did not

A such test or study as described in this

E. ‘The IDI is the custodian of such DOCUMENTS.

Tmade available to its employees a

‘oyram to determine the absence ox presence

of asbestos-related [ope If go, state:

part of such progranl(
B. Whether p:
mandatory condition
¢. Whether

program(s) ;

ANSWER: Evployees
described in this i

health insurance plaj

25. Prior to 1988
Compensation claim fp;
DEPENDANT or any Wor!

which provided coverage| for THIS DEFENDANT?

total number of such}
state:
A. The date!

8. The name

YWOA'S saaronssro crate HG INTERROGATORIESTO FRICTION DEFENDANTS 712.
CANTNDOWSDESKTOPY

tt x-rays or pulmonary function teats were
s)he
arficipation in any such program was a
oyment or was voluntary;
DEFENDANT has DOCUMENTS of such

D. The soared of the custodian of such DOCUMENTS.

Of YWoa are not provided with a program as

errogatory. Employees are provided with a

. Bid any person file a Workers!

x febestos-related injury against THIS

exp! Compensation carrier for THIS DEFENDANT
If so, state the
olkims and, for the first 20 such claims,

of| such claim;

of| the claimant;

VRIIOSIF,c. The casejn Ey
D. The court ah enach the claim wag filed)
E, The IDENTIT¢ ef THIS DEFENDANT's custodian of
DOCUMENTS evidencing|suth claims.
ANSWER: No. .
26. Does THIS DEFENDANT have insurance available to cover

judgment(s) entered aga net it in asbestos-related personal
injury lawsuits? If/se} state:

ao

eC MONA awh

A, The name/and principal place of business of any

inaurance carrier who has issued such policy of ingurance;
B. The womb a effective date of each policy;

6

B=

The amount(#) ef coverage of each policy;

a

The applicable dates of coverage.
Considering) the monetary exposure, if any, involved

in this lawsuit, VWoA ip self-insured for the purpose of this

lawsuit.
27. State whether ¥b0 have controlled, puxchased or in any

way acquired a contrblling interest in any corporation or
business entity which mined, manufactured, produced,
processed, compoundad, hold, supplied, distributed and/or
otherwise placed RAW| ASBESTOS ox ASBESTOS- CONTAINING: FRICTION
PRODUCTS in the atresm Of commerce. If so, state:

A. The name] ani address of said corperation or business

entity:

a. & YOu controlled, purchased or acquired any
interest;

The natus £ he business as it pertains to asbestos.

VWoA hagi k acquired any such interest as described

YWOA'S RESPONSES TO STANDARD INTERROGATORIES TO. FRICTION RETENDANTS. wieBw wa anne ein

in this interrogatory,.
28

. Lf THIS DEF! entered into any agreements for the
rebranding cf any ASBESWOS-CONTAINING FRICTION PRODUCTS by THIS

DEFENDANT for resale

describe each agreerent

agreement, the duration!

product (8) and/or ma
ANSWER: VWor.

described in this in}
29. If THIS RE

rebranding of ASBE:

sold, supplied or di:

or]

distribution by another person or entity,
‘a terms and the parties to said

of the agreemant and the name of each

erjal{s) covered by each such agreement.

tt. entered into any such agreements as

tory.

ANT entered into any agreements for the
PONTAINING FRICTION PRODUCTS manufactured,

jbuted by another person or entity for

resale or distribution

aid)

yy YOU, describe each of the agreements

and the parties to s agreement, the terms, the duration and

the names of each prpdugt (3) and/or material(s} covered by each

such agreement ,

ANSWER: VWoA has|not entered into any such agreements as

descxibed in this infertogatory.

30. Between the years 1939 and 1985, did you purchase or

otherwise acquire any AS -CONTAINING FRICTION PRODUCT lines

from another person dx éntity? Tf so, state for each such

purchase:

A. Date of gurghase or acquisition;

B. Terms of |pugchase or acquisition agreement;

CG. Hither afta¢h all DOCUMENTS or diske containing such

data, evidencing said adquisition, or describe such DOCUMENTS

with sufficient partjcujarity that they may be made the subject

of a request for production of documents;

~14-
WIDOT,

VWOA'S RESPONSES TO STANBARS

INTERROGATORIES TO FRICTION DEFENDANTS
CAWRNDON|

D. Trade, b
line so acquired;

HE. Name cf
Jer acquired each suc!

