Document 2RZkbExw9QerqrZdqOD7gYY95

RESPONSE: See General Objections Nos. 1-8. Union Carbide further objects to this Interrogatory on the grounds it is overly broad, unduly burdensome, and not reasonably calculated to lead to the discovery of admissible evidence. Subject to its objections, Union Carbide responds as follows: Documents responsive to this Interrogatory, and in the possession of Union Carbide, are located in the repositories maintained by Union Carbide's counsel. INTERROGATORY NO. 99: Identify any and all documents including, but not limited to, minutes, bulletins or reports, created by, or on behalfof, any trade organization, association or entity listed in response to Interrogatory No. 94 and/or 97 or any committee, subcommittee or subgroup thereof; (a) which refer to, relate to or reflect the subject of asbestos; (b) which refer to, relate to or reflect a relationship between asbestos exposure and any disease; or (c) which refer to, relate to or reflect the placement or providing of warnings with respect to hazardous products. RESPONSE: See General Objections Nos. 1-8. Union Carbide further objects to this Interrogatory on the grounds it is overly broad, unduly burdensome, and not reasonably calculated to lead to the discovery of admissible evidence. Subject to its objections. Union Carbide responds as follows: Documents responsive to this Interrogatory, and in the possession of Union Carbide, are located in the repositories maintained by Union Carbide's counsel. INTERROGATORY NO. 100: Identify any and all documents including, but not limited to, minutes, bulletins or reports, received by, or on behalfof, any trade organization, association or entity listed in response to Interrogatory No. 94 and/or 97, or any committee, subcommittee or subgroup thereof; (a) which refer to, relate to or reflect the subject of asbestos; (b) which refer to, relate to or reflect a relationship between asbestos exposure and any disease; or (c) which refer to, relate to or reflect the placement or providing of warnings with respect to hazardous products. RESPONSE: See Union Carbide's Response to Interrogatory No. 99, including all objections set forth DOCSNYI:1012018.1 63