When the identity of a natural person is requested, the request or inquiry includes the home address, business address, and his former and present position or job title and business affiliation, and, if the person is a corporation or association, the address of its principal place of business. d.

It wasn't only 9 asbestos. 10 Q.

However, the Defendant is able to provide the following responsive information.

What we're trying to do, Mr. 1 2 Myers, obviously is just find out information 13 about Unit>n Carbide in regard to some specific ] 4 items.

Pl.AlNTHT'S EXHIBIT '[ CAP-1734 [ [ Technological Feasibility and Economic Impact of OSHA Proposed Revision to the Asbestos Standard Prepared for: Asbestos Information Association/North America Washington, D.C.

Recently asbestos has been associated with bronchogenic carcinoma, pleural mesothelioma, peri toneal mesothelioma, and cancer of the stomach, colon, and rectum.

Pigg Asbestos Information Asso.

Celanese further states on present information and belief that it was never a member of the American Hygiene Foundation, the American Petroleum Institute, the Ohio Safety Congress, the Asbestos Information Association or the Industrial Medical Association.

INTERROGATORY NO. 3: Please list all trade organizations, trade associations and any other industry-wide groups to which you belong(ed) (specifically including but not limited to the following groups: American Hygiene Foundation, Industrial Hygiene Foundation, Chemical Manufacturer's Association, American Chemical Council, American Petroleum Institute, Texas Chemical Council, Ohio Safety Congress, National Safety Council, Asbestos Informa

Subject to and without waiving these objections, Celanese states that it cannot say with any certainty the first year any one of its employees first became aware of a health risk potentially associated with asbestos exposure, or how such information may have been acquired.

The Asbestos Information Association of North America: Based upon the best information currently available, Union Carbide was a member of this organization during the 70's.

It is not possible to correlate specific answers to interrogatories and sources of information. 2.

Indeed, the interrogatories seek information 18 created many years ago.

Pigg Asbestos Information Asso.

INTERROGATORY NO. 3: Please list all trade organizations, trade associations and any other industry-wide groups to which you belong(ed) (specifically including but not limited to the following groups: American Hygiene Foundation, Industrial Hygiene Foundation, Chemical Manufacturer's Association, American Chemical Council, American Petroleum Institute, Texas Chemical Council, Ohio Safety Congress, National Safety Council, Asbestos Information Association, Industrial Medical Association) in which information ordocuments relating to asbestos was discussed, disseminated, or published (including, but not limited to, the effects of exposure to asbestos, industrial hygiene measures relating to asbestos dust, and medical information or research relating to asbestos or its effects on animals or humans, populations at risk).