F. Location

manufactured herein.
ANSWER: VWoA did

31, Between the
ASBESTOS-CONTAINING

entity? If so, stat

A, Date of
Terms of

c. Hither at
data, evidencing sais
sufficient particula:
request for producti:
D. Trade, by
line sold;
x. Name of
ASBESTOS- CONTAINING
F. Location
the type of ASRESTOS/
therein.
ANSWER: VWoA did
described in this int
32. IDENTIFY all

| ‘VWOA'S RESPONSES TO STAN

re

and the type of ASBESTOS

deseribed in this inter?

te

snl and/or generic name of each such product

person or entity from whom YOU purchased
BESTOS-CONTAINING FRICTIGN PRODUCT LINE;
oflany manufacturing facilities so acquired
-CONTAINING FRICTION PRODUCTS

not acquire any such product line ag
rogatory.

6 1930 to 1985, did YOU sell any
ITION PRODUCT line to another person or
£

ale:

bx each such sale:

sales agreement;

tach all DOCUMENTS or diska containing such

A St
sof

€ documents;

le, or describe such DOCUMENTS with
that they may be made the subject of a
2

land and/or generic name of each such preduct

gon or entity to whom YOU sold each such
PTION PRODUCT LINE; and
of jany manufacturing facilities a0 sold and

CONTAINING FRICTION PRODUCTS manufactured

ino own or sell any such product line as

extogatory.
ordchures, pamphlets, catalogs or other

ARDINTERROGATGRIES TO FRICTIONDEFENDANTS ——~15-
‘CAWINDOWSDESKTORVWIZSP,oH HO fF Ow

Ss

Sot

a

advertising relating

state:
A desori
The year
The peri

presently exist;
F.

are located;
G. The IDI

ANSHER: VWoA did
described in this int
33. When do YOU

a4, How do you

human beings?

35.

data, evidencing the

supplied from the yedr 1930 to 1985.

disease in human eee
ANSWER: VWoA make!

there jie an associatit

ANSWER: VWoA make!
Bither attach

Interxogatory Nos. 34

to ASBESTOS-CONTAINING FRICTION PRODUCTS

and/or RAW ASBESTOS which YOU manufactured, scld, distributed or

Bor each such document,

tion of the document;
it was printed;

of time in which it was used;

The purpdse of said document;
Whether the documents or copies of said document

T£ said documents or copies still exist, where they

TTY of the custodian of such documents.
& use any such marketing materials as

srogatory.
tend THIS DEFENDANT Cirat became aware

that there is an assdciation between asbestos exposure and

mo such contention.
‘tend TRIS DEFENDANT first became aware that

between asbestos exposure and disease in

f no such contention.
all DOCUMENTS or diske containing such

information upon which YOUR contentions in
and 38 are based or describe such DOCUMENTS

with sufficient nereipaesicr that they may be made the subject

of a request for pi

VWOA'S RESPONSES TO ST.

otion of documents.

JARD INTERROGATORIES TO FRICTION DEFENDANTS
CAMEIDOWRDESETONANSWER: See VWoA!
Inerein by reference.
35.

36. When did You
asbestos could he haz;
A, Whether 4
B. Whether o

exist;

1
2
3
4
3
6
7
8
9

Cc. The IDENy
40

i

D. The conte

ANSWER: VWoA's en}

37, Did YOU ever

A. Provide 4

B. Describe
c. Either at
data, evidencing the
its subparts to YOUR
such DOCUMENTS with
made the subject of 4
ANSWER; See VWoA

herein by reference.

out of or’ through ary

each occasion:

| VWOA'S RESPONSES TO STA!

warming your orvtoved
hazardous te human

Is response to interrogatory 34, incorporated

VWoA makes no contention in interrogatory

first warn YOUR employees that exposure to
ardous to humen health? State:
ine first such warming was written or oral;

jopLes of DOCUMENTS containing such warning

ITY of the custodian of such DOCUMENTS;
int of the warning.

iphoyees did not require such a warning as

described in this interxogatory.

issue a written COMPANY policy discontinuing
9 that exposure to ashestos could be

alth? If so:

ihe date;

che circumstances;

tagh all DOCUMENTS or disks containing such
ingomnation sought in this interrogatory and
lamawares to these interrogatories or describe
jufficient particularity that they may be
Yequest for production of documents.

