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PLAINTIFF'S EXHIBIT PLANT NAME CONSULTING ENGINEER men I^ 1 Mansfield .............. ..

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PLAINTIFFS EXHIBIT RR-419e THIS BOOK IS THE PROPERTY OP SOUTHERN RAILWAY SYSTEM ISSUED TO Occupation ud mutt be returned to the proper office* when called for, or when leaving the service.

Cause No. 94-4608-A JOE NATHAN ELMORE, ET AL WOODROW EINDERS HONEYCUTT OWENS-CORNING FIBERGLASS CORPORATION, ET AL NORFOLK SOUTHERN RAILROAD COMPANY (individually and as a subsidiary of NORFOLK SOUTHERN CORPORATION and as successorin-interest to SOUTHERN RAILWAY COMPANY) IN THE DISTRICT COURT 28TH JUDICIAL DISTRICT NUECES COUNTY, TEXAS OBJECTIONS AND ANSWERS OF NORFOLK SOUTHERN RAILWAY COMPANY TO PLAINTIFF'S FIRST SET OF INTERROGATORIES SUBJECT TO DEFENDANT'S SPECIAL APPEARANCE Subject to Defendant's Special Appearance, Defendant, Norfolk Southern Railway Company (NSRC) f/k/a Southern Railway Company (Southern), for its Objections and Answers to Plaintiffs First Set of Interrogatories, states as follows: PRELIMINARY STATEMENT AND GENERAL OBJECTION The following responses are being provided after diligent investigation and inquiry by Defendant.

CAUSE NO. 96-00261 LLOYD CHAMPION AND DORIS MAE CHAMPION; WILTON CHESTER JORDAN AND FRANK LEWIS SAUNDERS H VS.

< * HAROLD LARMOUR,etal., vs.

On July 15, Sid Haynes and I conducted an asbestos insulation inspection in Facilities 26, 30, and 33.

JN-TRACOMPANY CORRESPONDENCE R.98 (Rov.

MARINE DIVISION ASBESTOS INTERROGATORIES TX TINER RMC0024195 Thirty-five Year Index 6.

PROTECTING THE WORKER: RESPIRATORS AND PROTECTIVE CLOTHING Instructor's Notes: Respirators and protective clothing can be a complicated subject within themselves.