Document jm35Lpdp29mrwRpEE7v0BD5OQ

Abex has not found any information in its files evidencing a corporate membership in IHF. 35. Have you, at any time, been a member of and/or contributed to the Industrial Hygiene Foundation: If so, state: (a) The dates you were a member and/or contributed; (b) The identification of any publication of any such organization; (c) What meetings you attended and who attended; (d) Who spoke at such meetings; (e) Where transcripts or summaries or minutes or notes made of such meetings? If so, identify the above, tell specifically what was made and give the name, title and address of the person or persons who have custody of the transcripts and/or summaries and or minutes and/or notes mentioned above and state when and where counsel for the plaintiff may examine and copy these documents. ANSWER TO INTERROGATORY NO. 3S: See answer to interrogatory No. 34. 36. State whether you have received any workmen's compensation claim for injury, occupational disease, or death, to any of your employees or to any persons working as independent contractor for you, or under your direction or to any persons in "contract units" operated by you or your subsidiaries or divisions or to any persons hired on an occasional basis by your agents, employees or directors, in the course of work activity performed by the aforementioned "contract unit" for the following diseases: asbestosis, emphysema, chronic bronchitis, pulmonary fibrosis dyspnea, carcinoma of the lungs, or mesothelioma. In answering this question confine your answer to workers who were occupationally exposed to asbestos products by their using, handling, fabricating, installing, removing, mixing, cutting, packing or transporting products containing any percentage whatsoever of asbestos whether raw or finished and whether made by you or made by some other company but used, handled, modified, installed, removed, mixed, cut packed or transported by the person or persons making the workmen's compensation claim for injury or unit managers or contract unit occasional workers independently contracted for. If there have been any workman's -26-