Document 6BqEwwvVokjwzgNMp0jdnqVqR

FILE NAME: General Electric (GE) DATE: 0000 DOC#: GE096 DOCUMENT DESCRIPTION: Legal - Excerpts from Amended Responses to Interrogatories 1 ) SEDGWICK, DETERT, MORAN & ARNOLD LLP CHARLES SHELDON Bar No. 155598 ' 2 MARC BRATNICH Bar No. 191034 One Embarcadero Center, 16th Floor 3 San Francisco, California 94111-3628 Telephone: (415) 781-7900 4 Facsimile: (415) 781-2635 5 Attorneys for Defendant GENERAL ELECTRIC COMPANY 6 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 CITY AND COUNTY OF SAN FRANCISCO 10 11 IN RE: CASE NO. 828684 12 COMPLEX ASBESTOS LITIGATION. 13 14 GENERAL ELECTRIC COMPANY'S AMENDED RESPONSES TO PLAINTIFF'S GENERAL ORDER NO. 129 STANDARD INTERROGATORIES TO ALL DEFENDANTS 15 16 17 RESPONDING PARTY: GENERAL ELECTRIC COMPANY 18 SET NUMBER: STANDARD INTERROGATORIES TO ALL DEFENDANTS 19 fl-53] 20 Pursuant to section 2030 o f the California Code o f Civil Procedure, and San Francisco 21 Superior Court General Order No. 129, defendant General Electric Company ("GE" or 22 "Defendant") hereby submits the following Amended Responses to the General Order 129 23 Standard Interrogatories to All Defendants. 24 25 AUTHORIZED OBJECTIONS AND RESERVATIONS 26 1. These responses are made solely for the purpose o f responding to standard 27 interrogatories pursuant to General Order No. 129. Under General Older 129, objections are not 28 allowed except on grounds o fattorney-client privilege, work product doctrine and/or burden. GE SF/l 152304vl ______________________________________________ - l - _______________________________________________________________________ G E 'S AM ENDED'RESPONSBS TO G .0 .129 STANDARD INTERROGATORIES O 1 U. U. S. Maritime Commission; 2 V. IDENTIFY any other organizations, associations or groups of manufacturers, 3 miners, distributors, importers, labelers, suppliers, and/or sellers o f ASBESTOS-CONTAINING 4 PRODUCTS o fwhich THIS DEFENDANT was a member, 5 W. IDENTIFY any such representative o f THIS DEFENDANT. 6 RESPONSE TO INTERROGATORY NO. 13: 7 GE has never been a miner,miller or supplier o f RAW ASBESTOS fiber. 8 GE is a large, decentralized company comprised o f numerous separate businesses with 9 over 300,000 employees. G6 operates in more than 100 countries around the world, and since 10 1979, GE has bought and/or sold thousands o f businesses. See 11 http://www.ge.ram/investor/annuals.hlm. GE may be unable to fully determine whether, during 12 the period between GE's incorporation in the 1890s and the end o f the `Time frame," GE may 13 have paid dues for any representative or employee to be a member o f the named organizations. 14 GE further states that because it is a large, decentralized company with facilities in numerous 15 states and foreign countries, and because there is no central repository for information o f the type 16 sought by way o f this interrogatory, GE no longer has, or never had, frie documents required to 17 fully answer this interrogatory. 18 Notwithstanding the above, GE further states that it has never been a membra' of the 19 asbestos industry as that term is commonly used, nor has it ever been a member o f the trade 20 organizations o fthe asbestos industry. GE responds further below: 21 A. American Conference o f Governmental Industrial Hygienists: GE states that some 22 o f its employees may have been members o f the American Conference o f Governmental 23 Industrial Hygienists ("ACGEFO at some points in (heir individual careers. GE has not been able 24 to locate historical materials in its possession received from the ACGIH during the relevant time 25 period. GE further states, however, that it is continuing to search for documents in its own files 26 confirming its historical membership in the ACGIH. SjfovKX 27 V w ^ w W N iM R IU h r 28 B. American Industrial Hygiene Association: Upon information and belief some o f GE's employees are currently members o f the American Industrial Hygiene Association. SF/I15230ivl ________________________________^ __________________________________________________ GE's Am en d ed Respo n ses t o G .0 .129 sta nd ard in terro g a to ries O \ ) 1 However, GE has not been able to determine whether any o f its employees may have been 2 members o f the American Industrial Hygiene Association at some points in their individual t. 3 careers daring the time period at issue in these discovery requests or whether GE received any 4 materials from the American Industrial Hygiene Association during the time period at issue in 5 these discovery requests. Investigation continues. 6 C. American Petroleum Institute: To date, GE's investigation has not discovered any 7 information or documents indicating that GE was ever a member, or paid dues for any 8 representative to be a member, o f this organization. 