S response to interrogatory 26, incorporated

38. At any time between 1930 and 19585, did YOU import,

export, ship, transatip ox otherwise trangport RAW ASBESTOS into,

port in the GEOGRAPHIC AREA? If so, for

ARD INTERROGATORIES TO FRICTION DEPEND AN Ronwe: oisA. IDENTIFY

ASBESTOS ;

operators thereof)

occasion;

data, evidencing the

its subparts to YOUR

ANSWER: No,

and 1985;

Buses / co:

Motorcys:

Rubber-t}

vehicles;

a

VWOa'S RESPONSES TO ST)

and describe the NATURE and amount of RAW

B. ween en, ship or ships {including the owmers and

to or from which the RAW ASBESTOS was

loaded, unleaded or Eranshipped;
Cc. State the dates, port and pier involved for each

D. Either atach all DOCUMENTS or disks containing such

information sought in this interrogatory and
answers to these interrogatories or describe

such DOCUMENTS with sufficient paxticularity that they may be
made the subject of p xequest fox production of documenta.

39, Did YOU or any of YOUR predecessors-in-intereat
manufacture any of the following products which contained
ASBESTOS ~ CONTAINING PRRCRION PRODUCTS at any time between 1930

A. Automobiles;
B. Light duby trucks;
C. Heavy duby trucks or trailers;

ohes;
e287

Grilling rig or cther stationary machinery;

xed crawler, conatruction or farm equipment;

ines or cars including light-railed’

DARD INTERROGATORIES TO FRICTION DEFENDANTS ~18-
CAWINDOWSDESKTOAYWIDISIF.K. Off-road:

L. Pork lif!

M. Other mar

state:
‘A. IDENTIFY,
dates of production;

B.

thereof;
ec.
ASBESTOS- CONTAINING
component parts in ¥%
D. Either a
data, evidencing the
its subparts to YOUR

such DOCUMENTS with

ORIGINAL EQUIPMENT
responsive to this 6:
PRICTION PRODUCTS) ;
#. IDENTIFY
about the information sought in thia interrogatory or ite
subparts,
ANSWER: VWoaA ass:
Golf and Jetta from

Not possess the info:

—

For each

IDENTIFY}

I,

‘YWOA'S RESPONSES TG STAND

vehicles;
bee

thinery or equipment (please deacribe) .

ANSWER: VWoA asaenbled automobiles and light duty trucks.
40, For each prog

fuct identified in Interrogatory No. 39,

the ORIGINAL EQUIPMENT including inclusive

IDENTIFY and describe the NATURE of the

ASBESTOS-CONTAINING FRICTION PRODUCTS and the inclusive dates

the manufacturer and/or distributor of the
CTION PRODUCTS which were included as
UR ORIGINAL EQUIPMENT;

tach all DOCUMENTS or diake containing such
information sought in thia interrogatory and
answers to these interrogatories or describe

uificient particularity that they may be

made the subject of 4 request for production of documents (as to

icle manufacturers, the documents

part are limited to ASBESTOS-CONTAINING

the person(s} presently most knowledgeable

led the Volkswagen Rabbit, Pick-up Truck,
@ to i988. As to subparte B. and C. does

ymation sought except, upoa information and

HARD INTERROGATORIES TO FRICTION DEFENDANTS.
CAWINDOWSORSCIONVWI205R,

-19-belief, brake shoe linings, pads and clutch facings contained
chrysotile. As to 3 ri D., VWoA does not possess the
materials sought. to subpart E., VWoA is unable to identify
which of its employeds is the mast knowledgeable of the
information sought im this interrogatory. An individual having. .
knowledge is Mr. yveq Le Coz, Senior Engineer, Product Analysis,
¢/o VWoA, 600 SylvaniAvenue, Englewood Cliffs, New Jersey.

41, Did YoU manufacture or have manufactured or @istribute in
the United States fox a foreign manufacturer ORIGINAL EQUIPMENT?
Tf so, please IDENTIFY each of YOUR authorized dealers during the
period 1930-1985 in the DEFINED GEOGRAPHIC AREA.

- . . ANSWER: VWoA impd¢xrted and distributed vehicles manufactured

lin Europe. VWoA sold to independant distributors which in turn
gold to their eee dealers, In 1973 YWoA purchased the

distributors. VWoA Has a copy of a list of authorized dealers.
42, Did YOU or atjy ef YOUR predecessors-in-interest MARKET

prake shoes, brake bilocks, brake pade, brake linings or brake
bands for any of the uses :listedbelow at any time between 1930
and 1985?

