Walter Sent from my iPhone Referred to DOE Margaret Coleman Team Lead, Exploration and Production Analysis Office of Petroleum, Natural Gas and Biofuels Analysis U.S.

CHESTERTON COMPANY et al ) CORPORATION'S RESPONSES TO 15 ) PLAINTIFFS SPECIAL Defendants ) INTERROGATORIES 16 ) ) Trial Date 3/22/10 17 ) Action Filed 7/29/09 .)) 18 19 PROPOUNDING PARTY : 20 RESPONDING PARTY : Plaintiffs RHODA EVANS and BOBBY EVANS Defendant KUBOTA CORPORATION 21 SET NUMBER 22 : ONE 1 23 Defendant KUBOTA CORPORATION hereby provides Responses to Plaintiff's Special 24 Interrogatories Propounded to Defendant Kubota Corporation Individually and as Successor 25 interest to Kubota Iron and Machinery Works and Kubota America as follows 35 GENERAL OBJECTIONS 27 Responding Party Defendant KUBOTA CORPORATION contends that many of these 28 interrogatories are objectionable as overly broad unduly burdensome not reasonably calculated 03/15/2010 03/15/2010 17:07 FAX 003/130073/137 to lead to the discovery of admissible evidence vague and ambiguous as applied to KUBOTA 2 CORPORATION and inconsistent with the requirements of the California Code of Civil 3 Procedure Accordingly KUBOTA CORPORATION has responded to the discovery as 4 understood Further in attempting to respond KUBOTA CORPORATION is hampered by the 5 passage of time Thus documents witnesses and evidence that may have helped KUBOTA CORPORATION to more completely respond to this discovery and defend itself in this litigation may no longer be in existence or available These responses are made solely for the purpose of litigation in Los Angeles County State of California To the extent applicable and expressly incorporated below the following objections are 10 incorporated in the response to each individual interrogatory 11 a KUBOTA CORPORATION objects generally to these interrogatories to the 12 extent they request information that is nol within KUBOTA CORPORATION's possession 13 custody or control However KUBOTA CORPORATION has conducted a good faith 14 investigation and reasonable search for information with which to respond to these 15 interrogatories These responses are made on behalf of KUBOTA CORPORATION only with 16 regard to information existing during the time asbestos cement pipe was exported to the United 17 States from 1962 to 1975 18 b KUBOTA CORPORATION objects generally to these interrogatories to the 19 extent they request information directed towards products topics and issues beyond the 20 KUBOTA CORPORATION products about which plaintiffs make allegations on the grounds 21 that such interrogatories are overly broad unduly burdensome oppressive and request 22 information that is not relevant to the subject matter of this litigation and not reasonably 23 calculated to lead to the discovery of admissible evidence 24 c KUBOTA CORPORATION objects generally to these interrogatories to the 25 extent they request information protected by the attorney privilege and the attorney 26 product doctrine 27 In responding to this discovery KUBOTA CORPORATION has furnished information 28 that is now available which may include hearsay and other forms of information that are neither 03/15/2010 03/15/2010 17:07 FAX 004/130047/137 reliable nor admissible as evidence In conducting its business KUBOTA CORPORATION has created documents that may have been kept in numerous different locations and may have 3 been moved from site to site As required by law these responses reflect all responsive 4 information identified by KUBOTA CORPORATION pursuant to a diligent search and reasonable inquiry To the extent that any discovery requires more KUBOTA CORPORATION objects because the discovery requests KUBOTA CORPORATION to conduct a scarch beyond 7 the scope of permissible discovery contemplated by law and compliance with such requests would impose an undue burden on KUBOTA CORPORATION KUBOTA CORPORATION interprets these interrogatorics as requesting information 10 that is not protected by the attorney privilege and the attorney product doctrine 11 KUBOTA CORPORATION provides the information in these responses solely for the purpose 12 of the present litigation KUBOTA CORPORATION expressly reserves all objections to the 13 attempted use of this information beyond the present forum complex asbestos litigation in Los 14 Angeles County 15 KUBOTA CORPORATION's investigation and discovery are ongoing KUBOTA 16 CORPORATION reserves the right to object to future discovery on the same or related matters 17 and does not waive any objection by providing the information reflected in these responses 18 KUBOTA CORPORATION further reserves the right to object to the admissibility of any of 19 these responses in whole or in part at trial in any action on any grounds including but not 20 limited to materiality relevance and privilege 21 Subject to the foregoing General Objections that are included without being individually 22 repeated in each of the following responses KUBOTA CORPORATION responds 23 KUBOTA'S RESPONSE TO PLAINTIFFS SPECIAL INTERROGATORIES 24 25 SPECIAL INTERROGATORY NO.1 26 IDENTIFY the June 29 2005 announcement regarding the occurrence of many 27 occupational victims of asbestos as well as the victims asbestos dust from environmental 28 exposure around the Kanzaki plant 3 03/15/2010 03/15/2010 17:08 FAX 005/137 005/137 RESPONSE TO SPECIAL INTERROGATORY NO 1 KUBOTA objects to this request as it invades the right to privacy of various individuals and their families is overly broad in scope unduly burdensome oppressive harassing irrelevant and not reasonably calculated to lead to the discovery of admissible evidence as to information 5 related to other containing products besides asbestos pressure pipe The 6 requested information is also protected by a confidentiality provision Compromise agreements and statements of sympathy are also protected by Evidence Code sections 1152 and 1160 Should KUBOTA be ordered to reveal such information said order will force KUBOTA to breach its confidential contract with third parties This demand also requests information that may be protected by the attorney and attomey work product privileges SPECIAL INTERROGATORY NO 2 IDENTIFY the approximately 75 former workers of the Kanzaki Plant developed mesothelioma as a result of their exposure to the plant's containing products and have died as a result of this fatal disease RESPONSE TO SPECIAL INTERROGATORY NO 2 16 KUBOTA objects to this request as it invades the right to privacy of various individuals and their families is overly broad in scope unduly burdensome oppressive harassing irrelevant and not reasonably calculated to lead to the discovery of admissible evidence as to information related to other containing products besides asbestos pressure pipe The requested information is also protected by a confidentiality provision Compromise agreements and statements of sympathy are also protected by Evidence Code sections 1152 and 1160 Should KUBOTA be ordered to reveal such information said order will force KUBOTA to 23 breach its confidential contract with third parties This demand also requests information that 24 may be protected by the attorney and attorney work product privileges 25 SPECIAL INTERROGATORY NO 3 26 IDENTIFY the familics you have compensated of deceased workers of the Kanzaki Plant 27 who developed mesothelioma as a result of their exposure to the plant's containing 28 products 4 03/15/2010 03/15/2010 17:08 FAX