9 D. American Railroad Association: To date, GE's investigation has not discovered 10 any information or documents indicating that GE. was ever a member, or paid dues for any 11 representative to be a member, o f this organization. 12 E . Asbestos Cement Producers Association: To date, GE's investigation has not 13 discovered any information or documents indicating that GE was ever a member, or paid dues for 14 any representative to be a member, o fthis organization. <4 15 F . Asbestos information Association (AIA): To date, GE's investigation has not 16 discovered any information or documents indicating that GE was ever a member, or paid dues for 17 any representative to be a member, o f this organization. 18 G. Asbestos Information Association/North America (AIA/NA): To date, GE's 19 investigation has not discovered any information or documents indicating that GE was ever a 20 member, or paid dues for any representative to be a member, o f this organization. 21 H . Asbestos Textile Institute (AH'!): To date, GE's investigation has net discovered 22 any information or documents indicating that GE was ever a member, or paid dues for any 23 representative to be a member, o f this organization. 24 I. Industrial Hygiene Foundation and /or Industrial Health Foundation QHF): Upon 25 information and belief in 1947, GE became a member o f the Industrial Hygiene Foundation 26 (`THF"), an association o f industrial hygiene professionals from government, academia, and 27 S&02S 28 industry which shared technical information relating to current industrial hygiene topics about numerous industrial materials among its members. GE has not been able to locate historical SF/U52304V1 -24GE's A m en d e d Respo n ses to G .0 .129 standard in ter ro g a to r ies s fe s s n i ) 1 materials in its possession received from the fflP during the time period at issue in this discovery. 2 GE continues to search for documents in its own files confirming its historical membership in the 3 IHF. 4 J . Industrial Mineral Insulation Manufacturers Institute: To date, GE's investigation 5 has not discovered any information or documents indicating that GE was ever a member, or paid 6 dues for any representative to be a member, o f this organization. 7 K. Magnesia Insulation Manufacturers* Association: To date, GE's investigation has 8 not discovered any information or documents indicating that GE was ever a member, or paid 9 dues for any representative to be a member, o fthis organization. 10 L. Magnesia Silica Insolation Manufacturers Association: To date, GE's 11 investigation has not discovered any information or documents indicating that GE was ever a 12 member, or paid dues for any representative to be a member, o f this organization. 13 M. Mineral Wool Institute: To date, GE's investigation has not discovered any 14 information or documents indicating that GE was ever a member, or paid dues for any 15 representative to be a member, o f this organization. 16 N. National Insulation Manufacturers Association (N1MA): To date, GE's 17 investigation has not discovered any information or documents indicating that GE was ever a 18 member, or paid dues for any representative to be a member, o f this organization. 19 O. National Safety Council: Upon information and belief GE was a charter member 20 o f the National Safety Council ("N SC 1) in approximately 1913. It has also been brought to GE's 21 attention through documents produced by other parties in asbestos-related litigation that some of 22 its employees may have been members o f the NSC at some points in their individual careers. 23 However, GE has not been able to locate any documents in its own files demonstrating this, and 24 therefore cannot attest to foe authenticity o f foe documents or the information contained therein 25 relating to membership in the NSC. GE has not been able to locate historical materials in its 26 possession received from foe NSC or which relate to foe NSC during the time period at issue in 27 this discovery. GE's investigation continues and it reserves to supplement this response if 28 additional relevant material becomes available. SM152304VI ______________________ -25z_____________ :_________ G E 'S AM ENDED RESPONSES TO G . 0 . 1 2 9 STANDARD INTERROGATORIES o 1 P. New York Academy o f Sciences; To date, GE's investigation has not discovered 2 any information or documents indicating that GE was ever a member, or paid dues for any 3 representative to be a member, o f this organization. 