Plaintiffs' use of the term "asbestos-containing product" incorporates an assumed release of asbestos dust and asbestos fibers in the use of a product.

Consequently, this section emphasizes the production processes and emissions associated with brake linings, placing lesser emphasis on other products in the friction . materials group. 82 TABLE 19.

Any omissions of such information are unintentional.

Testimony will be presented by several companies and the Asbestos Information Association.

Defendant did not manufacture any asbestos-containing products and therefore did not publish any documents associated with any asbestos-containing product.

No information as to weight of asbestos content is in this Defendan

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

Defendant KELLY-MOORE also objects to these ; 24 Interrogatories to the extent they call for information protected 25 by the attorney-client privilege, or the attorney work-product , 26 doctrine, or any other applicableprivilege. 1 27 6.

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.

(e) Defendant Maremont does not know the chemical composition of each such asbestos-containing product; however, Grizzly products collectively contained the following ingredients: Asbestos, 5R,Asbestos, 6D; Asbestos, 7D; Asbestos, 7M; Asbestos, 8T; Barium Ferrite; Barytes, Bleached and Unbleached; Carbon, Black; Cashew Particles; Cas

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.

RESPONSE: Hercules objects to this interrogatory as vague and confusing because it is unclear whether this interrogatory seeks information concerning the raw asbestos fibers which Hercules purchased from J-M Canada and Carey Canada or whether it seeks information concerning products sold by Hercules.

This booklet is published by the Asbestos Information Association and is a good reference for specific procedures involving the different types of operations involved in the construction process.

Such information will not be disclosed herein.

To the best of my present knowledge, information and belief, I certify that these records were made at or near the time by, or from information transmitted by, a person with knowledge, were kept in the course ofthe regularly conducted business activity ofManville, and it was the regular practice and the business activity ofManville to make the records.