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 Defendant objects to these Interrogatories on the grounds that they call for information which is protected by the attorney-client privilege and work product doctrine. 2.

That is the period in which we find ourselves now with asbestos fiber.

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 -6- or interests, and/or learning information or facts of interest to the various members of the organization or association. 13.

T echnical B u lle tin #83-3 "Asbestos Exposures".

The interrogatories request information going back many years and Garlock has found it difficult, if not impossible, to reconstruct or retrieve much of the information requested.

Hall objects to Plaintiffs' Interrogatories to the extent that they purport to request information concerning mining, manufacturing, installation, removal, or "tear-out" of asbestos-containing products.

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

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.

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.

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.

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; C

The present OSHA Asbestos Standard discussed in this booklet became effective July 7 1972 Thorough understanding of the standard is important to management of any company utilizing asbestos in its manufacturing or processing operations The work practices on the following pages have been prepared by the Standards and Technical Committee of the Asbestos Information Association America They are intended as general guidance for safe and clean workplace conditions in keeping with the spirit and intent of the OSHA Standard for Occupational Exposure to Asbestos Dust : These practices have been developed through careful study and consultation and are recommended as good procedure It is recognized that manufacturing conditions vary Implementation of the practices contained herein cannot be considered as a guarantee of OSHA compliance Where there may be a question of compliance OSHA personnel should be consulted A proposed revision to the OSHA Asbestos Standard was published in the Federal Register on October 9 1975.

Hamilton, Inc. objects to providing any information with regard to any of its products which are not at issue in this case.