This information is disclosed only within GM on a needto-know basis.

PRELIMINARY MATTERS The Fund objects to these Interrogatories to the extent that they ask for information relating to the Defendant's involvement in the asbestos industry.

Pierson (0023505) BUCKINGHAM, DOOLITTLE & BURROUGHS A Legal Professional Association P.O.

., and answers the Interrogatories propounded to it by plaintiffs as follows: General Objection Defendant objects to the extent that the discovery seeks information regarding asbestos product manufacture, design, composition, or similar information which is more properly directed i toward asbestos product manufacturers.

Asbestos Information Association (AIA) (please answer through date of your 2 answers); 3 G.

GAF objects to these Requests to the extent that they seek to require it to reveal trade secrets or other confidential product or commercial information.

William Roberts, Jr. & Associates, 11 Charleston, SC 12 Joseph H.

Much of the information is sought from many years ago and is, therefore, difficult or impossible to reconstruct or retrieve.

While the manufacturing firms themselves will participate in the state's October hearing, the Asbestos Cement Pipe Producers Association won't be allowed to by the state, said association Director of Public Af fairs John Welch.

This request includes, but is not limited to, information concerning membership in the Asbestos Information Association (A.I.A.), the Asbestos Textile Institute (A.T.I.), the National Safety Council (N.S.C.), the Industrial Hygiene Foundation (I.H.F.), and/or the Mellon Institute.

PRELIMINARY MATTERS The Fund objects to these Interrogatories to the extent that they ask for information relating to the Defendant's involvement in the asbestos industry.

While the ANPRM purports to seek information to evaluate asbestos, it is abundantly clear in reading the ANPRM, plus the public statements U 2J attributed to EPA scientists and U J.

AIA-94 Death of the Asbestos Matthew M.

These interrogatories seek information about events that occurred many years ago.

Chandler...........................................................................13 7 Witness' Signature Page.................................................................................333 8 Reporter's Certificate.................................................................................... 334 9 REQUESTED DOCUMENTS/INFORMATION 10 Number Description Pg/Ln 11 (None) 12 CERTIFIED QUESTIONS 13 Number Pg/Ln 14 Certified Question 1 31/9 15 EXHIBIT INDEX 16 Exhibit No.