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Vista Chemical Company 900 Threadneedie Houston, Texas 77079 ;713) 588-3000 P.O.

INTERVIEW WITH THOMAS COMMES PRESIDENT AND CHIEF OPERATING OFFICER SHERWIN-WILLIAMS CLEVELAND, OHIO JANUARY 25, 1991 INTERVIEW CONDUCTED BY KATHLEEN MCDERMOTT AND DAVIS DYER THE WINTHROP GROUP, INC. & PATRICIA ELDRIDGE S W CO.

S FIRST UPDATED RESPONSES TO PLAINTIFFS STANDARD INTERROGATORIES TO DEFENDANTS 16 17 PROPOUNDING PARTY Plaintiffs 18 RESPONDING PARTY = Defendant KAISER GYPSUM COMPANY INC 19 SET 20 DATE Standard July 30 1999 21 COMES NOW defendant KAISER GYPSUM COMPANY INC hereinafter 22 KAISER GYPSUM and provides the following First Updated Responses to Plaintiffs 23 Standard Interrogatories To All Defendants propounded pursuant to San Francisco 24 County Complex Asbestos Litigation General Order No. 129 25 Hf 26 HI 27 // 28 Hf 1 Kaiser Gv^sum'sFirst Undated Responses to Plaintiffs Standard Interrogatories to Defendants KAISER GYPSUM'S PRELIMINARY STATEMENT KAISER GYPSUM submits this preliminary statement to memorialize certain steps taken to implement the standard discovery regime adopted pursuant to the revised General Orders filed November 15 1996 governing asbestos personal injury and wrongful death cases filed in San Francisco Superior Court Under the terms of General Order No. 129 all defendants must respond to the Plaintiffs Standard Interrogatories To All Defendants without objection even where those interrogatories appear objectionable under the rules defined by California statutes and appellate precedent The General Orders do contemplate that plaintiffs counsel must meet and confer with defendants and 10 consider a specific defendant's concerns with the standard interrogatories as applied to 11 that defendant's factual and litigation circumstances In KAISER GYPSUM's case that 12 process proved sufficiently successful that KAISER GYPSUM did not believe it 13 necessary to file a motion seeking judicial relief from the burdensomeness that would 14 arise in KAISER GYPSUM's circumstances from responding to the literal terms of the 15 discovery 16 The meet and confer process was structured pursuant to an April 24 1997 letter 17 circulated by plaintiffs counsel In accordance with that procedure KAISER GYPSUM 18 - held a meet and confer session with certain plaintiffs counsel on May 15 1997 as 19 contemplated by their April 24 1997 letter During that session agreements were 20 reached on interpretations of numerous specific provisions of the subject standard 21 interrogatories which have since been concurred in by plaintiffs counsel that did not 22 attend the May 15 1997 meeting KAISER GYPSUM's pursuit of its 23 burdensomeness objections remains contingent on continued realization of the 24 agreements reached at the May 15. 1997 meeting 25 KAISER GYPSUM also stated other objections to the subject Plaintiffs Standard 26 Interrogatories during the course of the proceedings leading to their adoption Those 27 objections concerned both the concept of using standard interrogatories for discovery 28 unrelated to the resolution of cases or controversies before the Court objections to the 2 Vaicor Vaicor Cuncum's Cuncum's First Undated Undated Dosnonces Dosnonces to Dlaintiffs Dlaintiffs Dlaintiffs Standard Standard Interrogatories Interrogatories to Defendante Defendante procedures underlying the development and adoption of the standard interrogatories and objections to specific aspects of the standard interrogatories on grounds other than burdensomeness all of which objections were either accepted or implicitly rejected through adoption of the final standard interrogatories KAISER GYPSUM hereby makes express on the record that by serving its Responses to Plaintiffs Standard Interrogatories To All Defendants KAISER GYPSUM neither intends to nor does it waive its rights to press those objections at an appropriate future opportunity both in the context of specific cases before the Superior Court and on appellate review KAISER GYPSUM objects to Plaintiffs Standard Interrogatories To All 10 Defendants to the extent that they call for information protected by the attorney 11 privilege or product doctrine 12 This Preliminary Statement and the objections contained herein are incorporated 13 into each of the responses set below 14 KAISER GYPSUM'S RESPONSES TO INTERROGATORIES 15 ~ KAISER GYPSUM has not manufactured or marketed any products which 16 contained asbestos as a component since 1976.

