Defendant KELLY-MOORE objects on the grounds these 4 5 Interrogatories are overly broad as to time and scope, are 6 burdensome, and are not reasonably calculated to lead to 7 discovery of admissible evidence, as the interrogatories seek 8 information that covers a time period of 60 years and request 9 Defendant to assimilate documents and information that may or may 10 i not have been retained over such a period of time. 11 2.

The words "trade organization," or "trade association" mean any organizations or associations of business or industrial entities that are associated and/or meet for the purpose of achieving common goals and/or exchanging information related to common needs or interests, and/or learning information or facts of interest to the various members of the organization or association. 13.

The information provided in these answers to requests and interrogatories is based upon such information as is presently available to Abex, and Abex expressly reserves the right to supplement or amend these answers when and if additional relevant information or documentation is discovered.

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.

If responsive information can be located.

The words "trade organization," or "trade association" mean any organizations or associations of business or industrial entities that are associated and/or meet for the purpose of achieving common goals and/or exchanging information related to common needs or interests, and/or learning information or facts of interest to the various members of the organization or association. 13.

Substitutes Table 3 summarizes the primary substitutes for asbestos siding and roofing shingles There are no substitutes for asbestos shingles in the maintenance and repair market because there are no substitute products that resemble the asbestos product closely enough to be able to replace it in parts National Roofing Contractor's Association 1986 Supradur 1986b Slate is the only shingle that would be close in appearance to some asbestos shingles but it is much thicker and far more expensive Supradur 1986b For our study we will consider substitutes that can be used instead of asbestos shingles for complete remodeling or new construction The following section presents separate discussions of substitutes for asbestos siding shingles and asbestos roofing shingles 1.

The information provided in these answers to requests and interrogatories is based upon such information as is presently available to Abex, and Abex expressly reserves the right to supplement or amend these answers when and if additional relevant information or documentation is discovered.

If so, identify the document containing such information by date and location.

(asbestos users from the St.

Subject thereto: American Gas Association.

The words "trade organization," or "trade association" mean any organizations or associations of business or industrial entities that are associated and/or meet for the purpose of achieving common goals and/or exchanging information related to common needs or interests, and/or learning information or facts of interest to the various members of the organization or association. 13.

Hennessy cannot exclude the possibility that its continued investigation may at some time reveal more complete information or even information which indicates an answer now supplied is incorrect, Hennessy, therefore, reserves the right to use and rely upon subsequently discovered facts, information and/or legal theories.

Defendant KELLY-MOORE also objects to these 17 Interrogatories to the extent they call for information protected 18 by the attorney-client privilege or the attorney work-product 19 doctrine. 20 4.

EVER SELL ASBESTOS 5.