Document G6z3wJkw2YbQwGj8VnqrDdOdx

Additional information responsive to this Interrogatory, and in the possession of Union Carbide, is located in the repositories maintained by Union Carbide's counsel. INTERROGATORY NO. 83: With regard to any knowledge or information obtained subsequent to that identified in your answer to Interrogatory No. 82 (a), identify any and all documents or communications (oral and/or written) concerning the causal connection between exposure to asbestos-containing or asbestos products and any disease, which were sent to, or received by. Defendant, and identify any and all persons conveying and/or receiving such communications. RESPONSE: See General Objections Nos. 1-8. Union Carbide further objects to this Interrogatory on the ground that 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: Information responsive to this Interrogatory, and in the possession of Union Carbide, is located in the repositories maintained by Union Carbide's counsel. See also Union Carbide's Response to Interrogatory Nos. 63,64, and 79. INTERROGATORY NO. 84: As to any knowledge or information referred to in Interrogatories 79-83, did Defendant, at any time, educate or inform its employees, distributors, purchasers or any persons working in the vicinity where any asbestos-containing product was being applied or installed as to the hazards known to Defendant or about which Defendant had information, and as to the safety precautions necessary to guard against cancer and other diseases arising from the use and handling of the products identified in response to Interrogatory No. 19? RESPONSE: See General Objections Nos. 1-8. Union Carbide further objects to this Interrogatory on the grounds that it is overly broad, unduly burdensome, and not reasonably calculated to lead to the discovery of admissible evidence. Union Carbide further objects to this Interrogatory to the extent that it calls for information about Union Carbide employees or premises, or policies pertaining to Union Carbide employees or premises that are unrelated to the claims in this litigation on the grounds that such requests are 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: The Calidria asbestos mined and sold by Union Carbide from the Coalinga ore deposit is a unique short-fiber, pure chrysotile asbestos uncontaminated by tremolite asbestos. Tremolite is a form of amphibole asbestos that can contaminate chrysotile ore from certain locations and has also been recognized as a contaminant of some vermiculite and talc deposits. There is no scientific basis today to conclude that Calidria caused or contributed to the causation of mesothelioma, lung cancer, asbestosis, pleural plaques, or any alleged asbestos associated DOCSNYI:I012018.1 54