Autowobiles or light duty trucks;

Heavy dutly trucks or trailers;

Buses or jcoaches;

Motorcycles;

Winches, |Grilling rigs or other stationary machinery;

Rirorafe

Rubber tired crawlers, construction or farm
equipment;

Lm HR. Railed engines or cara including Light railed

VWOA'S RESPONSES TO STANDARD INTERROGATORIES TG FRICTION DEFENDANTS
CAWINDOWSIDESKTOMoe 47m up w nv

RGOwn 2 Ss

vehicles;

I. Shipboard.

Off-road|vehicles;

Forklifts;

Other uses.

ANSWER: VWoA dia!
and brake pads for ai
43. For each use

A.
product wags known £
B. The date

1. begar

ributed Volkswagen brake shoes with linings
tomobiles and light duty trucks.

identified in Interrogatory No. 42, state:

The ek brand and generic name by which the

i930 to 1985;
8} YOU:
MARKETING the product;

2. ceasdd to MARKET the product;

3. recal

led the product from the market, if ever as

a result of asbestosirelated health concerns, if any;

C. A desert

in the ASBESTOS-CONT!

"| asbestos fiber by per

CONTAINING FRICTION
inclusive;

D, A general

lcion of the type and grade of RAW ASBESTOS
INING FRICTION PRODUCT and the range of
fentage of weight in each such ASBESTOS-

for sach year between 1930 and 1985,

description of the physical appearance and

NATURE of each type df ASRESTOS-CONTAINING FRICTION PRODUCT

ineluding any general)

iy used method identification of the product

such aa distinctive tarkings and/or logos and the date,

inclusive, during whith they appeared.

In addition to describing

the distinctive markings and/or legos, please IDENTIFY the

manufacturer or distr

FRICTION PRODUCT;

VWO4’S RESPONSES TO STANDARD INTERROGATORIES TO FRICTION DEFENDANTS.

butor of each type of ASBESTOS-CONTAINING

21
VW 28STP,t

zE
each type of ASBESTOS)

period ef supply;

F, The
type of ASBESTOS- CONT
agent, fire retardant!

a.

oo A AH EP ON

period of time during}
er carton;

BH, A detail
trademaxk appearing

identified in G abovel

used;

I. aA detailet
wrapping or printed 4)
container, package or!
inclusive period of ¢
or printed insert was}

a.

YOUR control samples

or carton; 2) each pr}

Did rou pF
PRICTION PRODUCTS YOT
time?

Pomme

I

VWOA’S RESPONSES TO: STANDARD INTERROGATORIES TO FRICTION DEFENDANTS

EDENTIFY {the suppliers of the RAW ASBESTOS used in

CONTAINING FRICTION PRODUCT and the time

@ for the inclusion of asbestos in each
INING FRICTION PRODUCT (eg., binding

2 ROCF

The type pf shipping package and the range of
shipping package dimensions; if not solid, and the inclusive

which You used each such container, package

description of any printed material or
each type of container, package or carton

and the inclusive period of time during

which each such conbipation of printed material and trademark was

G description of any written instructions,
gert Which wag or is placed in the

carton with each such product and the

ime during which each instruction, wrapping

placed in the container, package or carton;

Whether of not You have in YOuR possession of under

xy exemplars of: 1) each container, package

nted material or trademark appearing

thereon; or 3} each written instruction, wrapping or printed

insert mentioned in rT regponse to G, H and I above.

x.

ace edge codes on the ASBESTOS-CONTAINING

MARKETED and, if so, during what period of

~22-
NgSIPea oe aK HH ew ON

BSBURBEREE BES

L. Either attach all DOCUMENTS or disks containing such
data, evidencing the information sought in this interrogatory and
its subparts to YOUR answer to these interrogatories or describe
euch DOCUMENTS with sufficient particularity that they may be
made the subject of a requast for production of documents;

M. IDENTIFY the persen(s} presently most knowledgeable
about the information soiight in this interrogatory or its
subparts. °

