Atlantic Richfield Company reserves the right to amend or modify these responses in light of subsequently obtained information.

for definition of the terms "asbestos or asbestos product".

P. 193.3, you are hereby advised that material or information which may be responsive is privileged, and has been withheld from this response on that basis.

Therefore, some information may be incomplete or no 3 longer available due to the passage of time.

W V 9 f W W i f , l l | i i PUjiwupB Um An Information Resource U.S.

In 1983 the Truck Trailer Brake Research Group (TTBRG) was formed by the American Trucking Associations (ATA), Motor Vehicle Manufacturers Association (MVMA) and the Truck Trailer Manufacturers Association (TTMA).

Subject to these objections, Dow asserts it is unable to pinpoint a precise date on which it, as a corporate entity, affirmatively knew of an association between asbestos exposure and disease as medical and scientific literature regarding asbestos related disease developed gradually over time.

The person does not, however, have direct knowledge regarding any specific answer, but is informed that the review ofthe documents and discussions referred to above support the answers based upon the information available as to the date of signature.

(g) any indemnity and insuring agreements described in Rule 192.3(f); RESPONSE: Since Plaintiff has provided insufficient work history information, Defendant is unable to specify at this time the insurance policies which may be applicable.

Asbestos manufacturers or insulation contractors, not Defendant, supplied the asbestos-containing products used on Monsanto's premises.

(g) any indemnity and insuring agreements described in Rule 192.3(f); RESPONSE: Since Plaintiff has provided insufficient work history information, Defendant is unable to specify at this time the insurance policies which may be applicable.

Defendant objects to the terms "trade organization" and "trade association" as vague, overlybroad, unduly burdensome and not calculated to lead to the discovery of admissible information. 7.

The person does not, however, have direct knowledge regarding any specific answer, but is informed that the review of the documents and discussions referred to above support the answers based upon the information available as to the date of signature.

(g) any indemnity and insuring agreements described in Rule 192.3(f); RESPONSE: Since Plaintiff has provided insufficient work history information, Defendant is unable to specify at this time the insurance policies which may be applicable.

The person does not, however, have direct knowledge regarding any specific answer, but is informed that the review of the documents and discussions referred to above support the answers based upon the information available as to the date of signature.