4 Q . Quebec Asbestos Mining Association (QAMA):. To date, GE's investigation has 5 not discovered any information or documents indicating that GB was ever a member, or paid 6 dues for any representative to be a member, o f this organization 7 R. Refractories Institute: To date, GE's investigation has not discovered any 8 information or documents indicating that GE was ever a member, or paid dues for any 9 representative to be a member, o f tins organization 10 S. Safe Building Alliance: To date, GE's investigation has not discovered any 11 information or documents indicating that GE was ever a member, or paid dues for any 12 representative to be a member, o ftins organization 13 T. Thermal Insulation Manufacturers Association (TIMA): To date, GE's 14 investigation has not discovered any information or documents indicating that GE was ever a 15 member, or paid dues for any representative to be a member, o f this organization 16 U. U. S. Maritime Commission: This was and is an agency o f the U.S. federal 17 government and it is not clear how any person could pay "dues" or become a "member" o f this 18 agency. 19 V. [Other described organizations]: Additionally, it has been brought to GE's 20 attention through documents produced by other parties in asbestos-related litigation that some of 21 its employees were members o f the American Ceramics Society at some points in their individual 22 careers. However, GB has not been able to locate these documents in its own files, and therefore 23 cannot attest to their authenticity. Nonetheless, upon request, GE w ill produce copies o f these 24 documents to plaintiffs' counsel at a mutually convenient time and place. GE further states upon 25 information and belief that certain GE businesses were at various points in time members o f the 26 National Electrical Manufacturers Association ("NEMA"). 27 W . See Responses to Subparts A through V. 28 GE's investigation continues and it reserves to supplement this response if additional SP/1I52304v1 ________________________________________________________________ GE's Amended Responses to G .0 .129 standard interrogatories o o 1 RESPONSE TO INTERROGATORY NO. 16: 2 GE is a large, decentralized company comprised o f numerous separate businesses with 3 over 300,000 employees. GE operates in more than 100 countries around the world. Since 1979, 4 GE has bought and/or sold thousands o f businesses. See 5 http://www.ge.com/investor/aniiuals.htm. GE further states that because it is a large, 6 decentralized company with facilities in numerous states and foreign countries, and because there 7 is no central repository for information o f the type sought by way o f tins interrogatory, GE may 8 no longer have, or never have had, the documents required to fully answer this interrogatory. 9 There is no possible way to determine whether or not, during the period between GE's 10 incorporation in the 1890s and 1973, any GE employee received a copy or any portion o f a study 11 or test conducted by an insurance company, including but not limited to Metropolitan Life 12 Insurance Company and Aetna Insurance, "relating to asbestos exposure in the workplace or the 13 human health consequences o f exposure to asbestos." L4 Notwithstanding the above, GE states that it has conducted a reasonably thorough and 15 diligent search and has not been able to locate any documents or records reflecting receipt o f any 16 such documents prior to 1973. 17 18 INTERROGATORY NO. 17: 19 Had THIS DEFENDANT prior to 1973 received any DOCUMENTS containing results or 20 conclusions o f any studies and/or tests conducted by any laboratory, including but not limited to, 21 the Saranac Laboratory relating to asbestos exposure in the workplace or the human health 22 consequences o f exposure to asbestos? If so: 23 A. Either (1) attach all DOCUMENTS evidencing the information sought in this 24 Interrogatory and its subparts to your answers to these Interrogatories, or (2) attach disks 25 containing such data, or (3) describe such DOCUMENTS with sufficient particularity that they 26 may be made the subject o f a request for production o f documents. 27 B. State the date upon which THIS DEFENDANT first received such 28 DOCUMENTS; SF/l 152304! _______________________-JS^______________________ GE's Amended Responses to G .0 .129 standard mtbrroqatories o n 1 C. State the IDENTITY o f the custodian o f such DOCUMENTS. 2 D. This interrogatory does not apply to DOCUMENTS contained in a library 3 maintained by a DEFENDANT hospital or a DEFENDANT'S library providing access to the 4 general public. 5 RESPONSE TO INTERROGATORY NO. 17: 6 GE is a large, decentralized company comprised o f numerous separate businesses with 7 over 300,000 employees. GE operates in more than 100 countries around the world. Since 1979, 8 GE has bought and/or sold thousands o f businesses. See 9 http://www.ge.com/investor/annuals.htm. GE further states that because it is a large, 10 decentralized company with facilities in numerous states and foreign countries, and because there 11 is no central repository for information o f the type sought by way o f this interrogatory, GE may 12 no longer have, or never have had, the documents required to fully answer this interrogatory. 