As worded, this document request could reach information BSR\504531 -4- which is confidential and/or proprietary business information.

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 which is confidential and/or proprietary business information.

As worded, this document request could reach information BSRV504537 -4- which is confidential and/or proprietary business information.

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).

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.

If not, state the correct legal name of the defendant and provide the ^information requested in No. 3 above concerning the defendant as correctly names.

WORKSHOP ON ASBESTOS: DEFINITIONS AND MEASUREMENTS METHODS July 18 -20, 1977 GENERAL INFORMATION ..

See instruction 12, page 6, for definition of the terms "asbestos .: or asbestos product".

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

Also provide historical information regarding all predecessors, prior names, asset purchases, acquisitions or spin-offs for all associated business entities that were involved, in an

As worded, this document request could reach information BSR\507129 -4- 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).

Have you ever studied asbestos?

Westinghouse further objects to this interrogatory to the extent it calls for information protected by the attorney/client privilege or attorney work product doctrine.