In responding to these 18 interrogatories, responding party has provided such information as is presently available.

These responses 28 3- - 1 are based on the most current information. 2 0.

Gibbs may testify generally as to the dangers posed by the inhalation of asbestos fibers, the relative risks associated with exposure to low levels of airborne asbestos dust in the general environment, and the risks posed to Plaintiff from his alleged exposure to airborne asbestos dust.

PLAINTIFF'S .

The number of each question and its subpart for which such personnel provided information; b.

Additionally, Ford in its own ongoing searches for information which may be relevant to asbestos litigation has accumulated approximately 20,000 pages of non-privileged documents.

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 6- - or interests, and/or learning information or facts of interest to the various members of the organization or association. 13.

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

It is evidence of prolonged exposure to asbestos but is not necessarily associated with symptoms of ill-health.

Gaburo D Information Center 4 Sen eran fen PRODUCED JM PRODUCED SM Manville Research and Development Center AIA Tech Tech Memorandum M411-821 Date October 16 1978 TRIP REPORT - DANSK ETERNIT FISKER AND NIELSON GERMAN ETERNIT INTERNATIONAL ASSOCIATION ASBESTOS INFORMATION CENTER ASBESTOS and PANELS LIMITED WEMBLEY ROOFING COMPANY UK and CAPE 30ARDS The was the of this trio by D.

I'-irchollo Cattando Mornr AnJjonfcos Information Association/ North America ."

AIA Brochure CONSPIRACY ADMISSIONS ( No Date (early 1970s) - Formed in December 1970. - Headquarters at 22 East 40th St., New York, New York (JM World Headquarters) - The INDUSTRY lacked a single, constantly available source . . . to provide information. - To provide INDUSTRY-WIDE information on asbestos and health . . - To EXCHANGE INFORMATION on methods and techniques of asbestos dust control. - To publicize the unique benefits and importance of asbestos to protecting human life and property - Keep THE INDUSTRY fully aware of all new developments whether medical, governmental or technical, concerning asbestos health. - "Maintains a close working relationship with other ASBESTOS INDUSTRY groups, including the Asbestos Textile Institute, Asbestos Cement Products Assocation, Friction Materials Standards Institute, the British Asbestos Information Committee and Asbestos Research Council and similar groups in France, the Benelux countries, and Scandanavia. - Members listed, currently viable members include CAPCO, Certain-teed, Union Carbide. - 1/000008 - UCC_01_Cull\AIA_Formation_UCC000008-000010.pdf 18.

Accordingly, Ford does not, 3 and could not possibly, represent that its responses constitute all 4 of the information requested.

Union 21 Carbide's answers to these interrogatories are based on information known to Union Carbide at 22 this time.

Also provide historical information regarding all predecessors, prior names, asset purchases, acquisitions or spin-offs for all associated business entities that were involved, in any manner, in the sale, manufacture, distribution, and/or mining of asbestos and/or asbestos containing products.