PLAINTIFF'S ( EXHIBIT BIR-6 REPORT of ASBESTOS TESTING OF BIRD INC.

AR226-2996 .

Defendant does not understand this discovery as amended and conformed to embrace products which may contain asbestos but are not friable in any manner, which have been used because of the unavailability of alternate suitable materials; and which were approved by OSHA for use after 1972, such as gaskets, woven thermocouple lead wires, graphite or teflon impregnated woven asbestos packing and. textile safety materials such as gloves and blankets.

Vista Chemical Company 900 Thracdneed'e Houston, Texas 77079 (713) 588-3000 pq ?

HNM-UIN TOOCOLOOY (tolsihm R & s 028201 Dhie. 19t{taA IM*|.

ABDOO103272 Guidance Manual for EPA Chemical Safety Audit Team Members Chemical Emergency Preparedness and Prevention Office Office of Solid Waste and Emergency Response U.S.

Reference Request Sheet i__________ ... v r g . r V . ; . . * _____:_____1 A R C IS jArchives and Records Centers Information System Reference Request#: ARR1-2784959568 ARR1-2784959568 Request Category : General Reference Transfer #: PT-181 -2017-0265 Container #: 1: Asset #: AAC1-2407911403 \ Asset Location : RVR-01 -04-101 -2-018-04-005 Case/File Information : 5090, 1997, TM-2246-ENV Whole Container: N Public Request : N Creation Date : 07/26/2017 Charge Code : 00 Requested By : KRISTY NEWSOME Department of the Navy Assigned To : Batch #: 208SS1 SREQ Ship T o : KRISTY NEWSOME 1000 23RD AVE BLDG 1000 CODE BD42 PORT HUENEME CA 93043-4301 Shipping Method : Shipping Acc #: Nature of Service : Service Level : Source : Email : SmartScan N/A SmartScan Standard .

ELEY may be 6 taken before Deborah Salers Garrett, CSR, RPR, 7 as Commissioner and Notary Public, Alabama at 8 Large, at Birmingham, Alabama, on January 6, 9 1999, at 1:00 p.m. 10 1 1 IT IS STIPULATED AND AGREED that it 1 2 shall not be necessary for any objections to 1 3 be made by counsel to any questions except as 1 4 to form or leading questions and that counsel 1 5 may make objections and assign grounds at the 1 6 time of trial or at the time said deposition 1 7 is offered in evidence or prior thereto. 18 1 9 IT IS STIPULATED AND AGREED that notice 2 0 of filing by the Commissioner is waived. 21 22 23 REGIONAL REPORTING SERVICE, INC.

PLAINTIFF'S EXHIBIT ASA-1382 SET October 22,1996 X)roS.s n&xi'vzx *t}iwssm& U<S \x-y->..vA--v.: i-w.' t'w;i:: Abatement Plan for the Removal of Asbestos at ASARCO,Inc.

