(asbestos users from the St.

Met Life prepared its own report of the Canadian studies which included dust study 7 information as well entitled Effects of the Inhalation of Asbestos Dust Upon the Lungs of Asbestos 8 Workers Canadian Study Exhibit 11.

Associate General Counsel and Assistant Secretary.

This information was transmitted to Wyatt McCallie (Johns-Manville) on or about August 4,1931.

Subject thereto: American Gas Association.

Hercules had no relationship of any kind with the Haveg Plant or any asbestos at that plant prior to 1964.

No. 96C-07-226 ) (Asbestos) HERCULES, INCORPORATED, ) et al

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.

SUPPLEMENTARY INFORMATION: I.

Hennessy cannot exclude the possibility that its continued investigation may at some time reveal more complete information or even information which indicates an answer now supplied is incorrect, Hennessy, therefore, reserves the right to use and rely upon subsequently discovered facts, information and/or legal theories.

Graybar objects to these interrogatories to the extent that they seek confidential or 9 trade secret information or materials. . 10 6.

If any piece of equipment which was used at any time to install, cut, shape, etc. products identified in answer to interrogatory no. 1 or 7(b) was invented, -7- developed or first made by answering defendant or any person associated with you or any related company or association, state: (a) When it was invented, developed or made (including changes or improvements to previously available equipment); (b) The identity of each individual who participated therein and describe in detail the extent of his participation; (c) The identity of each document which reflects, refers or relates to any information set forth in answer to this interrogatory.

Defendant KELLY-MOORE also objects to these 17 Interrogatories to the extent they call for information protected 18 by the attorney-client privilege or the attorney work-product 19 doctrine. 20 4.

EVER SELL ASBESTOS 5.

INTERROGATORY NO. 3: Please list all trade organizations, trade associations and any other industry-wide groups to which you belong(ed) (specifically including but not limited to the following groups: American Hygiene Foundation, Industrial Hygiene Foundation, Chemical Manufacturer's Association, American Chemical Council, American Petroleum Institute, Texas Chemical Council, Ohio Safety Congress, National Safety Council, Asbestos Information Association, Industrial Medical Association) in which information or documents relating to asbestos was discussed, disseminated, or published (including, but not limited to, the effects of exposure to asbestos, industrial hygiene measures relating to asbestos dust, and medical information or research relating to asbestos or its effects on animals or humans, populations at risk).