There is no asbestos discharge to water associated with manufacturing.

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

INTERROGATORY NO. 1: For each person who has supplied any information used in answering t

Gypsum to engage in unduly burdensome research, divulge privileged information and produce privileged documents.

George Wright reporting from all key government and scientific committees formation of AIA Sabourin flying around trying to get scientists to sign a statement that present asbestos levels are no problem Congressman R.

The Management Information System (MIS) section appended to the plan contains a compilation of AACPP policies and procedures along with current membership and committee rosters, meeting schedules and formats and, for designated recipients, pertinent financial information, i.e., budget, quarterly financial statement.

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

C 295 122 RESPONSES OF DEFENDANT GAF CORPORATION TO PLAINTIFF'S FIRST SET OF INTERROGATORIES 19 TO PLAINTIFF AND HIS ATTORNEY OF RECORD: 20 Pursuant to California Code of Civil Procedure Section 21 2030, defendant GAF CORPORATION (hereinafter "GAF") responds, 22 under oath, to plaintiff's First Set of Interrogatories as 23 follows: 24 // 25 // 26 // 27 // 28 // 11 INTERROGATORY NO. 2: 12 Please state the address of your principal place of 13 business and whether you have assumed the assets and/or 14 laibilities of any predecessor corporation or entity (such 15 predecessor corporations being limited to any association 16 whatsoever with the asbestos aspect of the defendant's 17 business).

Clement Associates, Inc. 1010 Wisconsin Avenue, N.W.

Based upon information provided to DuPont's counsel regarding Jose Alonzo Jr.'

r NOON & PRATT 7 1 asbestos fiber. 2 Q Does the mining and milling take place 3 .

A number of Plaintiffs' Discovery Requests seek information regarding "asbestos insulation products or "asbestos-containing materials."

As worded, this document request could reach information BSR\504545 -4- which is confidential and/or proprietary business information.

Based upon information and belief, no persons with personal knowledge of facts relating to many of the subjects regarding which plaintiffs seek information are currently in Orr Safety's employ.

I am sending along information on Regional Membership.