No additional information has been given, such as the time period of Mr.

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.

REQUESTS FOR PRODUCTION -- PAGE 1 022S5 C3253 LIT 21SCI 1985; (b) information or documents acquired by or known to employees of the Automotive Sector of Allied Corporation from April l, 1985 through September 29, 1987; and (c) information or documents acquired by or known to employees of the Automotive Sector of AlliedSignal Inc. since September 30, 1987.

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

Congoleum was a member of the Asbestos Information Association/North America from 1972 through 1984.

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.

It is not possible to list each and every document which was involved in the compilation of this information. 2.

Chemical Manufacturers Association 5.

" ; For its "excellent performance in The district mechanics are mem- protecting district mechanics bers of the International Association from a cancer-causing substance, of Machinists & Aerospace Workers | ; asbestos in fiber form," California's (1AM), Marin County Lodge No. 238.

If not by 1985, when, ifever, did you become aware of information or foots concerning any reported association between exposure to asbestos or asbestos products and the health effects listed above?

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

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. -6- 13.

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

FMSI 04284 Minutes of the Board of Directors Meeting 4 June 14, 1988 Upon motion duly made, seconded and unanimously passed, it was: RESOLVED: That effective July 1, 1988 the annual fee for Regional Members (Regular) would be $1,600; Regional Member (Association) $2,600; Licensee: $600.