Document J30MOpj11jBQ9KZY4V4dbYgYe

(a) As to each product, whether such product is mined, manufactured, and/or marketed or sold. (b) The names and addresses of the companies mining, manufacturing, marketing, and/or selling each of those products. (c) The trade or brand name of each of those products mined, manufactured, marketed, and/or sold. (d) The date each of the named products was placed on the market. (e) A description of the physical (chemical) composition of each of the named products, including the type of asbestos contained in the product. (f) A description of the physical appearance of each product and its packaging. (g) A detailed description of the intended uses of each of the named products. (h) Whether there are any warning labels on said products or containers regarding potential asbestos-related health hazards. RESPONSE: See responses to 6 and 14. INTERROGATORY NO. 38: State whether you or any of your predecessors and/or subsidiaries maintain, from 1940 through the present or for any portion thereof, copies of invoices, shipping documents, bills of lading, purchase orders, or other documents of a similar nature relating to the mining, manufacture, marketing, sale or distribution of asbestos products. If so, state: (a) The location of such documents. (b) The name and address of the custodian of the documents. (c) The format in which the documents are kept, i.e., hard copy, microfilm, microfiche, etc. (d) In what form the documents can be accessed, i.e., by state, by product, etc., and if by product, whether kept according to asbestos or non-asbestos. 33