(g) any indemnity and insuring agreements described in Rule 192.3(f); RESPONSE: Since Plaintiff has provided insufficient work history information, Defendant is unable to specify at this time the insurance policies which may be applicable.

Subject to these objections, Dow asserts it is unable to pinpoint a precise date on which it, as a corporate entity, affirmatively knew of an association between asbestos exposure and disease as medical and scientific literature regarding asbestos related disease developed gradually over time.

Asbestos manufacturers or insulation contractors, not Defendant, supplied the asbestos-containing products used on Monsanto's premises.

(g) any indemnity and insuring agreements described in Rule 192.3(f); RESPONSE: Since Plaintiff has provided insufficient work history information, Defendant is unable to specify at this time the insurance policies which may be applicable.

Defendant objects to the terms "trade organization" and "trade association" as vague, overlybroad, unduly burdensome and not calculated to lead to the discovery of admissible information. 7.

Therefore, Crane Co. has no information responsive to this Interrogatory.

The person does not, however, have direct knowledge regarding any specific answer, but is informed that the review of the documents and discussions referred to above support the answers based upon the information available as to the date of signature.

(g) any indemnity and insuring agreements described in Rule 192.3(f); RESPONSE: Since Plaintiff has provided insufficient work history information, Defendant is unable to specify at this time the insurance policies which may be applicable.

Therefore, Crane Co. has no information responsive to this Interrogatory.

If so, identify the document containing such information by date and location.

The person does not, however, have direct knowledge regarding any specific answer, but is informed that the review of the documents and discussions referred to above support the answers based upon the information available as to the date of signature.

Subject to these objections, Dow asserts it is unable to pinpoint a precise date on which it, as a corporate entity, affirmatively knew of an association between asbestos exposure and disease as medical and scientific literature regarding asbestos related disease developed gradually over time.

(reprint from Water Engineering & Management magazine) "A/C Pipe and Drinking Water" (A/C Pipe Producers Association booklet) Specifications (back pocket) AWWA C-400-80: Asbestos Cement Distribution Pipe, 4 In.

SUMMON* IN A CIVIL ACTION

The person does not, however, have direct knowledge regarding any specific answer, but is informed that the review of the documents and discussions referred to above support the answers based upon the information available as to the date of signature.