Document Gm0LK2VJo32gZk3D6epqbo1rN

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. 66: With respect to each product identified in response to Interrogatory No. 65 as having been accompanied by a warning, state whether, subsequent to the first warning described above, any different warning was ever placed upon said product. Any alteration, change or modification in the language, wording, capitalization, punctuation, style of type or printing, size, color, or location on the package or container, of the warning constitutes a different warning. RESPONSE: See Union Carbide's Response to Interrogatory Nos. 63 and 64, including all objections set forth therein. INTERROGATORY NO. 67: With respect to each different warning which accompanied each product listed in response to Interrogatory No. 65: (a) State the date on which any order directing that such different warning be placed on said product first issued; (b) Identify any and all persons participating in the decision to issue that order; (c) State the first date on which such different warning was actually placed on said product; (d) State the first date on which such product accompanied by such different warning was sold, distributed or installed; (e) Describe, with specificity, any and all changes, modifications or differences between the different warning and the prior wamings(s); (f) Identify any and all persons who participated in any phase of the drafting or design of such different warning, including, but not limited to, those who performed the actual drafting and design work, those who reviewed the work, those who edited the work and those who approved the different warning; (g) State why you placed such different warning on said product, including, but not limited to, whether you placed such different warning on said product because you received a directive, command, suggestion, legal opinion, or any type of communication (written or otherwise) from any person, firm, corporation, governmental agency, committee, association, attorney or institute; and (h) Identify any and all documents referring to, relating to or reflecting, said different warning, its drafting, and/or the decision to place the different warning on said product. DOCSNYl: 1012018.1 45