Accordingly, Ford does not, and could not possibly, represent that its responses constitute all o f the information requested.

List any and all such sources of information relied upon.

To the extent that additional information responsive to this Interrogatory is in the possession ofUnion Carbide, this information is located in the repositories maintained by Union Carbide's counsel.

As worded, this document request could reach information BSRA515205 -4- which is confidential and/or proprietary business information.

The failure to limit this discovery to information related to Buffalo Pumps, Inc.'

Myers (11-29-01) we -- in dealing with the hazards of asbestos and providing them -- them with information regarding the attributes of our product and the potential hazards of asbestos for customers.

Myers (11-29-01) we -- in dealing with the hazards of asbestos and providing them -- them with information regarding the attributes of our product and the potential hazards of asbestos for customers.

Name Defendants ) 7/16/04 7/16/04 7/16/047/16/04 7/16/04 Rose File PACCAR INC'S ANSWERS TO PLAINTIFFS INTERROGATORIES TO Plaintiffs by and through their attorneys of record The Simmons Firm LLC PACCAR INC one of the Defendants in the referenced cause of action provides its Objections and Responses to Plaintiffs Interrogatories PRELIMINARY PRELIMINARY PRELIMINARY PRELIMINARY STATEMENT STATEMENT These responses are provided only for those products to which Plaintiff has alleged exposure These responses are based on an ongoing review of PACCAR's documents and - information obtained from ongoing discussions with various PACCAR personnel Much of the information requested dates back many years and is difficult or impossible to reconstruct or retrieve Therefore PACCAR reserves the right to amend these responses if more information becomes available No single employee officer or agent of PACCAR has direct knowledge of the documents necessary to supply each and every answer The person signing these Answers to Interrogatories does so to satisfy whatever requirements may exist under the applicable rules The person does not however have direct knowledge regarding any specific answer but is informed that the review of the documents and discussion referred to above support the answers based on the information as of the date of the signature GENERAL OBJECTIONS PACCAR objects to Plaintiff's interrogatories to the extent that they seek information concerning products other than those products to which Plaintiff has alleged exposure and therefore seek information which is wholly irrelevant to the subject matter of this action and not reasonably calculated to lead to the discovery of admissible evidence PACCAR objects to the Plaintiff's interrogatories to the extent that they seek corporate knowledge as it is impossible for PACCAR to set forth the collective knowledge of all of its past or present employees PACCAR reserves the right to revise correct supplement and amend its answers to provide information discovered subsequent to the answers contained herein PACCAR asserts the following objections and incorporates each by reference into each and every answer to Plaintiff's interrogatories set forth herein a PACCAR asserts the right to object on the grounds of competency privilege relevancy materiality or any other proper ground to the use of any said answers for any purpose in whole or in part in any subsequent step or proceedingin this action or any other action. | b PACCAR asserts the right to object on any other ground to other interrogatories or other discovery procedures involving or relating to the subject matter of the interrogatories answered herein c PACCAR asserts the right to at any time revise correct supplement or clarify any of the answers or objections set forth herein PACCAR objects to the instructions and definitions as outlined in the Plaintiff's interrogatories as overly broad unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence PACCAR further objects to the instructions and definitions as set forth by the Plaintiff in that the definitions contain meanings and defined terms consistent with the Plaintiff's and not this Defendant's interpretation of these defined terms and phrases PACCAR objects to the Plaintiff's interrogatories to the extent that they involve matters outside of the geographical area at issue in this litigation and limits its answers to said area and specifically to those job sites identified by Plaintiff and workers in this case Further these interrogatories ask PACCAR to disclose information most of which may no longer exist or may not be readily available which is unrelated to the claimed work sites the products allegedly used or to which exposure is alleged the locations at which any PACCAR product was allegedly used the conditions under which the products were allegedly used the time period during which any PACCAR product was allegedly in use at any alleged work sites or the time periods during which exposure to a PACCAR product allegedly occurred Thus these interrogatories are overly broad in time scope and location seek information which is neither material nor relevant to the issues in this litigation or are otherwise not reasonably calculated to lead to the discovery of admissible evidence These interrogatories are oppressive and burdensome and would require PACCAR to undertake a massive and extraordinary document search the results of which would have little to no demonstrable bearing on this matter in light of the alleged exposure These interrogatories are not susceptible to a response