Document 3NYGJvO6nYedLBZ4Vyo5d0y7a

1 RESPONSE: 2 (a) Asbestos Corporation, Ltd., Thetford Mines, Que 3 bec, Canada; Bell Asbestos Mines, Ltd., Thetford Mines, Quebec, 4 Canada; Lake Asbestos, Black Lake, Quebec, Canada; Johns5 Manville Corporation, Quebec, Canada; and Vermont Asbestos Group, 6 Inc., Hyde Park, Vermont; 7 (b) Yes. 8 (c) and (d) Defendant does not have records which 9 reflect- such information; however, it presently recalls that it 10 believes cautionary warnings did accompany asbestos purchased 11 from the Canadian Mines beginning in mid-1972 and from Vermont 12 Asbestos Group beginning in mid-1974. Current cautionary 13 instructions are as follows: 14 Bell Asbestos Mines, Ltd: WARNING. Contains asbestos fibers. 15 Avoid creating dust. Breathing asbestos dust may cause cancer and 16 other fatal diseases. Smoking greatly increases the lung cancer 17 risk. [Note: The cautionary instruction also appears in 18 French.] 19 Asbestos Corporation, Ltd.: CAUTION. Contains asbestos fibers. 20 Avoid creating dust. Breathing asbestos dust may cause serious 21 bodily harm. [Note.- The cautionary instruction also appears in 22 French.] 23 Johns-Manville Corporation: CAUTION. Contains asbestos fibers. 24 Avoid creating dust- Breathing asbestos dust may cause serious 25 bodily harm. Smoking greatly increases the risk of serious 26 bodily harm. [Note: The cautionary instruction also appears in 27 five other languages.] NZO 0* 28 /// Afl O '16 i