PROCEDURE BULLETIN TEXAS CITY PLANT FIRE, ENTRY, AND SPECIAL PERMIT PROCEDURE P-0117 PURPOSE The purpose of this bulletin is to define work requiring a rire.

divisions, on the one hand (collectively "Abex"), and their attorneys, both outside and inhouse counsel, on the other hand, as well as documents prepared at the request of, or for the benefit of such counsel or setting forth mental impressions of the attorneys on matters concerning Abex.

INTERROGATORY NO. 38: Identify any and all facilities at which Defendant, any predecessor or any related company, at any time, manufactured or processed asbestos-containing products, or processed raw asbestos.

To the extent that any of the documents that plaintiffs decide to inspect were prepared in anticipation of litigation or for trial or are otherwise covered by the work-product doctrine, or are protected from disclosure by the attorney-client privilege, Abex objects and will not make such documents available to plaintiffs.

INTERROGATORY NO. 53: If your answer to any subpart of Interrogatory No. 52 is "Yes,": (a) Identify the library(ies) involved and state the years during which Defendant, its predecessor or related company was a member of, or otherwise had use of or access to said library; and (b) If applicable, identify the organization or association through which Defendant, its predecessor or related company, obtained the use of or access to, such library(ies).

Abex also objects to this interrogatory on the grounds that the information and/or documents requested are subject to confidentiality agreements and/or Court issued Protective Orders.

1 A Yes.

1 products consult with medical and industrial hygiene Page 262 2 professionals to make sure that hazardous materials 3 that are incorporated into those products don't pose a 4 safety risk?

ClaH Part No.

BALKAMP/ INC* / Indianapolis, Indiana 46241

Balkamp ALPHABETICAL listings Modal PwtH*.

PLAINTIFF'S EXHIBIT f i sc 001499 LAW1002702 SC 001500 LAM002703

PROCEDURE BULLETIN-tpxm wty pi amt Luhb PktVtNTION it SAP11Y SECTION - NUMERICAL LISTING - TABLE OF CONTENTS Code Latest Issue Date Latest Review Date Procedure Title * P-0100 P-0101 P-0102 P-0103 P-0104 P-0105 P-0106 P-0107 P-0108 P-0109 P-01 10 P-01 1 1 P-01 12 P-01 13 P-01 14 P-01 15 P-01 16 P-01 17 P-01 18 P-01 19 P-0120 P-0120 P-0121 P-0122 P-0123 P-0124 P-0124 P-0125 P-0126 P-0127 P-0128 P-0129 P-0130 P-0131 P-0132 P-0133 P-0!

GENERAL SERVICE ITEMS AND ACCESSORIES Class Part No.

4NAPA> B aIkamp LICENSE PLATE BRACKETS-256 Adjustable Clamps on Front Bumper of Late Model Cars 3-4937 Volkswagen Bracket Designed for Front and Rear Heavy Gauge Steel 3-4933 Quick change holder fabricated of rust resistant, zinc plated spring steel.