SHIPPING >3 BUILDING SERVICE INDUSTRIAL SALES C0.f INC. 620 N. 108th PLACTE ; .

in itsf i iai Memorandum Oat# January 16, 1^6 To W.

i^C 'l *W*/ John Farther Esq BA FIFireF Editor The Safety & Health Practitioner Paramount Publishing Limited 17-21 Shenley Soad BOEEHAXYOOD Herts VD6 1ST Hay Pear Sir SAFETY & HEALTH PRACTITIONER /JUNE J.3R3.

FEB 2mi 13:05 FR WiLLMPN & RRNOLD 412 366 3462 TO 19733609831 P. 02^-02 1: iFv DEFENDANT'S EXHIBIT HWBU10002656 *\NfcU'00 DANGER CONTAINS ASBESTOS FIBERS AUOID CREATING DUST CANCER AND LUNG DISEASE HAZARD HWBUI0002658 Post - 6/2001 'S~*W HWBUI0002659

INTERROGATORY NO. 65: If your answer to Interrogatory No 64 is "Yes," identify each and every product upon which such a warning was placed, and with respect to each such product identified' (a) State the date on which any order directing that a warning be placed on said ---------- product, first-issued;___________________________________________________ (b) Identify any and all persons participating in the decision to issue that order; (c) State the first date on which such warning was actually placed on said product; (d) State the first date on which such product accompanied by such warning was first sold, distributed or installed; (e) State the exact wordmg of this first warning; (f) State the exact location and size of this first warning as it appeared on said product; (g) Identify any and all persons who participated in any phase ofthe drafting or design of said first warning, including, but not limited to, those who performed the actual drafting and design work, those who reviewed the work, those who edited the work and those who approved the warning, 00 State why you placed such warning on said product, mcluding, but not limited to, whether you placed such warning on said product because you received a directive, command, suggestion, legal opinion, or any type of communication (written or otherwise) from any person, firm, corporation, governmental agency, committee, association, attorney or institute, and (i) Identify any and all documents referring to, relatmg to or reflecting, said warning, its drafting, and/or the decision to place the warning on said product, includmg, but not limited to, any communication as described m subpart (h) of this interrogatory ANSWER TO INTERROGATORY NO. 65: Abex objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, compound, vague and ambiguous and calls for speculation -151-

litigation; legal issues related to corporate governance or management; as well as other legal issues, transactions and claims.

INTERROGATORY NO. 31: Was each of the asbestos-containing products listed in response to Interrogatory No 19 generally expected to reach, or was each packaged to reach, the consumer or user, without substantial change in the condition in which it was sold'?

materials lack relevance to the issues arising in these cases and are not reasonably calculated to lead to the discovery of admissible evidence. 1 Abex also objects to this interrogatory on the ground that it assumes the truth of matters not established or matters not in evidence.

aia/7/3/ppod A3K>3T0S A1TD KPAI/TK ITT TPJS FRICTION HATRIAL IPJSTTSTPY The Probl era Hxposure to asbestos dust is recognised es a potential occupational hazard.

-v V ' ` BENDIX .' ;" .....; .

Pursuant to the Illinois Code of Civil Procedure, plaintiffs will have a reasonable opportunity to examine, audit, inspect and to make copies, compilations, abstracts, or summaries of these boxes of documents, which will be produced to plaintiffs at Abex's facility in Brooklyn, ______________ \ _________________________________________________________________________ New York, where they are maintained m the ordinary course of business, should plaintiffs decide to inspect them.

>ped work ew years, regressive his pulse ssure was alike over inds were PULMONARY ASBESTOSIS.

568 KENNETH M.

* n'l is'i ' mmIiIlf:jt fett' ls BBS, f fe*H' ; Ifrl; ' >, s ' ELEMENTS OF INDUSTRIAL TOXICOLOGY in the handling of wet dross from a light metals plant, in the cleaning of tauk cars which have held sulfuric and hydrochloric adds, in the cleaning of pipes with an add contaminated with arsenic, in the precipita tion of cadmium with metallic zinc, and in other operations.