Abex further objects to these interrogatories to the extent that they make no distinction among exposure to raw asbestos fibers, exposure to asbestos-containing building products and exposure to asbestos-containing automotive friction products.

Please state whether or not you have ever held a certif icate of authority to do business in the State of North Dakota and the date thereof and the address of your principal place of business and whether you have assumed the assets and/or liabilities of any predecessor corporation or entity (such predecessor corpora tions being limited to any association whatsoever with the asbestos aspect of the Defendant's business).

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

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1/31ENVIRONMENTAL FACTS/Asbcslos A Condensation of Environmental Facts On ASBESTOS and HEALTH Presented at a Series of Customer Seminars by JOHNS-MANVILLE CORPORATION PRODUCED JM -83 For further information on this subject please contact: Environmental Affairs Department Johns-Manville Greenwood Plaza Denver, CO 80217 PRODUCED JM -83 !

That is the period in which we find ourselves now with asbestos fiber.

Defendant further objects to each request for information or documents to the extent that it seeks non-relevant information or documents.

^ A Condensation of Environmental Facts On ASBESTOS and HEALTH Presented at a Series of Customer Seminars by 0 JOHNS-MANVILLE CORPORATION PRODUCED JM -83 t i I V \ * For further information on this subject please contact: Environmental Affairs Department Johns-Manville Greenwood Plaza Denver, CO 80217 PRODUCED JM-83 * * TABLE OF CONTENTS Introduction to Asbestos and Health.................................................................................... 1 Overview....;.....................................................................................................

Therefore, GPR reserves the right to supplement these responses when, if, and as information is discovered.

In addition to published information of all kinds, I examined files, unpublished information available fi*om the U.S. government archives, the archives of scientists and the archives of institutions that had worked for and with asbestos companies.

ktht Mimii ENVIRONMENTAL FACTS/Asbestos in A Condensation of Environmental Facts On ASBESTOS and HEALTH Presented at a Series of Customer Seminars by JOHNS-MANVILLE CORPORATION t PLAINTIFFS * Ia^EXHIBIT I PRODUCED JM -83 t I $ i For further information on this subject please contact: Environmental Affairs Department Johns'Manville Greenwood Plaza Denver, CO 80217 produced jM - 83 TABLE OF CONTENTS Introduction to Asbestos and Health..........

and Compllimce officers to fulfill this gonj The :i.pi* o Kthnd^rd* aill pr^sc rihe informing 'f;f!

a I ASBESTOS INFORMATION ASSOCIATION; tv..^ ..fy -- ......................................... ..

SWBT states that until it has had sufficient opportunity to examine and/or evaluate through additional physioian(s) Plaintiffs Decedent's alleged asbestos-related disease, SWBT contends that Decedent's injuries were either not caused by asbestos or caused by asbestos to which he was exposed while not working for the Defendant 2) Lack ofexposure to asbestos while employed by SWBT.