Document k9N81RNEGE2L9GLD3YOM1Qo40

employed by defendant and/or any predecessor/related entity at any time from 1940 to date in a management or upper-level supervisory (including upper-level assistants and associates) position having responsibility in each of the areas listed below: (a) Occupational health and/or safety; (b) Compliance with federal, state and/or local safety regulations (including, but limited to OSHA) / (c) Compliance with federal, environmental regulations; state and/or local (d) Compliance with federal, state and/or local health regulations (including, but limited to OSHA) / (e) Industrial hygiene; (f) Insurance or risk management; (g) Workers compensation; (h) Medical director; (i) Asbestos abatement; (j) The manufacture, sale, distribution, possession, application, installation or use of asbestoscontaining materials/products; and, (k) The design and/or preparation of manufacturing specifications asbestos-containing materials and/or products. ANSWER: a) James Turner b) James Turner c) James Turner and Herb Allen d) Jim Turner e) Jim Turner f) Rachel Collins g) Mary Ann Rail h) Mary Ann Rail i) James Turner j) Gleason objects to.this Interrogatory as overly broad, burdensome, harassing, excessive in scope and time and incorrectly implying that its products were a health hazard. k) Gleason objects to this Interrogatory as overly GLEASON-000027