CHESTERTON COMPANY et al 15 ee CORPORATION'S RESPONSES TO nee PLAINTIFFS SPECIAL Defendants Sone INTERROGATORIES 16 eee em Trial Date 3/22/10 17 See Action Filed 7/29/09 18 19 PROPOUNDING PARTY : 20 RESPONDING PARTY : 21 SET NUMBER : 2222 Plaintiffs RHODA EVANS and BOBBY EVANS Defendant KUBOTA CORPORATION ONE 1 2222 Defendant KUBOTA CORPORATION hereby provides Responses to Plaintiff's Special 24 Interrogatories Propounded to Defendant Kubota Corporation Individually and as Successor 25 interest to Kubota Iron and Machinery Works and Kubota America as follows 26 GENERAL OBJECTIONS 27 Responding Party Defendant KUBOTA CORPORATION contends that many of these 28 interrogatories are objectionable as overly broad unduly burdensome not reasonably calculated DEFENDANT KUBOTA CORPORATION'S RESPONSES TO PLAINTIFFS SPECIAL INTERROGATORIES SET ONE to lead to the discovery of admissible evidence vague and ambiguous as applied to KUBOTA CORPORATION and inconsistent with the requirements of the California Code of Civil Procedure Accordingly KUBOTA CORPORATION has responded to the discovery as understood Further in attempting to respond KUBOTA CORPORATION is hampered by the passage of time Thus documents witnesses and evidence that may have helped KUBOTA CORPORATION to more completely respond to this discovery and defend itself in this litigation may no longer be in existence or available These responses are made solely for the purpose of litigation in Los Angeles County State of California To the extent applicable and expressly incorporated below the following objections are 10 incorporated in the response to each individual interrogatory 11 a KUBOTA CORPORATION objects generally to these interrogatories to the 12 extent they request information that is not within KUBOTA CORPORATION's possession 13 custody or control However KUBOTA CORPORATION has conducted a good faith 14 investigation and reasonable search for information with which to respond to these 15 interrogatories These responses are made on behalf of KUBOTA CORPORATION only with 16 regard to information existing during the time asbestos cement pipe was exported to the United 17 States from 1962 to 1975 18 b KUBOTA CORPORATION objects generally to these interrogatories to the 19 extent they request information directed towards products topics and issues beyond the 20 KUBOTA CORPORATION products about which plaintiffs make allegations on the grounds 21 that such interrogatories are overly broad unduly burdensome oppressive and request 22 information that is not relevant to the subject matter of this litigation and not reasonably 23 calculated to lead to the discovery of admissible evidence 24 c KUBOTA CORPORATION objects generally to these interrogatories to the 25 extent they request information protected by the attorney privilege and the attorney 26 product doctrine 27 In responding to this discovery KUBOTA CORPORATION has furnished information 28 that is now available which may include hearsay and other forms of information that are neither DEFENDANT KUBOTA CORPORATION'S RESPONSES TO PLAINTIFFS SPECIAL INTERROGATORIES SET ONE reliable nor admissible as evidence In conducting its business KUBOTA CORPORATION has created documents that may have been kept in numerous different locations and may have 3 been moved from site to site As required by law these responses reflect all responsive 4 information identified by KUBOTA CORPORATION pursuant to a diligent search and 5 reasonable inquiry To the extent that any discovery requires more KUBOTA CORPORATION objects because the discovery requests KUBOTA CORPORATION to conduct a search beyond 6 the scope of permissible discovery contemplated by law and compliance with such requests would impose an undue burden on KUBOTA CORPORATION KUBOTA CORPORATION interprets these interrogatories as requesting information 10 that is not protected by the attorney privilege and the attorney product doctrine 11 KUBOTA CORPORATION provides the information in these responses solely for the purpose 12 of the present litigation KUBOTA CORPORATION expressly reserves all objections to the 13 attempted use of this information beyond the present forum complex asbestos litigation in Los 14 Angeles County 15 KUBOTA CORPORATION's investigation and discovery are ongoing KUBOTA 16 CORPORATION reserves the right to object to future discovery on the same or related matters 17 and does not waive any objection by providing the information reflected in these responses 18 KUBOTA CORPORATION further reserves the right to