ANSWER: Ag to subparts A. and B. Volkawagen brand brake shoes
and brake pads were distributed during the pericd 1955 through
1985. As to subpart C., VWoA does not possess the information
sought except that, upon information and belief, the brake shoes
contained chrysotile. As to subpart D., VWoA does not possess
the information sought except that the Volkswagen logo, an
interlocking "V* and "W" inside a circle, appeared on originals
parta during the period 1955 through 1585. As to subpart Bi,
WWoA does not possess the information seught. As to subpart F.,
brake linings and pads contained chrysotile to insure adequate
performance of the braking system. As to subparte G., BH. dg. and
L., VWoA will produce, if requested, a photocopy of three
packages. As to subpart I, VWoA does not possesa the information
sought. As to subpart K., VWoA did not place codes as described
in this subpart. As to subpart M,, VWoA is unable to identify
which of its employees is the most knowledgeable of the
information sought in thie interrogatory. An individual with
knowledge is Mr. Yves Le cox, Senior Engineer, Product Analysis,

c/o VWoA, 600 Sylvan. Averlue, Englewood Cliffs, New Jersey.

44. Did YOU or any of YOUR predecessors-in-interest WARKET

YWOA'S RESPONSES TO STANDARD INTERROGATORIESTO ERICTION DEFENDANTS +2
CAWIRDOWSDESKTORV WIEST,clutch facings, clutch plates or automatic transmission plates
for any of the uses listed below at any time between 1930 and
19852
Automobiles or light duty trucks;
Heavy duty trucks or trailers;
Buses or coaches;
Motorcycles;
Winches, drilling rigs or other stationary machinery;
Aircraft ;
Rubber tired crawlers, construction or farm
equipment ;
HR. Railed engine or cara, including light railed
vehicles; Ms
I, Shipboard;
O£f-read vehicles;
Forklifts;
Other uses.
ANSWER: VWoA distributed clutch plates and automatic
transmission plates for automobiles and light duty trucks.
45. For each use identified in Interregatory Ne. 44, state:
A. the trade, brand and generic name by which the
Product was known from 1930 to 1886;
B. The date(s) you:
2. began MARKETING the product;
2. ceased te MARKET the product;
3. recalled the product from the market, if ever, as
a result of asbestos-related health concerns, if any;

Cc. aA description of the type and grade of RAW ASBESTOS

VWOA’S RESPONSES TO STANDARD INTERROGATORIES TO FRICTION DEFENDANTS oe
CAWINDOWSWESKTOAYY |cooraue vn |

BS

in the ASBESTOS-CONTAINING FRICTION PRODUCT and the range of
asbestos fiber by percentage of waight in seach such ASBESTOS-
CONTAINING FRICTION propucr for each year between 1930 and 2985,
incrusive ; :

D. A general dedeription of the physical appearance and
NATURE of each type of AgBESTOS-conTAINING FRICTION PRODUCT
including any generally used method of identification of the
product such as distinctive. markings and/or logos and the dates,
inclusive, during which they appeared. In addition to describing
the distinctive markings and/or logos, please IDENTIFY the
manufacturer or distributor of each type of ASBESTOS-CONTAINING
FRICTION PRODUCT; i

—. ‘IDENTIFY the |auppliers of the RAW ASBESTOS used in
each type of ASBESTOS-CONTAINING FRICTION PRODUCT at the time
period of supply;

F, The purpose lox the inclusion of asbestos in each
type of ASBESTOS-CONTAIN: FRICTION PRODUCT {e.g., binding
agent, fire retardant, ete.) s

G. The type of shipping package and the range of
shipping package dimensiqns, if not solid, and the inclusive
period of time during whijch YOU used each such container, package

ox carton;

&. A detailed daneription of any printed material or

trademark appearing on “‘htype of container, package or carton
identified in G above, the inclusive period of time during
which such combination of printed material and trademark was

used; t

I. aA detailed ddacription of any written instructions;

‘
1

VWOA'S RESPONSES TO STANDARD INTERROGATORIES TO FRICTION DEFENDANTS 2
CAWINDOWSDESETORY WT:

|nie . |

wrapping or printed insext which was or is placed in the
container, package or caxton with each such product, and the
inclusive period of time lauring which each instruction, wrapping
or printed insert was pldced in the container, package or carton;

dg, Whether or nde You have in YOUR possession or under
YOUR control samples or dxemplars of: 1) each container, package
or Garton); 2) each printed material or trademark appearing
thereon; or 3) each written instruction, wrapping or printed
insert mentioned in Your response to 6, H and I above;

K. Did vou otal edge codes on the ASBESTOS. CONTAINING
FRICTION pRobucTa You and, if ao, during what period of
time? ;

L, Either attacH all DOCUMENTS or disks containing such
data, evidencing the infdrmation sought in this interrogatory and
its subparts te YOUR answers to these interrogatories or describe
cuch DOCUMENTS with sufficient particularity that they may be
made the subject of a request for production of documents;

M. ‘IDENTIFY the person(s} most knowledgeable about the

dntormation eought in 1 interrogatory or its subparts.

