Document rpO9znr4pGZ7mLX19YdxR7D0r

contained small quantities of asbestos. The asbestos fiber in those products was encapsulated by binder ingredients in the production process. The company sold a subsidiary which produced these products and ceased producing all asbestos containing products (except for TRE-HOLD, a tree sprout inhibitor) prior to Union Carbide's acquisition of the company. In addition, there were some welding and gas distributors that were acquired by Union Carbide which may also have sold asbestos products. See also Union Carbide's Response to Interrogatory No. 3. INTERROGATORY NO. 7: With respect to each corporation, company, business or joint venture identified in response to Interrogatory No. 6 state: (a) The type of business, conducted by such related company; (b) The past and present business relationship(s) between said related company and Defendant; (c) The nature of the products or services which Defendant has sold to, or purchased from, said related company; (d) Whether or not said related company advertises or has advertised products or services supplied by Defendant; (e) Whether or not said related company sells or has sold Defendant's products or services within the State of Illinois and, if so, the approximate value of those sales from 1930 to date; (f) Whether or not said related company pays taxes of any type to the State of Illinois or to any political subdivision thereof and, if so, the type of taxes paid; (g) Whether or not Defendant controls or has controlled, directly or indirectly, in whole or in part, said related company's advertising; and, (h) The identity of any past or present officer or director of Defendant who, at any time, served as an officer or director of said related company. RESPONSE: See Union Carbide's Responses to Interrogatory No. 6, including all objections set forth therein. INTERROGATORY NO. 8: List all directors and officers of Defendant from 1940 to date and for each state all positions held and the date(s) during which each position was held. DOCSNYH012018.I 7