object to the admissibility of any of 19 these responses in whole or in part at trial in any action on any grounds including but not 20 limited to materiality relevance and privilege 21 Subject to the foregoing General Objections that are included without being individually 22 repeated in each of the following responses KUBOTA CORPORATION responds 23 KUBOTA'S RESPONSE TO PLAINTIFFS SPECIAL INTERROGATORIES 24 25 SPECIAL INTERROGATORY NO.1 26 IDENTIFY the June 29 2005 announcement regarding the occurrence of many 27 occupational victims of asbestos as well as the victims asbestos dust from environmental 28 exposure around the Kanzaki plant 3 DEFENDANT KUBOTA CORPORATION'S RESPONSES TO PLAINTIFFS SPECIAL INTERROGATORIES SET ONE RESPONSE TO SPECIAL INTERROGATORY NO 1 KUBOTA objects to this request as it invades the right to privacy of various individuals and their families is overly broad in scope unduly burdensome oppressive harassing irrelevant and not reasonably calculated to lead to the discovery of admissible evidence as to information related to other containing products besides asbestos pressure pipe The requested information is also protected by a confidentiality provision Compromise agreements 6 and statements of sympathy are also protected by Evidence Code sections 1152 and 1160 8 Should KUBOTA be ordered to reveal such information said order will force KUBOTA to 9 breach its confidential contract with third parties This demand also requests information that 10 may be protected by the attorney and attorney work product privileges 11 SPECIAL INTERROGATORY NO 2 12 IDENTIFY the approximately 75 former workers of the Kanzaki Plant developed 13 mesothelioma as a result of their exposure to the plant's containing products and have 14 died as a result of this fatal disease 15 RESPONSE TO SPECIAL INTERROGATORY NO 2 16 KUBOTA objects to this request as it invades the right to privacy of various individuals 17 and their families is overly broad in scope unduly burdensome oppressive harassing irrelevant 18 and not reasonably calculated to lead to the discovery of admissible evidence as to information 19 related to other containing products besides asbestos pressure pipe The 20 requested information is also protected by a confidentiality provision Compromise agreements 21 and statements of sympathy are also protected by Evidence Code sections 1152 and 1160 22 Should KUBOTA be ordered to reveal such information said order will force KUBOTA to 23 breach its confidential contract with third parties This demand also requests information that 24 may be protected by the attorney and attorney work product privileges 25 SPECIAL INTERROGATORY NO 3 26 IDENTIFY the families you have compensated of deceased workers of the Kanzaki Plant 27 who developed mesothelioma as a result of their exposure to the plant's containing 28 products 4 DEFENDANT KUBOTA CORPORATION'S RESPONSES TO PLAINTIFFS SPECIAL INTERROGATORIES SET ONE RESPONSE TO SPECIAL INTERROGATORY NO 3 KUBOTA objects to this request as it invades the right to privacy of various individuals and their families is overly broad in scope unduly burdensome oppressive harassing irrelevant and not reasonably calculated to lead to the discovery of admissible evidence as to information related to other containing products besides asbestos pressure pipe The 6 requested information is also protected by a confidentiality provision Compromise agreements 7 and statements of sympathy are also protected by Evidence Code sections 1152 and 1160 8 Should KUBOTA be ordered to reveal such information said order will force KUBOTA to 9 breach its confidential contract with third parties This demand also requests information that 10 may be protected by the attorney and attorney work product privileges 11 SPECIAL INTERROGATORY NO 4 12 Do YOU contend that residents of Arnagasaki City Japan did not develop mesothelioma 13 during and after the years the Kanzaki Plant produced containing products as a result of 14 exposure to the Kanzaki Plant's containing products 15 RESPONSE TO SPECIAL INTERROGATORY NO 4 16 KUBOTA objects to this request as it invades the right to privacy of various individuals 17 and their families is overly broad in scope unduly burdensome oppressive harassing irrelevant 18 and not reasonably calculated to lead to the discovery of admissible evidence as to information 19 related to other containing products besides asbestos pressure pipe The 20 requested information is also protected by a confidentiality provision Compromise agreements 21

