IN RE: ALL ASBESTOS-RELATED ) PERSONAL INJURY OR DEATH ) CASES FILED BY BARON & ) BUDD, P.C.

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PLAINTIFF'S EXHIBIT 4 s.* iw \ t C;:: >t-. .

1A5-I 2/2-1U-78 THE BABCOCK l WILCOX COMPANY POWER GENERATION GROUP INDUSTRIAL & MARINE DIVISION SPECIFICATION FOR INSULATION MATERIALS CONFIDENTIAL 13M Vendor is to list for each insulation item and part thereof, the square feet area of component involved and the extra per cent of quantity included for breakage in shipment, handling and erection. iLM Use of all types of medium temperature block approved by B&W Co. is permitted where medium temperature block is called for. 15M We require on the 15th and last of each month a report showing percentage of material shipped to the job site to date.

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To the extent that the information contained herein differs in any respect from any prior answer to discovery, these answers shall be deemed to update and supersede any prior answers' in any and all actions.

b. member of the families of workers; If your answer is "yes", state what that knowledge is and when it was received.

one of their components.

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7m* LABORATORY TOR THI STUDY Of TUSMCULOSU o tm* KWAta u nupAU rawMOAnoM UwtC Lajo.

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INTERROGATORY NO. 48.2: V State whether any records concerning the manufacture, sale, supply, distribution, advertising, delivery, use or installation or tear-out of asbestos-containing products have been destroyed or discarded and if so, indicate: (a) the date and location of such destruction or discard; (b) the custodian and location of such records prior to their destruction or discard and the identity of each employee, representative, official or agent who ordered, authorized or supervised such destruction or discard.

Abex object to this request to the extent to which it seeks information regarding time periods and products that are not at issue in this case on the ground that such information lacks relevance, and is not reasonably calculated to lead to the discovery of admissible evidence.