Also provide historical information regarding all predecessors, prior names, asset purchases, acquisitions or spin-offs.

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.

(e) Defendant Maremont does not know the chemical composition of each such asbestos-containing product; however, Grizzly products collectively contained the following ingredients: Asbestos, 5R,Asbestos, 6D; Asbestos, 7D; Asbestos, 7M; Asbestos, 8T; Barium Ferrite; Barytes, Bleached and Unbleached; Carbon, Black; Cashew Particles; Cas

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.

This booklet is published by the Asbestos Information Association and is a good reference for specific procedures involving the different types of operations involved in the construction process.

Such information will not be disclosed herein.

Defendant's present slate of incorporation oi stale in which Defendant is registered as a partnership, association, ele., whichever is applicable; il Defendant has, at any time, 2 been incorporated or registered in a diffeient state, identify which slate and when; h.

Asbestos cement; Asbestos Finishes; ii.

Also provide historical information regarding all predecessors, prior names, asset purchases, acquisitions or spin-offs.

ANSWER: The information herein is being provided by Ken Linge with the assistance of outside counsel for PPG Industries, Inc.

Defendant objects to these Interrogatories to the extent that they seek information subject to the attorney-client privilege, information which constitutes work product and/or information which is not otherwise subject to discovery pursuant to the Ohio Rules of Civil Procedure and/or the Local Rules of the Cuyahoga Court of Common Pleas and/or the Standing Order of the Cuyahoga County Asbestos Cases Special Docket. 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.

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).

Such information will not be disclosed herein.

INTERROGATORY NO. 1: 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).