Document pemqGdbBe4RK3G9ZD9602ynYj

ANSWER TO INTERROGATORY NO. 35 : Abex has found no documentation in its files evidencing a corporate membership in the Industrial Hygiene Foundation. 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 m'anagers or contract unit occasional workers independently contracted for. If there have been any workman's compensation claims within the above-described criteria between the years 1930 and 1978, state: (a) The date you received notice of the claim; (b) The identity of the person making the claim; or on whose behalf the claim was made; (c) The specific disease or illness complained of In particular, all complaints of: asbestos, emphysema, chronic bronchitis, pulmonary fibrosis, dyspnea, carcinoma of the lungs and mesothelioma; (d) The name of any physician or nurse who made any notes on the claim or who inscribed any words whatsoever on any document, paper, letter, book, or record pertaining to the evaluation of the facts and/or the merits and/or the medical workup of the claim filed; (e) A brief summary of the substance of the written materials mentioned in section (d); 12/21/90 DISK: ABEX/edpa-33/abex interrogs/marcinowski -32-