Th e Sh e r w in -Wil l ia ms Co . 0007-SWP-C0C0C3996 ~ vi ;.: .

Further, the Request is not limited to the time periods and corresponding specific premises sites relevant in this case, nor limited to the matters made the basis of this case, specifically alleged exposure to asbestos-containing thermal insulation products, and the Request is not reas' lably calculated to lead to the discovery of admissible evidence.

Union Carbide further objects to this Interrogatory on the grounds it is overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence.

Further, the Request is not limited to the time periods and corresponding specific premises sites relevant in this case, nor limited to the matters made the basis of this case, specifically alleged exposure to asbestos-containing thermal insulation products, and the Request is not reas' lably calculated to lead to the discovery of admissible evidence.

Union Carbide further objects to this Interrogatory on the grounds it is overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence.

Union Carbide further objects to this Interrogatory on the grounds it is overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence.

Further, the Request is not limited to the time periods and corresponding specific premises sites relevant in this case, nor limited to the matters made the basis of this case, specifically alleged exposure to asbestos-containing thermal insulation products, and the Request is not reas* :ably calculated to lead to the discovery of admissible evidence.

The company contin ues to maintain an industry leading position in this market because of its size and long term significance.

*vr-- ' - 9?

Further, the Request is not limited to the time periods and corresponding specific premises sites relevant in this case, not limited to the contractors for whom the Plaintiff worked, nor limited to the matters made the basis of this case, specifically alleged exposures to asbestos-containing thermal insulation products, and the Request is not reasonably calculated to lead to the discovery of admissible evidence.

Union Carbide further objects to this Interrogatory on the grounds it is overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence.

.* "> *'Sh i 1 * 'V vVGfiK '* -a Istniw \ '** xV'v ^ "4: I ^\\l 1 I n|2-H PAINT SPECIFICATIONS SPECIFICATION CHART EXTERIOR SURFACES TYPE OF SURFACE CONSTRUCTION Siding Wood Trim & Shutters Wood Shingles and Shakes and Rough Lumber Wood Shingles, Shakes and Wood Siding Wood Porches, Steps, Floors & Decks Wood Barns, Silos, Fences, Corn Cribs Wood Masonry Walls Brick, Stucco, Asbestos Siding Trim Adjacent to Masonry Metal Surfaces Adjacent to Masonry Floors Siding, Trim, Sash, Roofs and Gutters Screens Wood Iron & Steel Cement Metal Copper FINISH Paint Paint Paint Stain Paint Paint Paint Paint Paint Paint Paint Paint DESCRIPTION OF SPECIFICATION White Colors Lead Free or Fume Proof White Mildew Resistant White Semi-Paste White One Coat White Flat House Paint White and Colors Chaik-Resistant White Chalk-Resistant Colors White and Colors Brushing Dip-Coating Colors White (Lead Free) Green or Red Semi-Paste Red Colors White White or Colors White or Colors Colors White & Colors Black SPEC.

ANSWER TO INTERROGATORY NO. 69: Abex objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, compound, vague and ambiguous and calls for speculation Abex also objects to this interrogatory on the ground that it purports to shift the burden of establishing causation from plaintiffs to Abex Abex further objects to this interrogatory to the extent it purports to seek information or materials regarding time periods and products that are not at issue in these cases, on the ground that such information or materials lack relevance and are not reasonably calculated to lead to the discovery of admissible evidence Abex objects to this interrogatory on the grounds that the information or materials it purports to seek otherwise lack relevance to the issues arising in these cases and are not reasonably calculated to lead to the discovery of admissible evidence Abex also objects to this interrogatory on the grounds that it assumes the truth of matters not established or matters not m evidence -159-

LEAD INDUSTRIES ASSOCIATION 420 Lexington.

ANSWER TO INTERROGATORY NO, 39: Abex objects to this interrogatory on the grounds that it is overly broad, burdensome, lacks relevance to this case and is not reasonably calculated to lead to the discovery of admissible evidence.