Since 1980 Champlain has had no interest in the Haveg Plant or in any business relating to asbestos or asbestos products.

Grace therefore, reserves the right to amend these answers as and if new or better information becomes available to it or if errors are discovered. -2- Unless otherwise stated in an answer to a specific interrogatory, the answers are limited to thermal insulation products containing commercial asoestos, _.-.d to thermal insulation products that do not contain commercial asbestos but contain vermiculite, which were or are used in the construction industry and Grace's activities associated with the manufacture and sale of same in the United States.

Grace further objects to these interrogatories insofar as they seek production of any information constituting a trade secret, confidential financial data or other confidential research, development or commercial information.

Has THIS DEFENDANT engaged in the KARTOTlng of ASBESTOS- 21 CONTAINING PRODUCTS comprised in whole or in part of chrysotile 22, asbestos fiber?

Amerioan Junketing Association Sales Dept.