The contents of the information provided.

ASARCO objects to plaintiffs definition of "product containing asbestos fibers," "asbestos-containing products," "asbestos products," "asbestos" or "asbestos materials" on the grounds that it is overly broad, vague, ill-defined, and not susceptible to a precise response. 6.

Without waiving the foregoing objections, Defendant answers that it is impossible to know in an organization the size of this Defendant exactly what year it would have obtained this kind of information. 4 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).

As worded, this document request could reach information which is confidential and/or proprietary business information.

Without waiving the foregoing objections, Defendant answers that it is impossible to know in an organization the size of this Defendant exactly what year it would have obtained this kind of information. 4 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).

PREFACE The Notice of Deposition and its associated topics of testimony or areas of inquiry (Exhibit A) and requests for documents (Exhibit B) seek information and documents for a period of over 80 years.

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

The failure to limit this discovery to information related to Buffalo Pumps, Inc.'

Defendant objects to Plaintiffs definition of the words "trade organization" and "trade association" because it is overbroad and unduly burdensome.

As worded, this document request could reach information BSRA508611 -5- which is confidential and/or proprietary business information.

-V * m asbestos information association 1745 Jefferson Davis Highway, Crystal Square 4, Suite 509 Arlington, Virginia 22202 (703) 979-1150 January 25, 1983 Memorandum For: W.

PRELIMINARY STATEMENT Information provided in these responses is based upon such information as presently is reasonably available to DuPont, and DuPont expressly reserves the right, without imposing on DuPont any duty not required by the Texas Rules of Civil Procedure, to supplement these responses when and if additional information or documentation comes to its attention.

This search involves:,-:,,: Investigate risks associated with v..-_4~. th aggregate.

As worded, this document request could reach information which is confidential and/or proprietary business information.

WORKSHOP ON ASBESTOS: DEFINITIONS AND MEASUREMENTS METHODS July 18 T 20, 1977 GENERAL INFORMATION WELCOME!