In the course of responding to discovery over several years, various persons have provided information and referred to documents which persons and documents this defendant is presently unable to identify individually or in relation to specific items of information.

The contents of the information provided.

Such a 11 tourse1 wcu 1 d ir.vo 1 ve n.c t on 1 y the presentation of all of the information in detail but mo st 1ihe1y site visits a s we11.

Congoleum was a member of the Asbestos Information Association/North America from 1972 through 1984.

George Wright reporting from all key government and scientific committees formation of AIA Sabourin flying around trying to get scientists to sign a statement that present asbestos levels are no problem Congressman R.

This interrogatory is overbroad and irrelevant in part insofar as it seeks information not specific to manufacture and/or sale of asbestos- containing products.

Much of the--' information requested date back many years and thus, it is difficult if not impossible to reconstruct or retrieve this information.

Without waiving this objection, see this Defendant's response to Interrogatory No. 4 where information specific to manufacture and/or sale of asbestos-containing products is provided. 4.

Asbestos is a known human carcinogen that nausea tong lom-uca*; fw. 4T-tj Comments on this proposed rule and cancer, mesothelioma (a cancer of the requests to participate the Informal chest and ubdorairwl lining) find is also Asbestos; Proposed Mining and Import hearings must be submitted by April 29, lloked to other cancers.

This is not meant to suggest that excessive exposures to vinyl chloride, asbestos, arsenic, and other compounds have not caused cancer?

This information follows in complete de tail.

(b) Liaison with member companies to keep them informed of such published reports.

Pittsburgh Metals objects to any interrogatory which seeks information about any products it may have manufactured or sold because the plaintiffs have not produced any evidence of exposure to any Pittsburgh Metals asbestos-containing products. 5.

INTERROGATORY NO. 3: Please list all trade organizations, trade associations and any other industry-wide groups to which you belong(ed) (specifically including but not limited to the following groups: American Hygiene Foundation, Industrial Hygiene Foundation, Chemical Manufacturer's Association, American Chemical Council, American Petroleum Institute, Texas Chemical Council, Ohio Safety Congress, National Safety Council, Asbestos Information Association, Industrial Medical Association) in which information or documents relating to asbestos was discussed, disseminated, or published (including, but not limited to, the effects of exposure to asbestos, industrial hygiene measures relating to asbestos dust, and medical information or research relating to asbestos or its effects on animals or humans, populations at risk).

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