Subject to these objections, Dow asserts it is unable to pinpoint a precise date on which it, as a corporate entity, affirmatively knew of an association between asbestos exposure and disease as medical and scientific literature regarding asbestos related disease developed gradually over time.

Dow objects to paragraph twelve (12) of the DEFINITIONS section to the extent the information sought concerns asbestos in a non-friable form.

Dow objects to paragraph twelve (12) of the DEFINITIONS section to the extent the information sought concerns asbestos in a non-friable form.