Several major participants in the rulemaking proceeding including the AFL-CIO, the Building and Construction Trades Department (BCTD) of the AFL-CIO, and the Asbestos Information Association (AIA), challenged various provisions of the revised standards.

Due to his long association with Kentile, Mr.

Due to his long association with Kentile, Mr.

Because of 19 these 'limitations on Flintkote's information, the responses that 20 follow are based only on the information and belief of the person 21 verifying these responses.

Gypsum to engage in unduly burdensome research, divulge privileged information and produce privileged documents.

Please review same and advise me whether there is additional information which you seek.

Product information 3.

SUPPLEMENTARY INFORMATION: I.

Defendant KELLY-MOORE also objects to these 24 Interrogatories to the extent they call for information protected 25 by the attorney-client privilege, or the attorney work-product 26 doctrine, or any other applicable privilege. 27 6.

Ford states that it has not manufactured asbestos-containing brake linings, pads or clutch facings.

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

Defendant KELLY-MOORE also objects to these ; 24 Interrogatories to the extent they call for information protected 25 by the attorney-client privilege, or the attorney work-product , 26 doctrine, or any other applicableprivilege. 1 27 6.

To the best of my present knowledge, information and belief, I certify that these records were made at or near the time by, or from information transmitted by, a person with knowledge, were kept in the course ofthe regularly conducted business activity ofManville, and it was the regular practice and the business activity ofManville to make the records.

Despite the fact analysis.4 Finally, the industry subsidized an incom that these brakes are 40-70% asbestos, the brake man plete analysis of historical exposures to asbestos in ufacturers have vigorously denied that they contributed brake work.3 in any way to a single case of asbestos-caused disease.1 These companies have spent millions of dollars to The brake manufacturers have dismissed the fact that generate these epidemiologic studies in order to there is no known threshold of exposure associated refute claims of causation and thereby avoid com with mesothelioma (a rare cancer of the pleura or peri pensation payments to victims and their families.

State the names of all industry or trade association periodicals to which you subscribed or which you received without subscription at any time from 1900 to the present giving the period of subscription or receipt of each ANSWER : Reddawaiys unable to identify any industry or trade association periodicals for the period in question 20 Identify by name and date all medical texts treatises journals studies c reports whether privately or publicly circulated which you received or obtained at any time from 1900 to the present and which concerned in any