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).

q- state during what period of time such product has been associated with Defendant; ANSWER: J.

Rockbestos objects to any and all interrogatories insofar as they seek information outside the time period during which Plaintiff is alleged to have worked or inquire about diseases other than allegedly asbestos related diseases on the grounds that they are overly broad and unduly burdensome, and seek information that is neither relevant to any issue in this case, nor reasonably calculated to lead to the discovery of admissible evidence. 7- - 11.

Product Information 3.

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).

As worded, this document request could reach information BSRY510241 -5- which is confidential and/or proprietary business information.

As worded, this document request could reach information BSRA5045551 -4- which is confidential and/or proprietary business information.

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

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.

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.

ASARCO objects to plaintiffs definition of "product containing asbestos fibers," "asbestos-containing products," "asbestos products," "asbestos" or "asbestos materials" on the grounds that it is overly broad, vague, ill-defined, and not susceptible to a precise response. 6.

To provide such information would require a nationwide search unlimited by time, location, or type of information, and is thus over broad and unduly burdensome, III.

As worded, this document request could reach information BSRA505298 -4- which is confidential and/or proprietary business information.

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.

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).