INTERROGATORY NO. 3: Please list all trade organizations, trade associations and

Celanese objects to paragraph six of the DEFINITIONS to the extent information is sought concerning asbestos in a non-friable form. 11.

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

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 Counsel, Asbestos Information Association, Industrial Medical Association) in which information or documents 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).

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 or documents 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 F:\CCR\Galveston\Tijerina, Quinto\UNC-Answers to Rogs, RFP and RFA.wpd research relating to asbestos or its effects on animals or humans, populations at risk).

Some of the information included is very interesting and is contrary to general belief.

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 Counsel, Asbestos Information Association, Industrial Medical Association) in which information or documents 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).

Additional information pertinent to the subject matter of this interrogatory would be located in OC's collection of docu ments related to asbestos as set forth below.

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

An | Information * - Resource f_ A_ * "*J4V./ . 4 U.S.

You are authorized to verify all information.

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 or documents 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).

Asbestos Corporation Ltd., is prohibited from disclosing such information by the requirements of the Quebec Business Concerns Records Act, Chapter D-12 of the Revised Statutes of Quebec PAGE I (1977).

Beazer East objects to each interrogatory to the extent that the request seeks information unrelated to any of the plaintiffs in the Butler County, Ohio, asbestos litigation, in that such a request is overbroad, and the information sought is not reasonably calculated to lead to the discovery of admissible evidence. 4.

Beazer East objects to each interrogatory to the extent that the request seeks information unrelated to any of the plaintiffs in the Butler County, Ohio, asbestos litigation, in that such a request is overbroad, and the information sought is not reasonably calculated to lead to the discovery of admissible evidence. 4.