S FIRST UPDATED RESPONSES TO PLAINTIFFS STANDARD INTERROGATORIES TO DEFENDANTS 16 17 PROPOUNDING PARTY Plaintiffs 18 RESPONDING PARTY = Defendant KAISER GYPSUM COMPANY INC 19 SET 20 DATE Standard July 30 1999 21 COMES NOW defendant KAISER GYPSUM COMPANY INC hereinafter 22 KAISER GYPSUM and provides the following First Updated Responses to Plaintiffs 23 Standard Interrogatories To All Defendants propounded pursuant to San Francisco 24 County Complex Asbestos Litigation General Order No. 129 25 Hf 26 HI 27 // 28 Hf 1 Kaiser Gv^sum'sFirst Undated Responses to Plaintiffs Standard Interrogatories to Defendants KAISER GYPSUM'S PRELIMINARY STATEMENT KAISER GYPSUM submits this preliminary statement to memorialize certain steps taken to implement the standard discovery regime adopted pursuant to the revised General Orders filed November 15 1996 governing asbestos personal injury and wrongful death cases filed in San Francisco Superior Court Under the terms of General Order No. 129 all defendants must respond to the Plaintiffs Standard Interrogatories To All Defendants without objection even where those interrogatories appear objectionable under the rules defined by California statutes and appellate precedent The General Orders do contemplate that plaintiffs counsel must meet and confer with defendants and 10 consider a specific defendant's concerns with the standard interrogatories as applied to 11 that defendant's factual and litigation circumstances In KAISER GYPSUM's case that 12 process proved sufficiently successful that KAISER GYPSUM did not believe it 13 necessary to file a motion seeking judicial relief from the burdensomeness that would 14 arise in KAISER GYPSUM's circumstances from responding to the literal terms of the 15 discovery 16 The meet and confer process was structured pursuant to an April 24 1997 letter 17 circulated by plaintiffs counsel In accordance with that procedure KAISER GYPSUM 18 - held a meet and confer session with certain plaintiffs counsel on May 15 1997 as 19 contemplated by their April 24 1997 letter During that session agreements were 20 reached on interpretations of numerous specific provisions of the subject standard 21 interrogatories which have since been concurred in by plaintiffs counsel that did not 22 attend the May 15 1997 meeting KAISER GYPSUM's pursuit of its 23 burdensomeness objections remains contingent on continued realization of the 24 agreements reached at the May 15. 1997 meeting 25 KAISER GYPSUM also stated other objections to the subject Plaintiffs Standard 26 Interrogatories during the course of the proceedings leading to their adoption Those 27 objections concerned both the concept of using standard interrogatories for discovery 28 unrelated to the resolution of cases or controversies before the Court objections to the 2 Vaicor Vaicor Cuncum's Cuncum's First Undated Undated Dosnonces Dosnonces to Dlaintiffs Dlaintiffs Dlaintiffs Standard Standard Interrogatories Interrogatories to Defendante Defendante procedures underlying the development and adoption of the standard interrogatories and objections to specific aspects of the standard interrogatories on grounds other than burdensomeness all of which objections were either accepted or implicitly rejected through adoption of the final standard interrogatories KAISER GYPSUM hereby makes express on the record that by serving its Responses to Plaintiffs Standard Interrogatories To All Defendants KAISER GYPSUM neither intends to nor does it waive its rights to press those objections at an appropriate future opportunity both in the context of specific cases before the Superior Court and on appellate review KAISER GYPSUM objects to Plaintiffs Standard Interrogatories To All 10 Defendants to the extent that they call for information protected by the attorney 11 privilege or product doctrine 12 This Preliminary Statement and the objections contained herein are incorporated 13 into each of the responses set below 14 KAISER GYPSUM'S RESPONSES TO INTERROGATORIES 15 ~ KAISER GYPSUM has not manufactured or marketed any products which 16 contained asbestos as a component since 1976.

The same issues were iterated by a Based on an investigation of immunoglobulin gene or- i group of scientists convened by the International ganization and expression in hemopoietic stem cell leu- Agency for Research on Cancer (McMichael, 19883. kemia, Ford et al. (1983)have demonstrated that a clor,ai One of the major issues raised by both Wong (1983) event leading to blast crisis can occur in a committed H and McMichael (1988) is the relationship, if any. cell precursor rather than in the pluripotential stem .