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).

The Asbestos Information Association/North America reports that, during the past 30 years, the asbestos industry has spent millions of dollar

This interrogatory is overbroad and irrelevant in part insofar as it seeks information not specific to manufacture and/or sale of asbestos- containing products.

List any and all such sources of information relied upon, including, but not limited to, identifying any and all records or documents reviewed and persons providing information.

Chemical Manufacturers Association 5.

PDRC generally objects to the unlimited time frame associated with these requests.

upon written request from the EPA Pub11c Information Center (FM-215>,'401 M Street, S.W., .Washington, D.C. 20460 .* ' complicate `.enforcement procedures.

The interrogatories request information going back many years, and Garlock has found it difficult, if not impos sible, to reconstruct or retrieve much of the information requested.

List any and all such sources of information relied upon.

UBOW1TZ fit THOMAS A PROFESSIONAL ASSOCIATION FIFTH FLOOR 300 N.

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

Defendant supplies information about Haveg in the context of these lawsuits, to the best o f its current information and belief.

Attached is the information they have provided.

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).

UBOW1TZ fit THOMAS A PROFESSIONAL ASSOCIATION FIFTH FLOOR 300 N.