WORKS AND KUBOTA AMERICA Sener PROPOUNDING PARTY : ) Trial Date None Plaintiff CHRIS WEBBER RESPONDING PARTY : Defendant KUBOTA CORPORATION 20|| SET NUMBER 2 ONE 1 Defendant KUBOTA CORPORATION hereby provides Responses to Plaintiff's 28 Standard Interrogatories Propounded to Defendant Kubota Corporation Individually and Plaintif's i 607796.1DEFENDANT KUBOTA CORPORATION'S RESPONSES TO PLAINTIFF'S STANDARD , INTERROGATORIES SET ONE Successor to Kubota Iron and Machinery Works and Kubota America as follows 2 GENERAL OBJECTIONS 3 4 Responding Party Defendant KUBOTA CORPORATION contends that many of these S interrogatories are objectionable as overly broad unduly burdensome not likely to lead to the discovery of admissible evidence vague and ambiguous as applied to KUBOTA 6 CORPORATION and inconsistent with the requirements of the California Code of Civil Procedure 8 Accordingly KUBOTA CORPORATION has answered the discovery KUBOTA understood Further in attempting to answer 9 CORPORATIONis hampered by the Thus passage of time 10 documents witnesses and evidence that may have helped KUBOTA CORPORATION to more 11 completely answer this discovery and defend itselfin this litigation be may no longer 12 in existence or available These responses are made solely for the purpose of County litigationin Los Angeles 13 State of California incorporated To the extent applicable and expressly 14 below the following objections are incorporated in the response to each individual interrogatory 16 a KUBOTA CORPORATION objects generally to these interrogatories to the 17 extent they ask for information that is not within KUBOTA possession custody CORPORATION's 18 or control However KUBOTA CORPORATION has conducted a good faith 19 investigation and reasonable search for information with to respond to these interrogatories 20 These responses are made on behalf of KUBOTA CORPORATION 222 information existing during the time asbestos cement pipe was exported States from 1962 to 1975 only with regard to to the United b KUBOTA CORPORATION objects generally to these interrogatories to the 222 extent they ask for information directed towards products topics and issues beyond the 222 KUBOTA CORPORATION products about which plaintiff makes allegations on the grounds not 26 that such interrogatories are overly broad unduly burdensome and ask for information that is 27 relevant to the subject matter of this litigation and not reasonably calculated to lead to the 28 discovery of admissible evidence 2 SET DEFENDANT KUBOTA CORPORATION'S RESPONSES TO 607796.1 PLAINTIFF'S STANDARD INTERROGATORIES ONE .

RESPONSE: Defendant objects to this request on the grounds that it is overly broad, unduly burdensome, and not reasonably calculated to lead to the discovery of admissible evidence.

In 1998 OSHA declared its intention to follow DOE's lead, but three years later the agency dropped that initiative.

Abex further objects to this interrogatory on the grounds that the information or materials it purports to seek otherwise lack relevance to the issues arising in these cases and are not reasonably calculated to lead to the discovery of admissible evidence.

Do you want to be more specific than that, or allow the lead to put in dates once set?

To the extent it purports to seek information or matenals regarding the working conditions of Abex employees, this interrogatory is further objected to on the grounds that such information or matenals lack relevance to the issues ansing in these cases and are not reasonably calculated to lead to the discovery of admissible evidence Abex objects to this interrogatory on the ground that it assumes the truth of matters not established or matters not in evidence. -277-

Abex further objects to this interrogatory on the grounds that the information or f materials it purports to seek lack relevance to the issues arising in these cases and are not calculated to lead to the discovery of admissible evidence.

To the extent it purports to seek information or matenals regarding the working conditions of Abex employees, this interrogatory is further objected to on the grounds that such information or matenals lack relevance to the issues ansing in these cases and are not reasonably calculated to lead to the discovery of admissible evidence Abex objects to this interrogatory on the ground that it assumes the truth of matters not established or matters not in evidence. -277-

To the extent it purports to seek information or matenals regarding the workmg conditions of Abex employees, this interrogatory is further objected to on the grounds that such information or materials lack relevance to the issues arising m these cases and are not reasonably calculated to lead to the discovery of admissible evidence.

Abex also objects to this interrogatory on the grounds that the information or matenals it purports to seek lack relevance to the issues arising in these cases and are not calculated to lead to the discovery of admissible evidence To the extent it purports to seek information or matenals regarding the working conditions of Abex employees, this interrogatory is further objected to on the grounds that such information or matenals lack relevance to the issues ansmg in these cases and are not reasonably calculated to lead to the discovery of admissible evidence Abex objects to this interrogatory on the ground that it assumes the truth of matters not established or matters not in evidence.

To the extent it purports to seek information or matenals regarding the workmg conditions of Abex employees, this interrogatory is further objected to on the grounds that such information or materials lack relevance to the issues arising m these cases and are not reasonably calculated to lead to the discovery of admissible evidence.

Abex further objects to this interrogatory on the grounds that the information or materials it purports to seek lack relevance to the issues arising in these cases and are not reasonably calculated to lead to the discovery of admissibte evidence.

To the extent it purports to seek information or materials regarding the working conditions of Abex employees, this interrogatory is further objected to on the grounds that such information or materials lack relevance to the issues arising in these cases and are not reasonably calculated to lead to the discovery of admissible evidence.

Abex also objects to this interrogatory on the grounds that the information or matenals it purports to seek lack relevance to the issues arising in these cases and are not calculated to lead to the discovery of admissible evidence To the extent it purports to seek information or matenals regarding the working conditions of Abex employees, this interrogatory is further objected to on the grounds that such information or matenals lack relevance to the issues ansmg in these cases and are not reasonably calculated to lead to the discovery of admissible evidence Abex objects to this interrogatory on the ground that it assumes the truth of matters not established or matters not in evidence.

If it could be obtained from a department of industrial hygiene in Canada's leading university in return for a moderate annual for the Company would undoubtedly benefit.. ...Such a plan involves a definite quid pro quo, payments specifically conditioned upon a commensurate return, the adequacy ofsuch return to be determined by the President or those to whom he may delegate the decision__ ...The Sun Life might well ask - if it secured a mortgage on McGill.. .Technical guidance in regard to matters affecting community or individual health - such as, aid in preparation of publicity, occasional research matters not involving great outlays ofmoney, field investigations as of sanitation, water, or milk supplies, or industrial hazards. ...Observations ofour scheme at Harvard leads me to add that Martin should not only be prepared to render certain types of service but certain services, more or less routine perhaps, should be specified.