q- state during what period of time such product has been associated with Defendant; ANSWER: J.

DuPont's responses were prepared by counsel based upon information received from a

F oil, Dlreclor, Office of Information arid Consumer Affaire.

Rockbestos objects to any and all interrogatories insofar as they seek information outside the time period during which Plaintiff is alleged to have worked or inquire about diseases other than allegedly asbestos related diseases on the grounds that they are overly broad and unduly burdensome, and seek information that is neither relevant to any issue in this case, nor reasonably calculated to lead to the discovery of admissible evidence. 7- - 11.

Product Information 3.

It's the Asbestos Hazards Emergency Response 5 Act, and for clearance of school buildings after removal of 6 asbestos the U.S.

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 BSRY510241 -5- which is confidential and/or proprietary business information.

(f) Information sought in this Interrogatory is available in this defendant's annual reports.

Much of the--' information requested date back many years and thus, it is difficult if not impossible to reconstruct or retrieve this information.

Product Information 3.

Asbestos Information Association/North America (1972- 24 1984); Resilient Floor Covering Institute (December, 25 1975, through September, 1980, and February, , 1987 26 through the present). / / 27 B.

As worded, this document request could reach information BSRA5045551 -4- which is confidential and/or proprietary business information.

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

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