Therefore, some information may be incomplete, no longer available, or not within PPG's possession or control.

Defendant KELLY-MOORE objects on the grounds these 4 5 Interrogatories are overly broad as to time and scope, are 6 burdensome, and are not reasonably calculated to lead to 7 discovery of admissible evidence, as the interrogatories seek 8 information that covers a time period of 60 years and request 9 Defendant to assimilate documents and information that may or may 10 i not have been retained over such a period of time. 11 2.

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

The information provided in these answers to requests and interrogatories is based upon such information as is presently available to Abex, and Abex expressly reserves the right to supplement or amend these answers when and if additional relevant information or documentation is discovered.

Beazer East objects to each interrogatory to the extent that the request seeks information unrelated to any of the plaintiffs in the Butler County, Ohio, asbestos litigation, in that such a request is overbroad, and the information sought is not reasonably calculated to lead to the discovery of admissible evidence. 4.

Copies of these comments and testimony are sent as a matter of information.

If responsive information can be located.

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

I am not certain about my future as a member of the MAP at the present time and will not know until mid-March whether I will continue to represent the Asbestos Information Association of North America or not.

Wagner's widely publicized association of mesothelioma with Cape Crocidolite asbestos exposure created the potential for the introduction of diagnostic bias (Wagner, i960 ).

Substitutes Table 3 summarizes the primary substitutes for asbestos siding and roofing shingles There are no substitutes for asbestos shingles in the maintenance and repair market because there are no substitute products that resemble the asbestos product closely enough to be able to replace it in parts National Roofing Contractor's Association 1986 Supradur 1986b Slate is the only shingle that would be close in appearance to some asbestos shingles but it is much thicker and far more expensive Supradur 1986b For our study we will consider substitutes that can be used instead of asbestos shingles for complete remodeling or new construction The following section presents separate discussions of substitutes for asbestos siding shingles and asbestos roofing shingles 1.

I am not certain about my future as a member of the MAP at the present time and will not know until mid-March whether I will continue to represent the Asbestos Information Association of North America or not.

The information provided in these answers to requests and interrogatories is based upon such information as is presently available to Abex, and Abex expressly reserves the right to supplement or amend these answers when and if additional relevant information or documentation is discovered.

If so, identify the document containing such information by date and location.

Product information 3.