As worded, this document request could reach information BSRV504537 -4- which is confidential and/or proprietary business information.

McCrone Associates and the

DeLUCA, ESQUIRE 21021 Springbrook Plaza Drive Suite 150 Spring, Texas 77379 281-378-5070 Counsel for Plaintiffs ROBERT PEIRCE & ASSOCIATES, PC BY: R.

William Roberts, Jr. & Associates (800) 743-DEPO Carl Liggett - December 12,2001 Page 6 1 MS.

B0 Page 3 EXHIBITS, continued P-14 Internal Letter dated September B, 1987, 4 pages....................83 P-15 Industrial Hygiene Survey, Rockwell-Standard Company, Ashtabula, Ohio, July 21, 1971.... 90 P-16 National Safety council, Automotive, Tooling, Metalworking and Associated Industries Newsletter, 4 pages................ 96 P-17 Material Safety Data Sheet for Asbestos-Containing Brake Linings, 7 pages ...............98 10 P-18 Letter dated February 5, 1986, 11 with attachment, 14 pages.........102 12 P-19 Notice ofTaking Deposition and Request for Production of 13 Documents...........................131 14 15 16 17 10 19 20 21 22 23 24 25 Page 4 Page 5 Aiken & Welch Court Reporters 2 (Pages 2 to 5) B.

I am a video specialist with Maggard Associates whose principal place of business is Albany, New York.

Similarly, the Panel concludes that the asbestos-cement products and the fibro-cement products for which sufficient information has be

Substantial progress has been made finding information requested by Plaintiffs.

Therefore, Crane Co. has no information responsive to this Interrogatory.

Therefore, Crane Co. has no information responsive to this Interrogatory.

Similarly, the Panel concludes that the asbestos-cement products and the fibro-cement products for which sufficient information has been s

In brief we were informed that fi Inhaled asbestos dust was potentially cytotoxic if inhaled by workers at high concentrations over long periods of years It could cause diffuse fibrosis of the lung It was a pneumoconiotic dust Those workers at highest risk were in milling and mining operations for the ore and in manufacturing operations for products that utilized the asbestos fiber The health effects of asbestos and the types of workers at risk were first addressed in a seminal report from The United Kingdom in 1930.

Similarly, the Panel concludes that the asbestos- cement products and the fibro-cement products for which sufficient information has been submitted to the Panel are like products within the meaning of Article III:4 of the GATT 1994.

I 1 0 : 0 1 0 9 :3:: '' :41)0 : 0 1 l l ~ '-' am a video specialist with Maggard Associates whose principal place of 1 0 : 0 1 1 J :SJ C ,,1 0 0 1 1 :6J L' business is Albany, New York.

I 19 have an Associate's degree from Finger Lakes 20 Community College, and I have a Bachelor's 21 degree from Roberts Wesleyan. 22 Q- I'm going to mark as the first exhibit 23 this document. 24 (Whereupon, Heffron Exhibit 1, a CV, 25 was then received and marked for Alderson Reporting Company, Inc. 111114th Street, N.W.