Asbestos Information Association/North America (1972- 24 1984); Resilient Floor Covering Institute (December, 25 1975, through September, 1980, and February, , 1987 26 through the present). / / 27 B.

Uniroyal objects to any interrogatory which seeks information about any asbestos containing products it may have manufactured or sold because the plaintiffs have not produced any evidence of exposure to any Uniroyal or United States Rubber Company asbestos containing products.

Plaintiffs' use of the term "asbestos-containing product" incorporates an assumed release of asbestos dust and asbestos fibers in the use of a product.

Have you ever studied asbestos?

If information is later obtained which modifies any ofthe responses heron, such information will be conveyed to the parties submitting these interrogatories.

The information contained in the answers has been assembled by authorized employees and counsel for National Gypsum.

Users bear all risks associated with reliance on these work practices and shall have the sole responsibility to evaluate the information contained herein, to form their own independent judgments on the use of the Guidance Manual, and to modify or adapt it as may be appropriate to specific circumstances.

If so, identify the document containing such information by date and location.

The questions as stated request information going back many years.

-To the best of my knowledge, and I am quite certain of this, they did not do fiber counting analysis on any samples collected to measure personal exposures to asbestos.

In the spirit of discovery, however, Chrysler provides information herein.

Markusson, associate general counsel; and John D.

Users bear all risks associated with reliance on these work practices and shall have the sole responsibility to evaluate the information contained herein, to form their own independent judgments on the use of the Guidance Manual, and to modify or adapt it as may be appropriate to specific circumstances.

: \ 4 A I am associate professor again in the : 5 Division of Occupational Medicine in the Duke j 6 University Medical Center

Director of Information nri Consumer Affairs.