ANSWER: Aa to subpart A. and 8. Volkswagen clutch plates
were distributed during the period 1955 through 1988. As to
eubpart ¢., wpon information and belief, clutch facings contained
chrysotile, As to subpart D., VWoA does not possess the
information sought except{ that the Volkswagen logo, an
interlocking ‘v" and “W" knside a circle, appeared on originale
parts duxing the period 1955 through 1985, as to subpart B.,
WWoA does not possess the! information sought. As to subpart F.,

clutch facings contained ¢hrysctile to insure adequate
[ae

‘VWOA'S RESPONSES TO STANDARD INTERROGATORIES TO FRICTION DEFENDANTS —_“26-
CARINDOWSDESTOAN WHOSE,performance of the cxansnpssion aystem. As to subparts G., H.
I.,¢. and L., VWoA doas hot possess ‘theinformation sought. As
to subpart K., VWoA did nbt place codes as described in this
subpart. As to subpart xi, VWeA is unable to identify which of
its employees ia the most| knowledgeable of the information sought
in this interrogatory. Ah individual with knowledge is Mr. Yves
le Coz, Senior Engineer, Product a@malysis, ¢/o VWoA, 600 Sylvan
Avenue, Englewood Cliffe,|New Jersey. :

46, Did YOU or any oe! YOUR predecessore-in-interest MARKET
any ASBESTOS~CONTAINING FirerioN PRODUCTS to any ORIGTNAL
EQUIPMENT MANUFACTORER? ke g0, IDENTIFY each ORIGINAL EQUIEMENT
MANUFACTURER to whom YOU ASBESTOS-CONTAINING FRICTION
;PRODUCTSand as to each ORIGINAL EQUIPMENT MANUFACTURER, IDENTIFY
the ASBESTOS-CONTAINING FRICTION PRODUCT that YOU MARKETED to
them and the inclusive years that YoU did so.

A, Bither attach] all DOCUMENTS or disks containing such
data, evidencing the infofmation sought in this interrogatory and
ite subparts to YOUR ans to these interrogatories or deacribe
such DOCUMENTS with sufficient particularity that they may be
made the subject ef a reqbest for production of documents;

BR. IDENTIFY the person{s) presently most Knowledgeable
about the information soup: in thid interrogatory or ite
subparts.

ANSWER: No.

i

47, Did YOU or any of [YOUR predecessors-in-interest MARKET
any ASBESTOS~CONTAINING FRICTION PRODUCTS to any PRIVATE BRAND
ACCOUNT CUSTOMER? If se,!for cach PRIVATE BRAND ACCOUNT

CUSTOMER, IDENTIFY and degoribe the NATURE of the product
i

TO STAND, 2T-
VWOA'S RESPONSESTO STANDARD INTERROGATORIESTO PRICTION DEFENDANTSwo arn awn WN

MARKETED to that PRIVATE [BRAND ACCOUNT CUSTOMER, the inclusive
dates thereof and, if kndun. , the name(s) under which the PRIVATE
BRAND ACCOUNT CUSTOMER MARKETED the product .

A. DESCRIBE to the best of YOUR knowledge how the
PRIVATE BRAND ACCOUNT CUSTOMER MARKETED the product which YOu
gold or distributed to it;

RB. Either attach all DOCUMENTS or disks containing such
data, evidencing the infgrmation sought in this interrogatory or
its subparts to YOUR anstore te these interrogatories or describe
guch DOCUMENTS with sufficient particularity that they may be
made the subject of a reduest for production of documenta;

C. IDENTIFY the person(s} presently most knowledgeable
about the information sought in this interrogatory or its
subparts. '

ANSWER: No. :

48. Did YOU or any of YOUR predecessors-in-interest MARKET
any ASBESTOS-CONTAINING ICTION PRODUCTS to any AFTER MARKET or
REPLACEMENT PART RETAILER operating 1¢ or more stores in the
GROGRAPHEC ARBA? If so, |IDENTTFY each APTER MARKET or
REPLACEMENT PART RETAILER in the GEOGRAPHIC AREA and for each
please state:

