In responding to these 18 interrogatories, responding party has provided such information as is presently available.

These responses 28 3- - 1 are based on the most current information. 2 0.

The number of each question and its subpart for which such personnel provided information; b.

Additionally, Ford in its own ongoing searches for information which may be relevant to asbestos litigation has accumulated approximately 20,000 pages of non-privileged documents.

The words "trade organization," or "trade association" mean any organizations or associations of business or industrial entities that are associated and/or meet for the purpose of achieving common goals and/or exchanging information related to common needs 6- - or interests, and/or learning information or facts of interest to the various members of the organization or association. 13.

Also provide historical information regarding all predecessors, prior names, asset purchases, acquisitions or spin-offs.

Accordingly, Ford does not, 3 and could not possibly, represent that its responses constitute all 4 of the information requested.

Union 21 Carbide's answers to these interrogatories are based on information known to Union Carbide at 22 this time.

Also provide historical information regarding all predecessors, prior names, asset purchases, acquisitions or spin-offs for all associated business entities that were involved, in any manner, in the sale, manufacture, distribution, and/or mining of asbestos and/or asbestos containing products.

The number of each question and its subpart for which such personnel provided information; b.

Also provide historical information regarding all predecessors, prior names, asset purchases, acquisitions or spin-offs.

The words "trade organization," or "trade association" mean any organizations or associations of business or industrial entities that are associated and/or meet for the purpose of achieving common goals and/or exchanging information related to common needs or interests, and/or learning information or facts of interest to the various members of the organization or association. 13.

Pleural thickening associated with asbestosis is usually calcified and has a significant frequency of malignant mesothelioma of the pleura or the peritoneum. 24 ...... w.-.

Draft 12/27/79 RECOMMENDED STANDARD FOR ASBESTOS EXPOSURE IN CONSTRUCTION AND OTHER NON-FIXED WORK OPERATIONS Submitted to the Subgroup on Health Standards of the Advisory Committee on Construction Safety and Health by The Asbestos Information Association of North America and The Association of Asbestos Cement Pipe Producers CAP CO JEN 0012540 TABLE OF CONTENTS ?

Discovery is continuing and Abex reserves the right to supplement this answer should further information become available. 2.