FILE NAME International Nickel Corporation INC DATE 1995 DOC INC005 DOCUMENT DESCRIPTION INCO's Answers to Plaintiff's Interrogatories ANSWER INCO objects to this Interrogatory on the grounds that it broad unduly vague and not limited in time Without overly attached hereto is waiving objection a photocopy of a warning which is placed on asbestos- cWoensttaiVniirngginpiraoducts which are identified in the INCO plant in Huntington 23 Identify all documents in your possession regarding the health hazards of exposure to asbestos ANSWER INCO objects to this interrogatory on the grounds that it is overly broad unduly burdensome and goes beyond the scope of permissible discovery INCO has hundreds of employees and it has no way of determining whether individual employees have documents which may concern the health hazards of exposure to asbestos Without waiving this objection and specifically subject to it INCO has found the following documents which contain some information regarding asbestos a Occupational exposure to asbestos 1972 Department of Health Education and Welfare b Use in handling of asbestos textile products Asbestos Information Association C.

5 February 21, 19.84 c TO: ORC Asbestos Task Force .

Asbestos Information Association/North America jeexE&ooraoaxsKaeoc 1660 l street, n. w.

For your information, as a result of an investigative report exposing the "hazards" associated with buffing asbestos containing vinyl floor tiles, OSHA is anticipating a possible swell of criticism and questions regarding the adequacy of the asbestos standard and possibly pressure to lower the action level and the PEL.

The Asbestos Information Association/North America reports that, during the past 30 years, the asbestos industry has spent millions of dollars to improve mining, milling, and manufacturing methods (8).

FILE NAME Kaiser Gypsum KG DATE 1974 Mar DOC KG003 DOCUMENT DESCRIPTION Internal Manville Report - A Condensation of Environmental Facts on Asbestos and Health Presented at Customer Seminars ENVIRONMENTAL FACTS Asbestos kalnia ManvilleManville JJMM A Condensation of Environmental Facts On ASBESTOS and HEALTH Presented at a Series of Customer Seminars by MANVILLE CORPORATION PRODUCED JM - 83 For further information on this subject please contact Environmental Affairs Department Manville Greenwood Plaza Denver CO 80217 @ za, th 7 Rie ade cen: * TABLE OF CONTENTS { @ a , fi . i; \ Introduction to Asbestos and Health 2.0.0.0... eeecseeessssereeeetesssneensccensereneasoeesseeeeoneeeenees 1 Overview svotereneasessonseaescsacesenses 1 The Health Problem 1 Medical Aspects 2 Built Dust Defenses aes ceneeeceeeserees 2 Asbestos Diseases 3 Biological Reactions Asbestosis 4 Lung Cancer and Mesothelioma Leseceeeccesceceeeeeonsentenceesceeesensens 5 Fiber Differences Play Key ......... sosecccecsceeeccsseceetessseseuessesecseesneces 5 Dosage Standards 7 Dust Control How Effective 8 Smoking and Asbestos 9 Locked and Locked 10 OSHA Standards for Occupational Exposure to Asbestos sasasassenencsscessacetscscsesesssecscsussssseseseseaesesesesesesesesesecereeteeeneosse 11 12 Standards MonitoringVesccscessescescseocacsseceseoesesenesscnessessenssceseseeeeeeessssassaveraes 12 Methods of Compliance 12 Medical Requirements 13 13 Labeling EPA Standards for Airborne Asbestos .

That is the period in which we find ourselves now with asbestos fiber.