A. The inclusivg *yearsduring which YOU MARKETED
products to said AFTER Toor REPLACEMENT PART RETAILER;

B, IDENTIFY the ASBESTOS-CONTAINING FRICTION PRODUCTS
which YOU MARKETED to thd AFTER MARKET or REPLACEMENT PART
RETAILRR ; i

i
c. Either attack all DOCUMENTS or disks containing such

data, evidencing the internation sought in this interrogatory and

‘vwoa's RESPONSES TO STANDARD INTERROGATORIESTO FRICTION DEFRNDANTS
CAWINDOWSDESRTONVWI2ISEF,Soo I OO OO

its subparts to YOUR anawers to these interrogatories or describe
such DOCUMENTS with sufficient particularity that they may be
made the subject of a request for production of documents;

D. IDENTIFY the person(s) presently most knowledgeable
about the information sought in this interrogatory or ita
subparts.

SNSWER: No.

49. Did YOU or amy of YOUR predecessors-in-interest MARKET

any ASBESTOS-CONTAINING FRICTION SRODUCTS to any warehouse
distributor who MARKETED the product under YOUR name in the
GEOGRAPHIC AREA? If se, IDENTIFY each warehouse distributor who
MARKETED the product under your name in the GEOGRAPHIC ARBA and
for each state:

A. The inclusive years during which YOU MARKETED
ASBESTOS-CONTAINING FRICTION PRODUCTS to said warehouse
distributor who distributed the product under YOUR NAME;

B, IDENTIFY the ASBESTOS-CONTAINING FRICTION PRODUCTS
which YOU MARKETED to the warehouse distributor whe diatributed
the products under YOUR name;

Cc, Bither attach a1) DOCUMENTS or diaka containing such
data, evidencing the information sought in this interregatory and
its subparts te YOUR answers to these interrogatories or describe
such DOCUMENTS with sufficient particularity that they may be
made the subject of a request for production of documents;

D, IDENTIFY the person(s) presently most knowledgeable
about the information soug'htin this interrogatory or ita
subparts.

ANSWER: VWoA sold brake shoes and clutch plates to

A'S RESPONSES UES EFEND, -29-
VWOA'S RESPONSES TO STANDARD INTERROGATORIES TO FRICTION DEFENDANTS. “29°wo ON Rw ON oe

a5

independant distributors Compecition Metors, Inc., then
Volkswagen Pacific, Inc. until 1973.’ VWoA also sold these parts
to Reynold C. Johnson until 1973. VWoA has a list which

references these companies. As to subpart D., VROA is unable to

identify which of its employees is most knowledgeable of the
jmformation sought in this interrogatory. An individual with
knowledge is Mr. Yves Le Coz, Senior Engineer, Product Analysis,
c/o VWoA, 600 Sylvan Averue, Englewood Cliffs, New Jersey,

60, Did YOU or any of YOUR predecessors-in- interest MARKET
any ASBESTOS~CONTAINING FRICTION PRODUCTS to any warehouse
distributor who MARKETED YOUR ASBESTOS-CONTAINING FRICTION
PRODUCTS under a name other than YOURS in the GEQGRAPHIC AREA?
If so, IDENTIFY each warehouse distributor who MARKETED YOUR
ASBESTOS-CONTAINING FRICTION PRODUCTS under a name other than
YOURS in the GEOGRAPHIC AREA and for each please state:

A. Whe inclusive years during which YOU MARKETED
ASBESTOS-CONTAINING FRICTION PRODUCTS through said warehouse
distributor;

B, IDENTIFY the products which YOU MARKETED through the
warehouse distributor and for each the name under which the
warehouse distributed MARKETED the product;

Cc. Sither attach all DOCUMENTS or disks co'ntainingsuch
data, evidencing the information sought in this interrogatory and
its subparts to YOUR anawera to these interrogatories or describe
such DOCUMENTS with sufficient particularity that they may be
made the subject of a request for production of documents;

D. IDENTIFY the person{s) presentiy most knowledgeable

about the information sought in thie interrogatory er ite

YWOA'S RESPONSES TO STANDARD INTERROGATORIES TO FRICTION DEFENDANTS -30-
‘CAREIDOWSDESKTORVH 20ST,subparts.
ANSWER: VWoA did not market any ‘such products as described in

this interrogatory.