13 There is no possible way to determine whether or not, during the period between GE's 14 incorporation in the 1890s and 1973, a GE employee received a document that contained results 4 or conclusions o f a study or test conducted by a laboratory, including but not limited to, the 16 Saranac Laboratory, "relating to asbestos exposure in the workplace or the human health 17 consequences o f exposure to asbestos." 18 Notwithstanding the above, GE states that it would have received or become aware o f the 19 results o f studies performed by the U.S. Public Health Service in 1938 published by Dr. Dreesen 20 ("A Study o f Asbestosis in the Asbestos Textile Industry," Public Health Bull. No. 241, 21 Washington, D.C.: U.S. Public Health Service (1938)) and the U.S. Maritime Administration 22 published by Fleischer and Drinker in 1946 ("A Survey o f Pipecovering Operations in 23 Constructing Naval Vessels," J. Indust. Hyg. Tox. 28:9-16 (1946)). Indeed, GE does not deny 24 that it would have known o f the existence o f medical and scientific literature and studies as well 25 as government regulations and standards pertaining to asbestos exposure at various levels going 26 back to early part o f the last century. 27 28 S F /U 32304vl ______________________ r30:______________________ GE's Amended Responses to G .0 .129 standard interrogatories ` J J o n 1 A. Whether chest x-rays or pulmonary fonction, tests were part o f such program(s); B. Whether participation in any such program was a mandatory condition o f 3 employment or was voluntary; 4 C. Whether THIS DEFENDANT has DOCUMENTS o f such program(s); 5 D. The IDENTITY of foe custodian o f such DOCUMENTS. 6 BESPONSE TO INTERROGATORY NO. 24t 7 GE objects to the extent fois Interrogatory potentially calls for confidential medical 8 information regarding its employees. Subject to and without waiving this objection, GE states 9 that it at all times kept itselfinformed o ffoe prevailing standard o f medical art and the prevailing 10 standards o f foe industry relating to its products. In or about 1972, when OSHA began 11 mandating medical surveillance for certain employees, GE would have complied with such 12 regulations. Further, prior to foe formation o f OSHA, in cooperation with foe Massachusetts 13 Department o f Health, certain o f its Lowell, MA employees may have participated in a medical 14 surveillance program; such examinations were not required by regulation. GE has not been able 15 to locate documents relating to tins medical surveillance program in its own files, but has 16 obtained copies o f certain documents with information about tins program from foe government 17 through a FOIA request. These documents are as available to plaintiffs as to this defendant. 18 GE further states that because it is a large, decentralized company with facilities in 19 numerous states and foreign countries, because there is no central repository for information o f 20 foe type sought by way o f this interrogatory, and because GE no longer has, or never had, many 21 o f foe documents required to answer this interrogatory, GE is unable to fully respond to this 22 Interrogatory. Nonetheless, GE's investigation is continuing, and GE reserves the right to 23 supplement its responses. 25 INTERROGATORY NO. 25: 26 Prior to 1973, did any person file a Workers' Compensation claim for asbestos-related A a v ic x " injury against THIS DEFENDANT or against any Workers' Compensation insurance carrier which provided coverage for THIS DEFENDANT? If so, state foe total number o f such claims SF/l 152304vl -37GE's Am ended Responses to G .0.129standard interrogatories  J ^ o n 1 and, for the first 20 such claims state: A. The date o f such claim; 3 B. The name o fthe claimant; 4 C. The case number, 5 D. The court in "whichthe claim was filed; 6 E. The IDENTITY o f THIS DEFENDANT'S custodian o f DOCUMENTS 7 evidencing such claims. 8 RESPONSE TO INTERROGATORY NO. 25: 9 GE is aware o f a historical paper card file maintained at one time by a third-party 10 administrator, Sedgwick Claims Management, Inc., in Albany, New York for workers 11 compensation claims prior to 1990. The file contains eight cards for seven claimants reflecting 12 "dates o f accidents" for asbestosis and one for lung cancer prior to 1970. It is not clear whether 13 the "date o f the accident" reflects the dates o f 1he claims or the dates o f employment/exposure, 14 nor is it apparent if and when GE became aware o f these claims. The dates on which reserves 15 were set, however, would indicate that none o f these claims were made before 1971. Upon 16 request, these cards will be made available for inspection at a mutually convenient time and 17 place, or copies will be produced. 