-To the best of my knowledge, and I am quite certain of this, they did not do fiber counting analysis on any samples collected to measure personal exposures to asbestos.

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.

ASARCO objects to Plaintiffs definition of "trade organization" and "trade association" on the ground that it is overly broad, vague, ill-defined and not susceptible to a precise response. 10.

Dow objects to paragraph twelve (12) of the DEFINITIONS section to the extent the information sought concerns asbestos in a non-friable form.

Amerioan Junketing Association Sales Dept.

The words "trade organization," or "trade association" mean any oiganizations or associations of business or industrial entities that are associated and/or meet for the purpose of achieving common goals and/or exchanging information related to common needs or interests, and/or learning information or facts of interest to the various members of the organization or association. 13.

In the spirit of discovery, however, Chrysler provides information herein.

Dow objects to paragraph twelve (12) of the DEFINITIONS section to the extent the information sought concerns asbestos in a non-friable form.

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

Other information reasonably requested 2.

2i a0 il 2!

Langer PAGE 14 55 98 116 116 163 17 18 19 REQUESTS FOR INFORMATION PAGE 20 Electron micrograph data sheets 123 21 Air sampling for work sites 139 22 23 24 25 PRIORITY-ONE COURT REPORTING SERVICES (718) 761-0527 5 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 DK.

The data presented provide EPA with information on the likelihood of fiber release from selected asbestos products.

I 1 0 : 0 1 0 9 :3:: '' :41)0 : 0 1 l l ~ '-' am a video specialist with Maggard Associates whose principal place of 1 0 : 0 1 1 J :SJ C ,,1 0 0 1 1 :6J L' business is Albany, New York.

I 19 have an Associate's degree from Finger Lakes 20 Community College, and I have a Bachelor's 21 degree from Roberts Wesleyan. 22 Q- I'm going to mark as the first exhibit 23 this document. 24 (Whereupon, Heffron Exhibit 1, a CV, 25 was then received and marked for Alderson Reporting Company, Inc. 111114th Street, N.W.