As a result, in late 1970, eight companies gathered in New York City . to launch the Asbestos Information Association of North America,' . ~ Page 3`~ Pfhv Asbestos?

ASBESTOS INFORMATION ASSOCIATION NORTH AMERICA 1660 L Street.

As to each ... such product, provide the information requested in the preceding Interrogatory.

., the trade association of North American manufacturers of man-made vitreous fibers.

The questions as stated request information going back many years.

Any information produced in response hereto is produced expressly subject to any objections contained herein and is produced without in any way waiving or intending to waive any objections that Answering Defendant may have with respect to the subsequent use of such information and specifically reserves a All questions as to admissibility of any and all such information in whole or in part or of the subject matter thereof b The right to object to the use of any such information in whole or in part or the subject matter covered thereby in any subsequent step or proceeding in this litigation and c The right to object to any and all grounds at any time to interrogatories or other discovery procedures involving or related to the subject matter of the information sought by plaintiffs 3 Answering defendant objects to each and every discovery request to the extent it seeks information that is equally available to or already in the possession of plaintiffs and the burden on plaintiffs to obtain the requested information is no greater than the burden on these defendants -2- BP_FR_00422969 4.

The questions as stated request information going back many years.

Page 2 September Krebs PhD 7 1971 2 Proposed and Existing Legislation I enclose a paper prepared by the Asbestos Information Association that discusses pending and proposed legislation as it relates to asbestos fiber Unfortunately we advised of recent asbestos do not offer developments a service that would keep you that might affect users of Please contact me if you require additional information Very truly yours ------ ----,--, menmen ------ ----,--, Edmund M.

Identifiable information on works managers is not maintained for plants no

The Secretary had earlier sent background information on Scan-Pac to all members.

Information Association/^orth America.

V/i.th reference to the products named in (1) state W'-ich oroouct3 are known to Defendant, or Defendant has rea- / son to oelieve contains parr.i clo-s or dust which, may cause fibrosis if inhaled in sufficient quantity and for each sues scats: (a) ''acts or information on -which Defendant's knowledge i1 0 3 J-- t- Z 'ii'tr O rill t^C (b) rime when those1 facts or inform ation were first available .

Identifiable information on works managers is not maintained for plants no

Milliara Barton Mheeling Brake Block Company George Stratton Asbestos Information Association Bob J.

Information Association Bob J.