Is the organization or host of the event a registered 501(c)(3), (4), or has a 527 Political Action Committee (PAC): No, the Marcellus Shale Coalition as the lead conference partner is a 501(c)(6) not-for-profit trade association.

The rule requires schools to test each potable water outlet for lead, specifies an action level of 15 micrograms per liter for lead in drinking water of school buildings, and establishes initial and future monitoring requirements.

EPA 18cv3472 NDCA Tier 10 ED 002061 00259279-00004 2:00 - 2:40 Lead Topic Introduction: Hayley Hughes, National Lead Coordinator Di scussi on 0 uestions 1.

The poll found [Democrat Phil] Murphy leading [Lt.

Such action woul d prevent or minimize the current potential for lengthy studies and unconstrained damage claims and lead to more expeditious and cost-effective restoration of affected resources.

One year ago, Fox News had a dominant primetime lineup, with Bill O'Reilly leading into Megyn Kelly leading into Hannity.

The rule requires schools to test each potable water outlet for lead, specifies an action level of 15 micrograms per liter for lead in drinking water of school buildings, and establishes initial and future monitoring requirements.

Is the organization or host of the event a registered 501(c)(3), (4), or has a 527 Political Action Committee (PAC): No, the Marcellus Shale Coalition as the lead conference partner is a 501(c)(6) not-for-profit trade association.

s explanations of the meetings also changed from Saturday to Sunday, leading to a devastating front page for Trump's eldest son.

Such action would prevent or minimize the current potential for lengthy studies and unconstrained damage claims and lead to more expeditious and cost-effective restoration of affected resources.

It is also important to request studies that directly lead to development of specific license provisions that mitigate for known project effects.

Liz Menz I Director of Education I SIGMA America's Leading Fuel Marketers 3930 PP,ndP,r DriVP,, SuitP, 340, rairfax, VA 22030 I Dirnct: 703.375.0483 I www.siqma.org From: Ford, Hayley [mailto:ford.hayley@ cpa.go_y] 17cv01906 Sierra Club v.