g) The date when first implemented.

C 05IOI02C 1 REQUEST FOR ADMISSION L: You were aware as early as 1979 2 that one or more individuals had filed workmen's compensation 3 claims alleging injury or disease as a result of exposure to 4 asbestos while employed at one or more of your facilities. 5 RESPONSE: Admitted. 6 7 a 9 REQUEST FOR ADMISSION M: You were aware as early as 1980 10 that one or more individuals had filed workmen's compensation 11 claims alleging injury or disease as a result of exposure to 12 asbestos while employed at one or more of your facilities. 13 RESPONSE: S&s j-ggponse to Request for Admission L. 14 15 16 17 REQUEST FOR PRODUCTION Q: Pursuant to CR 34, attach or 18 produce according to the above instructions annual summaries of 19 compensation claims analyzed by nature of claims, lost time, 20 disposition and -the like. 21 22 RESPONSE: irrelevant objection. 23 24 25 26 PLAINTIFF'S FIRST INTERROGS, ETC. - 69 I I i t . * ; ; t i I i j !

1 2 cardboard boxes according to size.

is burdensome, overly broad as to time and scope and not reasonably calculated to lead to the discovery of admissible evidence.

Estimated Asbestos Related Cancer Mortality per IQOiQOQ by Number of Years Exposed and Exposure Level 1 Asbestos fiber CONCENTRATION (F/ML) 0.1 0.2 0.5 2,0 1:8 10.0 Cancer mortality/100,000 exposed Lung Mesothe lioma Gastro intestinal 7,2 \ 4.4 6m.1 715 1 YEAR EXPOSURE 20 YEARS EXPOSURE 69,2 271.3 527.8 650.9 1217,7 45 YEARS EXPOSURE m 114.3 441.6 844.1 1031,8 1851.5 Total 14.8 29,b 74,3 296,4 591.8 740,0 1470.5 225,9 451.8 1123.2 4392.3 8511.8 10476,9 13996,7 336,1 670,0 1664,3 6411.6 12209,1 14896,8 26507.5 1 Assumes exposure begins at age 25, Risks are calculated using U.S. male LUNG CANCER BACKGROUND RATES FOR 1977, 2 Estimated as 10% of lung cancer risk than calculated using dose-response INFORMATION, 10'd in`0131 JHiflOS XI0N3H SZ'Zl 98, S3HQT HWBUI0000395

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