The diverted material is managed as D008 hazardous waste lead-contaminated sand from product processing.

The diverted material is managed as D008 hazardous waste lead-contaminated sand from product processing.

The display needs to be dismantled and is thermally recycled at temperatures which lead to PFAS decomposition to HF and CO2.

Contract out testing for phenols, cyanide, lead, cadmium, barium, fecal, BOD, and sludge analysis to Microbac.

Contract out testing for phenols, cyanide, lead, cadmium, barium, fecal, BOD, and sludge analysis to Microbac.

However, broken funnel glass would be considered a D008 characteristic hazardous waste if disposed due to its lead content.

Concentrated lead and zinc are stored in an enclosed building before being trucked to the port.

Travis Culliton, Lead Management Program Analyst for the FHWA and Mr.

BEL AIR AUTO PARTS INC et al Defendants * * * * * * CASE NO 23-000029 * * April 8 2025 Trial Date * * * * * * * * * * DEFENDANT PACCAR INC'S OBJECTIONS AND ANSWERS TO PLAINTIFFS MASTER INTERROGATORIES AND NOW Comes Defendant PACCAR Inc Defendant PACCAR or PACCAR INC by and through their counsel DeHay & Elliston LLP and responds to Plaintiffs Master Interrogatories as follows PRELIMINARY STATEMENT These discovery responses are provided only for those products identified by Plaintiff and to which Plaintiff alleges exposure These discovery 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 These discovery responses are made pursuant to a reasonable and diligent investigation and search for the information requested PACCAR reserves the right to amend these discovery responses if new or additional information becomes available to it PACCAR prepared these discovery responses with the assistance of counsel No single employee officer or agent of PACCAR has hand knowledge regarding each and every response The person signing these responses does so to satisfy whatever requirement may exist under the applicable rules regarding verification That person is informed and believes that the information known as of the date of his signature supports the discovery responses below Page 1 of 193 INSTRUCTIONS Plaintiff's definitions and instructions are not repeated herein for the sake of brevity PACCAR objects to Plaintiff's definitions and instructions to the extent they are overbroad unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence PACCAR further objects to Plaintiff's definitions and instructions to the extent they include meanings and characterizations inconsistent with PACCAR's interpretation of the defined terms and phrases GENERAL OBJECTIONS PACCAR asserts the following objections and incorporates each by reference into each and every Answer to Plaintiff's Interrogatories set forth herein a PACCAR objects to Plaintiff's Interrogatories to the extent that they seek corporate knowledge as it is extremely difficult 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 discovery responses to provide information discovered subsequent to the responses contained herein b 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 discovery response for any purpose in whole or in part in any subsequent step or proceeding in this litigation c 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 d PACCAR asserts the right to revise correct supplement or clarify any of its discovery responses set forth herein at any time and PACCAR reserves the right to object to the use of these discovery responses at trial or any other proceeding as deemed necessary and appropriate by PACCAR e PACCAR objects to the extent Plaintiff seeks documents no longer in PACCAR's possession PACCAR's document retention policy is 7 years save for documents that fall under specific categories As such PACCAR may no longer possess documents responsive to certain Requests f PACCAR objects to Plaintiff's Interrogatories to the extent that they involve matters outside of the geographical area at issue in this litigation and limits its discovery responses to said area (g) Furthermore these Interrogatories ask PACCAR to disclose information of which may no longer exist or may not be readily available is unrelated to the products at issue in this case Such information is also unrelated to the locations at which Decedent may have used any PACCAR product the conditions under which Decedent may have Page 2 of 193 used any PACCAR product the time period during which Decedent may have used any PACCAR product or the time period during which Plaintiff alleges exposure to any PACCAR product Thus Plaintiff's Interrogatories seek information which is neither material nor relevant to the issues in this litigation are overbroad in time scope and location and are otherwise not reasonably calculated to lead to the discovery of admissible evidence h Plaintiff's Interrogatories are oppressive 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 litigation in light of the alleged exposure Moreover many of 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 Plaintiff's Interrogatories because