Without waiving the foregoing objections, Defendant answers that it is impossible to know in an organization the size of this Defendant exactly what year it would have obtained this kind of information. 4 INTERROGATORY NO. 3: Please list all trade organizations, trade associations and any other industry-wide groups to which you belong(ed) (specifically including but not limited to the following groups: American Hygiene Foundation, Industrial Hygiene Foundation, Chemical Manufacturer's Association, American Chemical Council, American Petroleum Institute, Texas Chemical Council, Ohio Safety Congress, National Safety Council, Asbestos Information Association, Industrial Medical Association) in which information or documents relating to asbestos was discussed, disseminated, or published (including, but not limited to, the effects of exposure to asbestos, industrial hygiene measures relating to asbestos dust, and medical information or research relating to asbestos or its effects on animals or humans, populations at risk).

Without waiving the foregoing objections, Defendant answers that it is impossible to know in an organization the size of this Defendant exactly what year it would have obtained this kind of information. 4 INTERROGATORY NO. 3: Please list all trade organizations, trade associations and any other industry-wide groups to which you belong(ed) (specifically including but not limited to the following groups: American Hygiene Foundation, Industrial Hygiene Foundation, Chemical Manufacturer's Association, American Chemical Council, American Petroleum Institute, Texas Chemical Council, Ohio Safety Congress, National Safety Council, Asbestos Information Association, Industrial Medical Association) in which information or documents relating to asbestos was discussed, disseminated, or published (including, but not limited to, the effects of exposure to asbestos, industrial hygiene measures relating to asbestos dust, and medical information or research relating to asbestos or its effects on animals or humans, populations at risk).

United United Gypsum Gypsum States Gypsum States Gypsum Association Association Company Company 1 GYPSUM ASSOCIATION DIRECTORS TASK FORCE PROGRAM Mr.

I 2 8 am a video specialist from Maggard 2 2 Associates, whose principal place of 1 5 business is Albany, New York.

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

Was that also an asbestos case?

BLACKWELL, 22 22 Representing Borg-Wamer. 23 23 24 24 Page 2 Page 4 1 APPEARANCES: 1 INDEX 2 2 WITNESS EXAMINATION 3 BRENT COON & ASSOCIATES 4 (3550 Fannin 3 CARL LIGGETT 4 By Mr.