IN RE: ALL ASBESTOS-RELATED PERSONAL INJURY OR DEATH CASES FILED OR TO BE FILED IN DALLAS COUNTY, TEXAS IN THE DISTRICT COURT DALLAS COUNTY, TEXAS 191ST JUDICIAL DISTRICT DEFENDANT'S ANSWERS AND OBJECTIONS TO PLAINTIFFS' INTERROGATORIES AND REQUESTS FOR PRODUCTION TO: Mr.

from WM GW S4*0 Raaaaxch labs 5092 June 26, 197* Biology Research WSSTIHGaOUSE BPUDIBG K.

NO. 92-10123 CHARLES NORMAN WHITE and PAULINE WHITE; HARVEY LEWIS SHADDOX and MARY SHADDOX; ORVEL WOODROW FITTS and MAVIS FITTS; LEO L.

EPA -450/3-90-017 National Emission Stand ards for Asbestos -------- Background Informati on for Promulgated Asbes tos NESHAP Revisions Emissions Standards Div ision U.S.

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FILE NAME: Calaveras (CALV) DATE: 1998 DOC#: CALVO 18 DOCUMENT DESCRIPTION: Legal - Further Answers of Defendant to Standard Interrogatories DOUGLAS GARTH WAH, SBN 64692 ADAMS NYE SINUNU * WALKER One Jackson Place 633 Battery Street, 5th Floor San Francisco, California 94111 Telephone: (415)982-8955 ____ PARA ____ ATTV CLASS RECEIVED OTHER RLE J l l 2 7 1998 BRA YTO N H ARLEY C U R TIS HAND OVilkCHT__ MAIL Attorneys for Defendant CALAVERAS ASBESTOS, LTD. 6 7 8 SUPERIOR COURT OF CALIFORNIA 9 IN AND FOR THE COUNTY OF SAN FRANCISCO 10 11 In re: Complex Asbestos Litigation 12 13 14 15 16 ) No. 828684 ) ) FURTHER ANSWERS OF ) DEFENDANT CALAVERAS ) ASBESTOS.

FILE NAME: Welding (WELD) DATE: 1995 DOC#: WELD031 DOCUMENT DESCRIPTION: Excerpt of Consultant Report - Evaluation of Asbestos-Containing Welding Rods for Asbestos Release D e po sit io n :> ex h ib it , EVALUATION O F ASBESTOS-CONTAINING WELDING RODS > FO R ASBESTOS FIBER RELEASE ) John H.

FILE NAME: WR Grace (WRG) DATE: November 2, 1995 DOC#: WRG009 DOCUMENT DESCRIPTION: 1995 Letter to Dr Egilman from BA Davis regarding response to FOIA request regarding Ambrose-Grace 1J1^03/1X9i/9U5i./008:01i : 1181735^8y4i 883072 656 5875 SSHC JACOBS CRU.UPLAR PAGE 05 002 ROBERT JACOBS THOMAS C.

American Journal of lndustrial Medicine 17:617-635 (1990) Dermal Absorption Potential of Industrial Chemicals: Criteria for Skin Notation V.

Occupational and Environmental Medicine 1994;51:523-529 523 Occupational exposure to solvent mixtures: effects on health and metabolism Hirohiko Ukai, Shiro Takada, Shunen Inui, Yoshiko Imai, Toshio Kawai, Shin-ichiro Shimbo, Masayuki Ikeda Department of Public Health, Kyoto University Faculty of Medicine, Kyoto 606-01, Japan H Ukai Y Imai M Ikeda Kyoto Industrial Health Association, Kyoto 604, Japan H Ukai S Takada S Inui Osaka Occupational Health Service Centre, Osaka 550, Japan T Kawai Department of Food and Nutrition, Kyoto Women's University, 605, Japan S Shimbo Correspondence to: Professor M Ikeda, Department of Public Health, Kyoto University Faculty of Medicine, Kyoto 606-01, Japan.

^ohmond^olimon CONSUMER SKILLMAN, NJ 06S58-94J8 January 20, 1994 SUBJECT: J&J.

FILE NAME: Asbestos in Schools & Other Buildings (AIS) DATE: 1991 DOC#: AIS001 DOCUMENT DESCRIPTION: Asbestos-Related Abnormalities in School Maintenance Personnel - Annals NY Academy of Science P A R T 16.

FILE NAME Allied Signal Bendix ASB DATE 1991 June 24 DOC ASB096 DOCUMENT DESCRIPTION Letter from Rayloc to Bendix RE Asbestos Dust Concerns NAPA RayLOC RayLOC DIVISION OF GENUINE PARTS COMPANY 600 RAYLOC DRIVE S.W.

FILE NAME Allied Signal Bendix ASB DATE 1997 DOC ASB001 DOCUMENT DESCRIPTION Legal - Excerpts - Plaintiff's Responses to Interrogatories litigation claims exposure and for that reason the formulation of a full and accurate answer is not possible Further this Interrogatory is vague ambiguous overly broad unduly burdensome oppressive irrelevant time consuming and oppressive and not reasonably calculated to lead to the discovery of admissible evidence Subject to and without waiving said objections although AlliedSignal does not believe there is any health hazard associated with the proper use of its friction products since October of 1973 in recognition of OSHA regulations concerning asbestos exposure a warning label has been placed on all cartons and boxes of containing friction products shipped to customers AlliedSignal and its predecessors have complied with OSHA warning regulations even though it has never been determined that exposure to friction products results in an exposure to asbestos fibers equal to or in excess of OSHA exposure limits for asbestos fibers From October 1973 until August 1986 the warning label read as follows CAUTION CONTAINS ASBESTOS FIBERS AVOID CREATING DUST BREATHING ASBESTOS MAY CAUSE SERIOUS BODILY HARM From September 1986 until the present the warning label reads as follows DANGER CONTAINS ASBESTOS FIBERS AVOID CREATING DUST CANCER AND LUNG DISEASE HAZARD - 11 Identify by date issued patent number patent application number and product name every patent for asbestos free products held by issued to or applied for by you or by any of your employees DEFENDANT ALLIEDSIGNAL INC.'

267 The Classification o; Cheat Radiographs lor Coal Workers' Pneumoconiosis.