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.

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

FMSI 04284 Minutes of the Board of Directors Meeting 4 June 14, 1988 Upon motion duly made, seconded and unanimously passed, it was: RESOLVED: That effective July 1, 1988 the annual fee for Regional Members (Regular) would be $1,600; Regional Member (Association) $2,600; Licensee: $600.

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

The Management Information System (MIS) section appended to the plan contains a compilation of AACPP policies and procedures along with current membership and committee rosters, meeting schedules and formats and, for designated recipients, pertinent financial information, i.e., budget, quarterly financial statement.

C 295 122 RESPONSES OF DEFENDANT GAF CORPORATION TO PLAINTIFF'S FIRST SET OF INTERROGATORIES 19 TO PLAINTIFF AND HIS ATTORNEY OF RECORD: 20 Pursuant to California Code of Civil Procedure Section 21 2030, defendant GAF CORPORATION (hereinafter "GAF") responds, 22 under oath, to plaintiff's First Set of Interrogatories as 23 follows: 24 // 25 // 26 // 27 // 28 // 11 INTERROGATORY NO. 2: 12 Please state the address of your principal place of 13 business and whether you have assumed the assets and/or 14 laibilities of any predecessor corporation or entity (such 15 predecessor corporations being limited to any association 16 whatsoever with the asbestos aspect of the defendant's 17 business).

As worded, this document request could reach information BSR\504545 -4- which is confidential and/or proprietary business information.

Based upon information and belief, no persons with personal knowledge of facts relating to many of the subjects regarding which plaintiffs seek information are currently in Orr Safety's employ.

I am sending along information on Regional Membership.

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).

List any and all such sources of information relied upon, including, but not limited to, identifying any and all records or documents reviewed and persons providing information.

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

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

If not by 1985, when, if ever, did you become aware of information or facts concerning any reported association between exposure to asbestos or asbestos products and the health effects listed above?

Attached is the information they have provided.