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. -6- 13.

Gypsum to engage in unduly burdensome research, divulge privileged information and produce privileged documents.

These answers are further limited to the activities of Grace-Conn's Zonolite and Construction Products Divisions ("CPD") associated with the manufacture and sale of such products in the United States during the relevant time period.

Defendant objects to Plaintiffs definition of the words "trade organization" and "trade association" because it is overbroad and unduly burdensome.

Without waiving the foregoing objections, Defendant answers that it is impossible to know in an organization the size of this Defendant exactly what year it would have obtained this kind of information. 4 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).

It is not possible to list each and every document which was involved in the compilation of this information. 2.

The grounds for this objection are that this part of the interrogatory is overly broad and unduly burdensome and seeks information which is

Wacker Drive Chicago, Illinois 60606 Please send information on multi-purpose corner bead Name- Company- Address__ City______ _State_ -Zip- ASBESTOS AND SILICA DUST 3SHA 3egyiazisns arasa siisosu?

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

Without waiving the foregoing objections, Defendant answers that it is impossible to know in an organization the size of this Defendant exactly what year it would have obtained this kind of information. 4 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).

4F3985.A07, 7F3990 i 9F3992, 9F3978, 1G3001 CPL/pk In the course of responding to discovery over several years, various persons have provided information and referred to documents which persons and documents this defendant is presently unable to identify individually or in relation to specific items of information.

Harry Demopoulos, Associate Professor of Pathology at the New York University Medical Center believes.

Some of the Interrogatories and Request for Production require information which goes beyond the scope of the permissible discovery in that a complete response to the Interrogatories and Request for Production would require disclosure of confidential financial data, confidential research, trade secrets, development or commercial information, or information otherwise confidential.

PDRC generally objects to the unlimited time frame associated with these requests.

As worded, this document request could reach information BSRA508617 -0- which is confidential and/or proprietary business information.