B.

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73.

BALLOT Friction Materials Standards Institute, Inc.

CENTRAL-STATION AND INDUSTRIAL!

0 5 i 0 l 0 z 5 'J 1 1.43 If your answer to the preceding interrogatory is in 2 the affirmative, state: 3 (a) The nature and substance of such agreement; 4 (b) The location of said agreement and/or copies* 5 ANSWER: 6 N/A 7 8 9 10 1.44 State the location of your national and Washington, 11 California and Oregon State warehouse, warehouse facilities, or 12 distribution centers for your asbestos-containing products during 13 the Relevant Times. 14 13 A---N--S--W---E--R: 16 17 S_ o.lon, Ohio Portland, Oregon Los Angeles, California San Francisco, California. 18 19 20 21 22 1.45 Specify the corporate relationship between you and 23 local dealers and/or manufacturer's representatives of asbestos 24 products who sold products containing your corporate identification 25 or trademark during each year of the Relevant Times. 26 PLAINTIFF'S FIRST INTERROGS, ETC. 33

Q 5 !

2 All asbestos waste should be disposed of in accordance with OSHA 3 ind EPA asbestos regulations.

(j) The records retention policies concerning claims of the kinds specified in Part (a) of the defendant, and of any state agencies of which the defendant has knowledge in states where the defendant does business, and to which the defendant supplies information concerning claims of this kind.

V \ Many of these interrogatories call for Abex to characterize the state of knowledge or awareness of a corporation at any given time with regard to a particular fact, event or subject.

V I

.

Abex can only respond to such interrogatories, if at all, by stating on information and belief the degree of knowledge of a particular fact, event or subject as held by a person at a specific time.