O'CONNELL A ASSOCIATES 12 (c/o ROBINSON A WOOLSON Attn: Ms.

The above signing officer has been informed that those files, documents and -1- PLAINTIFFS EXHIBIT nxioi.oo WV-21186 interviews support responses herein based u^^i a diligent search of available information conducted as of the date of signature.

In other words, did Maremont provide 2 you with compensation for your time in association 3 with those depositions?

Enclosures 21882\0RANGE\ltr3 .rla.doc cc: Brent Coon & Associates (w/enc.)

Abex never mined or commercially sold raw asbestos or asbestos products.

Met Life prepared its own report of the Canadian studies which included dust study 7 information as well entitled Effects of the Inhalation of Asbestos Dust Upon the Lungs of Asbestos 8 Workers Canadian Study Exhibit 11.

Graybar objects to these interrogatories to the extent that they seek confidential or 9 trade secret information or materials. . 10 6.

Published by Oxford University Press on behalf of the Business History Conference All rights reserved For permissions please mail journals.permis ions@oxfordjournals.org journals.permissions@oxfordjournals.org khm023 Advance Access publication May 29 2007 GEOFFREY TWEEDALE is reader in business history at Manchester Metropolitan University Contact information Manchester Metropolitan University Business School Aytoun Street Manchester M1 3GH U.K. mail G.Twedale@mu.ac.uk G.Tweedale@mmu.ac.uk LAURIE FLYNN is a freelance writer and documentary film producer Contact information mail laurievincentflynn@mac.com This article draws on a large mass of business and legal papers that was generated by the Yandle and Adams litigation The papers have been deposited at Manchester Metropolitan University Business School and document citations in the text are from this source We are grateful to Nick Wikeley for advice in the writing of this article David Bricknell David Jeremy Clive Bishop Barry Castleman Steve Tombs and Jock McCulloch kindly offered comments and help at various times Two anonymous referees and editors Steven Tolliday and Kenneth Lipartito provided some final sharpening The responsibility for the text is our own 268 Piercing the Corporate Veil Corporations are typically organized according to the laws of limited liability and increasingly operate across national boundaries by means of subsidiaries A massive business literature has described this process and extolled the enormous material benefits that have ensued Business historians have made important contributions to this field indeed the writings of Alfred D.

But the aspirin industry, with the assistance of the W hite House's Of fice o f Management and Budget, was able to delay a major government public educational program for two years, and mandatoiy labels for four years.6 Although the four studies were enough for the CDC to issue warnings, the industry raised 17 specific "flaws" in the studies7and insisted that more reliable studies were needed to establish a causal association betw een aspirin and Reye's syndrome.

Calidria is not an "asbestos-'containing product".

RESPONSE: Hercules objects to this interrogatory as vague and confusing because it is unclear whether this interrogatory seeks information concerning the raw asbestos fibers which Hercules purchased from J-M Canada and Carey Canada or whether it seeks information concerning products sold by Hercules.

Graybar did not manufacture "asbestos products" and did not sell or distribute "asbestos."

\t' -f.*1 ' * - . mm v .Jfr CRMC-SBGAB-000001 ASBESTOS INFORMATION ASSOCIATION NORTH AMERICA 1660 LSireet.

RESPONSE: Hercules objects to this interrogatory as vague and confusing because it is unclear whether this interrogatory seeks information concerning the raw asbestos fibers which Hercules purchased from J-M Canada and Carey Canada or whether it seeks information concerning products sold by Hercules.

Published by Oxford University Press on behalf of the Business History Conference All rights reserved For permissions please mail journals.permissions@oxfordjournals.org khm023 Advance Access publication May 29 2007 GEOFFREY TWEEDALE is reader in business history at Manchester Metropolitan University Contact information Manchester Metropolitan University Business School Aytoun Street Manchester M13GH M13GH U.K. mail G.Tweedale@mmu.ac.uk LAURIE FLYNN is a freelance writer and documentary film producer Contact information mail laurievincentflynn@mac.com This article draws on a large mass of business and legal papers that was generated by the Yandle and Adams litigation The papers have been deposited at Manchester Metropolitan University Business School and document citations in the text are from this source We are grateful to Nick Wikeley for advice in the writing of this article David Bricknell David Jeremy Clive Bishop Barry Castleman Steve Tombs and Jock McCulloch kindly offered comments and help at various times Two anonymous referees and editors Steven Tolliday and Kenneth Lipartito provided some final sharpening The responsibility for the text is our own 268 Piercing the Corporate Veil Corporations are typically organized according to the laws of limited liability and increasingly operate across national boundaries by means of subsidiaries A massive business literature has described this process and extolled the enormous material benefits that have ensued Business historians have made important contributions to this field indeed the writings of Alfred D.