18 19 INTERROGATORY NO. 26: 20 Does USES DEFENDANT have insurance available to cover judgm ents) entered against 21 it in asbestos-related personal injury lawsuits? If so, state: 22 A. The name and principal place o f business o f any insurance carrier who has issued 23 such policy o f insurance; 24 B. The number and effective date o f each policy; 25 C. The amount(s) o f coverage o f each policy; 26 D. The applicable dates o f coverage. RESPONSE TO INTERROGATORY NO. 26: 27 Yes. GE states that it is currently insured under multiple liability policies which provide SM152304vl -38GE's Am ended Responses to G .0.129standard interrogatories o \ I 1 asbestos, or been used in connection with products that contained asbestos, during a time period 2 which may or mayriot be relevant to any given case. 3 .By way o f further response, based on its investigation to date in asbestos related litigation 4 across the country, GE provides the following additional information. GE's investigation 5 continues about the products in many cases as noted below. Additionally, because relevant 6 information about any given product may vary depending on the facts specific to any given case - 7 including dates o f alleged exposure, information about the specific model, serial number or type 8 o f product allegedly at issue - GE will work with plaintiffs' counsel in each specific case to 9 gather additional relevant, existing, and responsive information. 10 11 Land- Based Steam Turbines 12 (A) The generic name o f this product is land-based steam turbine. 13 (B) GE has been manufacturing and selling land-based steam turbines for 14 approximately the last one hundred years. Whether asbestos-containing materials were used in 15 connection with GE's land-based steam turbines may, in some instances, be determined from 16 individual records pertaining to a particular site and the steam turbines installed there, to the 17 extent such records are available. GE continues to investigate when asbestos-containing 18 materials were first used in connection with its land-based steam turbines. See also GE's 19 Response to Subpart D, infra. 20 (C) The Turbine Business Operations division began recommending to its customers 21 that insulation materials applied by others on its land turbines be o f asbestos-free materials in the 22 early 1970s. Answering further, whether some other asbestos-containing materials were used in 23 connection with GE's land-based steam turbines may, in some instances, be determined from \ 24 individual records pertaining to a particular site and the steam turbines installed there, to the 25 extent such records are available. GE continues to investigate when any such other asbestos- 26 containing materials were no longer used in connection with its land-based steam turbines. See 27 also GE's Response to Subpart D, infra. 28 (D) GE's land-based steam turbines are not asbestos or asbestos-containing products SF/l 152304vl _____________________________ __________________________________ GE's Amended Responses to G .0 .129 standard interrogatories c c ` 4, J 1 (B) GE's residential boilers varied in shape and size. Certain of GE's residential boilers may have been labeled with the GE logo, which is a cursive, capitalized "GE" in a circle. 3 (F) GE's residential boilers were used to heat water for home use. 4 (G) Investigation is continuing. 5 (H) Not applicable. 6 0 ) To the best o f its knowledge and belief GE no longer has purchase orders, 7 invoices, or similar documents with respect to the sales or supply o f its residential boilers to any 8 premise or site within the GEOGRAPHIC AREA. 9 (J) GE ceased the manufacture o f its residential boilers in 1956. Therefore, many o f 10 tiie documents, drawings and specifications for this product may no longer exist due to the 11 passage o f time. If plaintiffs provide GE with identifying information regarding a particular 12 residential boiler at issue in a case, such as a serial number, model number, or other identifying 13 information, GE will attempt to locate any existing relevant and responsive records' and, upon 14 request, will produce them to plaintiffs counsel at a mutually convenient tim e and place. J 15 16 Gas Turbines 17 (A) The generic name o f this product is gas turbine. 18 (B) GE continues to investigate when it first began to manufacture and sell gas 19 turbines that may have been used in connection with asbestos containing materials. 20 (C) GE continues to investigate when it no longer manufactured or sold gas turbines 21 that may have been used in connection with asbestos containing materials. 