Document 4vrGGKyMXkRgk9QL0Z8VaZ09R
all documents referring to, relating to, and/or reflecting
the same:
(a) Asbestos;
(b) Asbestos-related disease;
(c) The hazards of asbestos;
(d) Working with and/or around asbestos (including, but not limited to, recommended practices, controls, TLVs, standards etc.);
(e) Medical monitoring of persons working with and/or around asbestos and/or otherwise exposed to asbestos;
(f) Marketing products;
asbestos
and/or
asbestos-containing
(g) Asbestos related claims and/or litigation;
(h) The
publication
and/or
dissemination
of
information concerning asbestos, asbestos-related
diseases and/or the hazards of asbestos (including
withholding the same);
(i) Warning, cautions and/or notices concerning . asbestos, asbestos- related diseases and/or the hazards of asbestos (including withholding the same);
(j) Government proceedings and/or actions regulating asbestos (including proposals to do so);
(k) Medical/scientific information and/or research concerning
(l) asbestos, asbestos-related diseases, ^working with and/or around asbestos, and/or the hazards of asbestos;
(m) Occupational health and safety / industrial hygiene (as they concern asbestos, asbestosrelated diseases, working with and/or around asbestos, and/or the hazards of asbestos).
ANSWER: - Gleason objects to this Interrogatory as overly broad, burdensome, harassing, excessive in scope and time and incorrectly implying that its products were a health hazard. By way of further response, see documents provided.
By way of further response, Gleason has been involved
GLEASON-000043