they were propounded to harass and coerce a settlement despite the lack or complete absence of verifiable product identification 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 assembled j 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 be taken out of context by Plaintiff's counsel to create allegations against PACCAR where none may legitimately exist k PACCAR objects to Plaintiff's Interrogatories as overbroad 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 all references in Plaintiff's Interrogatories to DEFENDANT YOU or YOUR and the like are assumed to refer only to PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company 1 PACCAR objects to each and every Interrogatory that seeks production of any information constituting a trade secret confidential financial data or other confidential research development or commercial information m PACCAR objects to Plaintiff's Interrogatories as argumentative because they assume that a health hazard is created by the PACCAR products that may have incorporated asbestoscontaining component parts which PACCAR denies n PACCAR objects to Plaintiff's Interrogatories on the basis that they are vague and ambiguous Interrogatories relating to certain diseases fail to provide facts relating to the amount of exposure duration of exposure fiber type in exposure and latency period o PACCAR objects to Plaintiff's Interrogatories in that they tend to group together all of Defendants in this litigation and are therefore overbroad unduly burdensome harassing and not calculated to lead to the discovery of relevant and material evidence Page 3 of 193 p PACCAR objects to each and every Interrogatory that calls for either pure speculation or legal conclusions on the part of PACCAR q PACCAR objects to each and every Interrogatory that calls for a medical conclusion beyond the scope of PACCAR's knowledge and capability r PACCAR objects to each and every Interrogatory that purports to impose any obligations on it that are not set forth in the Maryland Rules of Civil Procedure PACCAR objects that Plaintiff has propounded more than 30 interrogatories in violation of Maryland Rule of Civil Procedure 2-421 These responses are made without waiving its objection based on Rule 2-421 a s PACCAR objects to each and every Interrogatory that seeks information protected by the attorney privilege or attorney work product doctrine t PACCAR objects to each and every Interrogatory that seeks disclosure of information generated by persons other than PACCAR that has come into the possession of PACCAR's counsel during the course of discovery and trial preparation in asbestos litigation u PACCAR objects to each and every Interrogatory that seeks information for any time period unrelated to Decedent's alleged exposure v PACCAR objects to each and every Interrogatory that seeks information that is not under PACCAR's custody or control or which is within the public domain or otherwise equally available to Plaintiff or their counsel Subject to and without waiving any of the foregoing objections PACCAR states as follows RESPONSES TO INTERROGATORIES INTERROGATORY NO 1 State the name address and official capacity of each person who has supplied information used in answering these Interrogatories and indicate for which Interrogatory each such person is responsible RESPONSE TO INTERROGATORY NO 1 PACCAR incorporates its Preliminary Statement and General Objections herein PACCAR objects that this Interrogatory is vague ambiguous compound and unduly burdensome and oppressive PACCAR also objects to this Request as oppressive and burdensome as it would require PACCAR to undertake a massive and extraordinary document search the results of which would have little to no demonstrable bearing on this litigation in light of the alleged exposure Page 4 of 193 Subject to and without waiver of the foregoing objections PACCAR prepared its Answers to Plaintiff's Interrogatories with the assistance of counsel No single employee officer or agent of PACCAR has firsthand knowledge regarding each and every response The following responses were prepar

Waste lead-acid batteries are managed according to 40 CFR Part 266 Subpart G, and are shipped off site

They had already reached out to DG ENV and GROW who are the lead DGs for the strategy.

From: Schroder, Alex Sent: Tue, 6 May 2025 20:21:51 +0000 To: Senn, Chris <FAA> Cc: Matesic, Hannah (OST); Priebe, Jack (OST); Perrino, Madeline A <FAA>; Howard, Katherine <FAA>; McAlvanah, Anna (FAA) Subject: FW: FOR IMMEDIATE RELEASE: Malliotakis Co-Leads Legislation to Ban Non- Essential Helicopters in NYC a UTIO This email originated from outside of the Department of Transportation (DOT).

Congress should lead with him on this.

Will Springer Ridgewood Solutions 1201 Elk Grove Drive Richardson, TX 75251 Re: Toxic Substance Control Act (TSCA) Lead Based Paint Inspection Dear Mr.

Lynn Maupin Pristine Property Management 107 Magnolia Ln Longview Texas 75605 Re: Toxic Substance Control Act (TSCA) Lead Based Paint Inspection Dear Ms.