22 03) GE's gas turbines are not asbestos or asbestos-containing products as those terms 23 are commonly understood. Rather, they are mechanical devices made o f metal. GE's gas 24 turbines are used to convert heat energy into mechanical energy for various purposes in certain 25 industrial and marine applications. GE's gas turbines are manufactured by GE's Power Systems 26 and Aircraft Engines businesses. It is possible that some materials may have been used in A 27 connection with GE's gas turbines, during a period of time that may or may not be relevant to S V K & & 2g this litigation, that may have contained some quantity o f asbestos. These materials were SM152304vl -7 6 - OS's A m e n d e d R e s p o n s e s t o G .0.129s t a n d a r d in t e r r o g a t o r ie s n o r manufactured by outside vendors, not by GE. Furthermore, although gas turbines generally did i 1 not employ thermal insulation, it is possible that sn ail portions o f some individual units may 3 have been insulated with thermal insulation, that may have contained some quantity o f asbestos, 1based on customer requirements and circumstances, during a period o f time that may or may not 4 * 5 be relevant to any specific case. This thermal insulation material would have been manufactured 6 and installed by others, however, and not by GE. 7 The aforementioned other manufacturers and installers may have provided warnings or 8 other information concerning asbestos in their insulation producto that were used in connection 9 w ith GE's gas turbines. GE was not have been involved in the preparation o f such warnings. To 10 the best o f GE's knowledge, no warnings regarding such other manufacturer's products were 11 placed on the metal surfaces o f GE's gas turbines. Further, the nature and type o f thermal 12 insulation, if any, to be applied at any given site typically remained the prerogative o f the utility 13 or facility that purchased the turbine(s), and/or its consulting architect-engineers. GE is not 14 aware o f any clinical, epidemiological, toxicological, industrial hygiene, medical and/or scientific 3 15 literature demonstrating that GE's gas turbines cause asbestos-related disease. 16 Whether asbestos-containing materials were used in such applications, and their type, if 17 any, may, in some instances, be determined from individual records pertaining to a particular site 18 and the gas turbines installed there, to the extent such records are available. See Response to 19 Subpart J, infra. 20 GE's investigation with respect to its gas turbines is continuing and it reserves the right to 21 supplement its answer with additional existing, relevant, and responsive information. 22 (E) GE's gas turbines are mechanical devices made o f metal which varied in size and 23 shape. Certain o f GE's gas turbines may have been labeled with the GE logo, which is a cursive, 24 capitalized "GE" in a circle. 25 (F) GE's gas turbines are used to power various equipment in industrial and marine 26 applications. A 27 M^pEMUABOAu 28 (G) Investigation is continuing. (H) Not applicable. SF/1152304v! -77- G E 's A m e n d e d R e s p o n s e s to G . 0 . 129 standard interrogatories o ( the type sought by way o f this interrogatory, and because GG may no longer have, or never have 2 had, many o f the documents required to answer this interrogatory, its response may not be 3 comprehensive at this time and it reserves the right to supplement its responses. 4 5 INTERROGATORY NO. 43: 6 State whether or not any o f YOUR CONTRACT UNITS installed and/or removed RAW 7 ASBESTOS and/or ASBESTOS-CONTAINING PRODUCTS in the GEOGRAPHIC AREA at 8 anytim e between 1930 and 1985. If so; 9 A. State the business addresses and name o f the CONTRACT UNIT; 10 B. State the inclusive periods o f time the CONTRACT UNITS were working in the 11 GEOGRAPHIC AREA; 12 C. State the name and address o f each job site within the GEOGRAPHIC AREA and 13 the dates the CONTRACT UNIT worked at those job sites, and, IDENTIFY the RAW 14 ASBESTOS and/or ASBESTOS-CONTAINING PRODUCTS installed or removed on each 15 occasion; 16 D. Either (1) attach all DOCUMENTS evidencing the information sought in this 17 Interrogatory and its subparts to your answers to these Interrogatories, or (2) attach disks 18 containing such data, or (3) describe such DOCUMENTS with sufficient particularity that they 19 may be made the subject o f a request for production o f documents. 20 RESPONSE TO INTERROGATORY NO. 43; 21 Not applicable. See Response to Interrogatory No. 42, supra. 22 23 INTERROGATORY NO. 44; 24 When do YOU contend that THIS DEFENDANT first became aware that there is an 25 association between asbestos exposure and disease in human beings? 26 RESPONSE TO INTERROGATORY NO. 44; GE notes that the amount o f materials published in both the technical and popular press that discuss possible correlation between exposure to asbestos at sufficient levels, especially SF/U52304vl ______________________ 8;______________________ GE's A m end bd Respo n ses t o G .0 .129 sta n d a r d in ter ro g a to r ies