Document MmV4K624gNbg4J2zKe1qrNMx

during the course of its existence: Corporate Divisions ofUnion Carbide responsible for Calidria (1963-1985) (1963-1965) (1965-1967) (1967-1970) (1970-1984) (1984-1985) Nuclear Division Mining and Metals Division Chemicals and Plastic Division Mining and Metals Division UMETCO, a wholly owned subsidiary of Union Carbide, through Calidria Corporation, a wholly owned subsidiary of UMETCO. See also Union Carbide's Response to Interrogatory Nos. 16,18 and 19. INTERROGATORY NO. 21: Were any of the products, which were listed in response to Interrogatory No. 19 as having been specified, sold, distributed, applied or installed by Defendant, its predecessor or related company(ies), purchased from another company and re labeled for sale or distribution by Defendant, its predecessors or related companies? If so, identify those products, and with respect to each: (a) Identify the company from which Defendant, its predecessor or related company purchased the product; and, (b) Identify the company which manufactured the product; and, (c) State the date(s) during which said re-labeled product was sold, distributed or applied. RESPONSE: See General Objections Nos. 1-8. Subject to its objections. Union Carbide responds as follows: Union Carbide never was in the business of relabeling asbestos-containing products manufactured by other manufacturers. INTERROGATORY NO. 22: Has this Defendant, at any time, applied, contracted to apply, installed or engaged in the business of applying or installing, asbestos-containing products? If so: (a) State the date(s) on which or during which Defendant applied, contracted to apply, installed or engaged in the business of applying or installing asbestos-containing products; (b) Identify any and all sites within the State of Illinois at which Defendant applied, installed or contracted to apply or install asbestos-containing products, and for each such site: DOCSNYl:1012018.l 17