CHESTERTON INC et al ) \ Defendant ) ECEIVE ECEIVE ECEIVE 2012 , PACCAR INC'S ANSWER TO PLAINTIFFS MANUFACTURER INTERROGATORIES DIRECTED TO DEFENDANT Defendant PACCAR Inc hereinafter PACCAR by and through its attorneys Segal McCambridge Signer & Mahoney Ltd. and for its Answers to Plaintiffs Manufacturer Interrogatories Directed to Defendant states as follows PRELIMINARY STATEMENT These responses are provided only for those products to which Plaintiff has alleged exposure These responses are based on an ongoing review of PACCAR's documents and information obtained from ongoing discussions with various PACCAR personnel Much of the information requested dates back many years and is difficult or impossible to reconstruct or retrieve Therefore PACCAR reserves the right to amend these responses if more information becomes available PACCAR prepared these responses with the assistance of counsel No single employee officer or agent of PACCAR has hand knowledge regarding each and every response The person signing these responses does so to satisfy whatever requirements may exist under the applicable rules regarding verification That person is informed and believes that the information known as of the date of his signature supports the responses below DEFINITIONS Plaintiff's Definitions are not repeated herein for the sake of brevity PACCAR objects to those Definitions as overly broad vague and confusing as drafted PACCAR further objects to Plaintiff's Definitions in that they include meanings and characterizations inconsistent with PACCAR's interpretation of the defined terms and phrases GENERAL OBJECTIONS PACCAR objects to Plaintiff's Interrogatories to the extent that they seek corporate knowledge as it is impossible for PACCAR to set forth the collective knowledge of all of its past or present employees PACCAR reserves the right to revise correct supplement and amend its responses to provide information discovered subsequent to the answers contained herein PACCAR asserts the following objections and incorporates each by reference into each and every response to Plaintiff's Interrogatories set forth herein a PACCAR asserts the right tto o object on the grounds of competency privilege relevancy materiality or any other proper ground to the use of any said responses for any purpose in whole or in part in any subsequent step or proceeding in this litigation b PACCAR asserts the right to object on any other ground to other Interrogatories or other discovery procedures involving or relating to the subject matter of the Interrogatories answered herein c PACCAR asserts the right to revise correct supplement or clarify any of the responses or objections set forth herein at any time and PACCAR reserves the right to object to the use of these responses at trial or any other proceeding as deemed necessary and appropriate by PACCAR d PACCAR objects to the Plaintiff's Interrogatories to the extent that they involve matters outside of the geographical area at issue in this litigation and limits its responses to said area e Furthermore these Interrogatories ask PACCAR to disclose information of which may no longer exist or may not be readily available is unrelated to the products which Plaintiff alleges exposure to in this litigation and information which is also unrelated to the locations at which any PACCAR product was allegedly used the conditions under which the products were allegedly used the time period during which any PACCAR product was allegedly in use at any alleged work sites or the time periods during which exposure to a PACCAR product allegedly occurred Thus these Interrogatories seek information which is neither material nor relevant to the issues in this litigation are overly broad in time scope and location and are otherwise not reasonably calculated to lead to the discovery of admissible evidence f These Interrogatories are oppressive and burdensome and would require PACCAR to undertake a massive and extraordinary document search the results of which would have little to no demonstrable bearing on this litigation in light of the alleged exposure Moreover many of these Interrogatories are not susceptible to a response because they request information which dates back many years and is now virtually impossible for PACCAR to reconstruct or retrieve in its entirety g PACCAR objects to these Interrogatories because they were propounded to harass and coerce a settlement despite the lack or complete absence of verifiable product identification and the lack of evidence of injury as a result of alleged exposure to or use of any product which PACCAR may or may not have manufactured h PACCAR objects to these Interrogatories because they are propounded for an additional improper purpose namely as a fishing expedition for the purposes of obtaining information that may be taken out of context by Plaintiff's counsel to create allegations against PACCAR where none may legitimately exist ) PACCAR objects to these Interrogatories as overly broad in that they seek information from entities other than itself or its predecessors PACCAR over the course of its long history has owned several businesses which are not involved in the instant litigation Therefore all references in these Interrogatories to YOU YOUR COMPANY and THIS DEFENDANT are assumed to refer only to PACCAR's unincorporated truck divisions Kenworth Truck Company and Peterbilt Motors Company ( PACCAR objects to each and every Interrogatory that seeks production of any information constituting a trade secret confidential financial data or other confidential research development or commercial information k PACCAR objects on the basis that these Interrogatories are argumentative because they assume that a health hazard is created by the PACCAR products that may have incorporated containing component parts which PACCAR denies 1 PACCAR objects to these Interrogatories on the basis that they are vague and ambiguous The Interrogatories relating to certain diseases fail to provide facts relating to the amount of exposure duration of exposure fiber type in exposure and latency period m PACCAR objects to these Interrogatories in that they tend to group together all of the defendants in this litigation and are therefore overly broad unduly burdensome harassing and not calculated to lead to the discovery of relevant and material evidence n PACCAR objects to each and every Interrogatory that calls for either pure speculation or legal conclusions on the part of PACCAR for its answers o PACCAR objects to these Interrogatories to the extent that they call for a medical conclusion beyond the scope of PACCAR's knowledge and capability p PACCAR objects to each and every Interrogatory that purports to impose any obligations on it that are not set forth in the Missouri Rules of Civil Procedure q PACCAR objects to these Interrogatories to the extent that they seek information protected by the attorney client privilege or attorney work product doctrine \ r PACCAR objects to these Interrogatories to the extent that they seek disclosure of information generated by persons other than PACCAR that has come into the possession of PACCAR's counsel during the course of discovery and trial preparation in asbestos litigation s PACCAR objects to these Interrogatories to the extent that they seek information for any period subsequent to Bert Dobson's alleged exposure t PACCAR objects to these Interrogatories to the extent that they seek information that is not under PACCAR's custody or control or which is within the public domain or otherwise equally available to Plaintiff as it is to PACCAR Without waiving any of the foregoing objections PACCAR states as follows PACCAR'S ANSWERS TO INTERROGATORIES INTERROGATORY NO 1 Describe the manner in which the information used to answer these interrogatories was collected by identifying any and all such sources of information relied upon including records or documents reviewed records or documents determined to have been destroyed document retention policies persons providing information and overseeing the process and the person verifying the answers ANSWER PACCAR objects this Interrogatory is overly broad not limited in scope vague and confusing as drafted PACCAR further objects to the extent that this Interrogatory seeks information protected by the attorney privilege the attorney work product doctrine and the consulting expert privilege Subject to and without waiving objection Rod Curbo Product Safety and Compliance Manager for Peterbilt Motors Company has verified these answers and has supplied responsive information Mr.

., was exposed to any asbestos and/or asbestos-containing products at its El Paso facility.

Rosenberg of the Borg-Warner Research Center has attended meetings of the Asbestos Information Association.

Defendant objects to plaintiffs interrogatories to the extent that they seek information that is not within the personal knowledge of defendant's current employees.

to health, and asbestos is no exception.

It was felt that the information here incriminated asbestos unjustifiably as a carcinogenic material and it was felt some clarification of this subject should be extended.

The Interrogatories as stated, request information going back many years.

^ A Condensation of Environmental Facts On ASBESTOS and HEALTH Presented at a Series of Customer Seminars by 0 JOHNS-MANVILLE CORPORATION PRODUCED JM -83 t i I V \ * For further information on this subject please contact: Environmental Affairs Department Johns-Manville Greenwood Plaza Denver, CO 80217 PRODUCED JM-83 * * TABLE OF CONTENTS Introduction to Asbestos and Health.................................................................................... 1 Overview....;.....................................................................................................