This Defendant objects to these Interrogatories on the grounds that they call for information which is protected by the attorney-client privilege and work product doctrine. 2.

In fact, new information not referred to by OSHA strongly suggest that 2 or perhaps more fibers/cc is not associated with an excess incidence of pulmonary cancer.

Dept, of Commerce, Bureau of the Census, 1971) were assign ed to the employment information ascertained from medical histories, death certificates, and City Directories.

The form should be completed and returned by March 28 to the Asbestos Information Association (keep a copy for your files).

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

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.

Published by Oxford University Press on behalf of the Business History Conference All rights reserved For permissions please mail journals.permissions@oxfordjournals.org khm023 Advance Access publication May 29 2007 GEOFFREY TWEEDALE is reader in business history at Manchester Metropolitan University Contact information Manchester Metropolitan University Business School Aytoun Street Manchester M13GH M13GH U.K. mail G.Tweedale@mmu.ac.uk LAURIE FLYNN is a freelance writer and documentary film producer Contact information mail laurievincentflynn@mac.com This article draws on a large mass of business and legal papers that was generated by the Yandle and Adams litigation The papers have been deposited at Manchester Metropolitan University Business School and document citations in the text are from this source We are grateful to Nick Wikeley for advice in the writing of this article David Bricknell David Jeremy Clive Bishop Barry Castleman Steve Tombs and Jock McCulloch kindly offered comments and help at various times Two anonymous referees and editors Steven Tolliday and Kenneth Lipartito provided some final sharpening The responsibility for the text is our own 268 Piercing the Corporate Veil Corporations are typically organized according to the laws of limited liability and increasingly operate across national boundaries by means of subsidiaries A massive business literature has described this process and extolled the enormous material benefits that have ensued Business historians have made important contributions to this field indeed the writings of Alfred D.

Paustenbach and his authors omit this information despite having access to these discovery materials Limiting an analysis to published information is particularly inappropriate in this case since the brake manufacturers concealed knowledge and published misinformation about the risks of asbestos exposure Corporate documents reveal that the brake companies knew more about the risks to brake mechanics than did the medical and regulatory sectors This information includes speeches and minutes from meetings of the Friction Manufacturing Standards Institute FMSI and personal correspondence among company executives industrial hygiene consultants and representatives from industrysponsored asbestos research institutes Appendix 1 lists some of the documents omitted from Paustenbach et al.'

Despite the fact analysis.4 Finally, the industry subsidized an incom that these brakes are 40-70% asbestos, the brake man plete analysis of historical exposures to asbestos in ufacturers have vigorously denied that they contributed brake work.3 in any way to a single case of asbestos-caused disease.1 These companies have spent millions of dollars to The brake manufacturers have dismissed the fact that generate these epidemiologic studies in order to there is no known threshold of exposure associated refute claims of causation and thereby avoid com with mesothelioma (a rare cancer of the pleura or peri pensation payments to victims and their families.

It was also pointed out that the Asbestos Information Association (AIA) was referring the question of a captive to a consulting group, Tillinghast, Nelson and Warren of New York City.

Accordingly, Ford does not, and could not possibly, represent that its responses constitute all o f the information requested.

State the names of all industry or trade association periodicals to which you subscribed or which you received without subscription at any time from 1900 to the present giving the period of subscription or receipt of each ANSWER : Reddawaiys unable to identify any industry or trade association periodicals for the period in question 20 Identify by name and date all medical texts treatises journals studies c reports whether privately or publicly circulated which you received or obtained at any time from 1900 to the present and which concerned in any

It was also pointed out that the Asbestos Information Association (AIA) was referring the question of a captive to a consulting group, Tillinghast, Nelson and Warren of New York City.

N.W WASHINGTON, D C. 244-35- PLAINTIFF'S > EXHIBIT | FOR THE ASBESTOS INFORMATION ASSOCIATION SBCA 5051 } program ABC News Closeup STATION WJ LA-TV A8C Network DATE J u l y U , 1978 10:00 PM CITY Washington, O.C.

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.