51. Did YOU or any of YOUR predecessors-in-interest MARKET
any ASBESTOS-CONTAINING FRICTION PRODUCTS to any retailer
operating 10 or more stoxes in the GEOGRAPHIC AREA who sold
ASBESTOS-CONTAINING FRICTION PRODUCTS under YOUR name in the
GEOGRAPHIC AREA? If so, IDENTIFY each retailer who gold
ASBESTOS-CONTAINING FRICTION PRODUCTS under YOUR name in the
GEOGRAPHIC AREA and for each state:

A. The inclusive years during which YOU MARKETED
ASBESTOS-CONTAINING FRICTION PRODUCTS to said retailer who sold
the product under YOUR name;

B. Please identify the ASBESTOS-CONTAINING FRICTION
PRODUCTS which YOU MARKETED to the retailer who sold the product
under YOUR name;

c. Either attach all DOCUMENTS or disks containing such

data, evidencing the information sought in this interrogatory and
19] ite subparte to YOUR answers to these interrogatoriea or describe
20|| such DOCUMENTS with sufficient particularity that they may be

21 made the subject of a request for production of documents;

2 D. IDENTIFY the person(s} presently most knowledgeable

231] ahout the information sought in this interrogatory or its

aA subparts.

25 ANSWER: VWoA did not market any such products as deacribed in
26] thie interrogatozy.

27 82. Did You or any of YOUR predecessors-in-interest MARKET
28 || any ASBESTOS-CONTAINING FRICTION PRODUCTS to any retailer

YWOA'S RESPONSES TO STANDARD INTERROGATORIES TO FRICTIONDEPENDANTS “31+
CAWINDOWAREEETOR YW 1203,operating 10 or more stores in the GEOGRAPHIC AREA who MARKETED
the product under any other name in the GHOGRAPHIC AREA? If so,
IDENTIFY each retailer who MARKETED the product under any other
mame in the GEOGRAPHIC AREA. and for each state:

AL The inclusive years during which YOU MARKETED
products through said retailer;

B, IDENTIFY the products which YOU MARKETED through each
retailer and, for each, the name under which the retailer
MARKETED the product;

C, Bither attach all DOCUMENTS or disks containing such
data, evidencing the information sought in this interrogatory and
its subparts to YOUR answers to these interrogatories or describe
such DOCUMENTS with sufficient particularity that they may b made
the subject of a request for prodvction of documents;

D. IDENTIFY the person(s} presently most knowledgeable
about the information sought in this interrogatory or its
subparts.

ANSWER: VHoA did not muxker any auch products as described in
this interrogatory.

83, Did YOU or any of YOUR predecessors-in-intereat WARERT
ASBESTOS-CONTAINING FRICTICN PRODUCTS to any FABRICATOR OF
ORIGINAL EQUIEMENT PARTS? If so, IDENPIFY cach FABRICATOR OF
ORIGINAL EQUIPMENT PARTS, state:

A, The inclusive ‘yearsduring which YOU MARKETED said
products to each FABRICATOR OF ORIGINAL PARTS;

B, IDENTIFY each product YOU MARKETED to each FABRICATOR
OF ORIGINAL PARTS;

¢, Either attach all DOCUMENTS or disks containing such

YWOA'S RESPONSES TO STANDARD INTERROGATORIES TO FRICTION DEFENDANTS “32+
CAWINDOWRDESKTORYW [2051F,data, evidencing the information sought in this interrogatory and
its subparts to YOUR answers to these interrogatories or describe
such DOCUMENTS with sufficient particularity that they may be
made the subject ef a request for production of docutrents;

D, IDENTIFY the person(s} presently most kmowledgeable
about the information sought in this interrogatory or its
subparts.

ANSWER: VHeA did not market any such products aa described in
this interrogatory.

54, Did YOU or any of YOUR predecessors-in-interest MARKET
any ASBESTOS-CONTAINING FRICTION PRODUCTS te any agency or
department of the U.S. Government? If so, IDENTIFY each agency
er department of the U.S. Govertment to whom YOU MARKETED
products and as te each agency or department of the U.S.
Government IDENTIFY the product that YOU MARKETED to them and the
inclusive years that YOU did so.

A. Hither attach all DOCUMENTS or disks containing such
data, evidencing the informa