because they request information which dates back many years and is now virtually impossible for PACCAR to reconstruct or retrieve in its entirety PACCAR objects to these interrogatories because they were propounded to harass and coerce a settlement despite the lack or complete absence of verifiable product information and the lack of evidence of injury as a result of alleged exposure to or use of any product which PACCAR may or may not have manufactured PACCAR objects to these interrogatories because they are propounded for an additional improper purpose namely as a fishing expedition for the purposes of obtaining information ~ that may maybe taken out of context byPlaintiff's counselto create allegations againstPACCAR ~~ where none maylegitimatelyexist PACCAR reserves the right to assert additional objections and to clarify amend or modify these answers at any time as deemed necessary and appropriate by PACCAR PACCAR reserves the right to object to the use of these answers at trial or any other proceeding as deemed necessary and appropriate by PACCAR PACCAR objects to these Interrogatories to the extent that Plaintiff has failed to identify with specificity the PACCAR product allegedly used by or around Plaintiff at any of his work sites PACCAR objects to these interrogatories as overly broad in that they seek information from entities other than itself or its predecessors PACCAR over the course of its long history has owned several businesses which are not involved in the instant litigation Therefore PACCAR makes all responses to these interrogatories and all references in the interrogatories to your company are assumed to refer to PACCAR truck divisions Peterbilt Motors Company and Kenworth Truck Company only PACCAR objects to the Plaintiff's discovery requests to the extent they seek production of any information constituting a trade secret confidential financial data or other confidential research development or commercial information PACCAR objects on the basis that these interrogatories are argumentative in that they assume the PACCAR products which may have contained asbestos create a health hazard which PACCAR denies PACCAR objects to these interrogatories on the basis that they are vague and ambiguous Interrogatories relating to certain diseases fail to provide facts relating to amount of exposure duration of exposure fiber type in exposure and latency period PACCAR objects to these interrogatories on the basis that they are overly broad unduly burdensome harassing and not calculated to the discovery of relevant and material evidence in that they are not confined to the products to which Plaintiff claims exposure The interrogatories @ @ are overly broad in that they tend to group together all of the defendants Without waiving any of the foregoing objections PACCAR states as follows ANSWERS TO INTERROGATORIES INTERROGATORY NO 1 Identify the person answering these interrogatories on behalf of Defendant ANSWER ~ PACCARwith the assistancofe itscounsel INTERROGATORY NO 2 Has the person answering these interrogatories made reasonable inquiry of all available sources of information such that Plaintiff may rely upon these answers as the truthful and complete answers made on behalf of Defendant List any and all such sources of information relied upon ANSWER Yes The following responses are based upon the information that is presently known and reasonably available to PACCAR PACCAR believes that these responses are accurate as of the date made However many of the matters inquired about in the discovery request took place decades ago Due to the passage of time information may be incomplete or no longer available Nevertheless PACCAR has endeavored to investigate all relevant facts and circumstances The following answers are based upon that investigation PACCAR cannot however exclude the possibility that continued investigation may reveal more information PACCAR's investigation into the matters inquired into in the discovery requests continues The investigation is dependent upon locating knowledgeable individuals and relevant documents and information on an ongoing . basis No finite completion date can be placed upon those efforts PACCAR has made a reasonable effort to answer the discovery requests to the best of its present knowledge information and belief INTERROGATORY NO 3 State the following concerning this Defendant a Full and correct name b The form in which Defendant presently conducts business i.e. corporation partnership proprietorship etc. 03 Identify any and all predecessors and related companies as defined above 03 Any and all other forms in which defendant has conducted business at any time and the date when business was conducted in each form e Any and all names by which Defendant has been known or has conducted business at any time and the date during which Defendant has been known by and conducted business und

Defendant objects to Plaintiffs definition of the words "trade organization" and "trade association" because it is overbroad and unduly burdensome.

Chemical Manufacturers Association 5.

Chemical Manufacturers Association 5.

List any and all such sources of information relied upon.

It's the Asbestos Hazards Emergency Response 5 Act, and for clearance of school buildings after removal of 6 asbestos the U.S.

As worded, this document request could reach information BSR\504531 -4- which is confidential and/or proprietary business information.

Defendant objects to Plaintiffs definition of the words "trade organization" and "trade association" because it is overbroad and unduly burdensome.