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.

(asbestos users from the St.

If not, state the correct legal name of- the defendant and provide the information requested in No. 2 above concerning the defendant as correctly named.

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.

Also provide historical information regarding all predecessors, prior names, asset purchases, acquisitions or spin-offs for all associated business entities that were involved, in any manner, in the sale, manufacture, distribution, and/or mining of asbestos and/or asbestos containing products.

Such information will not be disclosed herein.

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

SUPPLEMENTAL ANSWER TO INTERROGATORY NO. 5(d): In addition to Answers previously given, Mallinckrodt states that there is little information to provide.

Given the foregoing qualifications, the information set forth herein is true and correct to the best of B-L's knowledge and information at this time.

Garlock objects to this Interrogatory on the basis that it assumes the truth of matters in dispute in this litigation, specifically, that there are dangers associated with the use of Garlock asbestos containing products.

Defendant KELLY-MOORE also objects to these 24 Interrogatories to the extent they call for information protected 25 by the attorney-client privilege, or the attorney work-product 26 doctrine, or any other applicable privilege, 6.

DUP 0821079 Asbestos International Association 68 Gloucester Place, London W1H 3HL.

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.