.N-lO mCC 930970 Monsanto fftOM (NAM| 4 lOCATION| J.

J.

,, -CC Monsanto nocAtxxi J. a.

M>IO mcc noic Monsanto wo- t iOCAnoM) DAT1 SUtJCO wwnci TO PLAINTIFF'S EXHIBIT E.P.

r M'Q CC *90970 Monsanto W.FtO {NAM( 4 LOCATION!

INTERROGATORY NO. 38: Identify any and all facilities at which Defendant, any predecessor or any related company, at any time, manufactured or processed asbestos-containing products, or processed raw asbestos.

To the extent that any of the documents that plaintiffs decide to inspect were prepared in anticipation of litigation or for trial or are otherwise covered by the work-product doctrine, or are protected from disclosure by the attorney-client privilege, Abex objects and will not make such documents available to plaintiffs.

1952-1955 1955-1966 1955-1960 D.

INTERROGATORY NO. 53: If your answer to any subpart of Interrogatory No. 52 is "Yes,": (a) Identify the library(ies) involved and state the years during which Defendant, its predecessor or related company was a member of, or otherwise had use of or access to said library; and (b) If applicable, identify the organization or association through which Defendant, its predecessor or related company, obtained the use of or access to, such library(ies).

Abex also objects to this interrogatory on the grounds that the information and/or documents requested are subject to confidentiality agreements and/or Court issued Protective Orders.

1 A Yes.

1 products consult with medical and industrial hygiene Page 262 2 professionals to make sure that hazardous materials 3 that are incorporated into those products don't pose a 4 safety risk?

ClaH Part No.

i&V-'-C- - '-hi- ':i BRfltCE bRUMS (Cont ) . 3 WHEREVER TWO DIFFERENT NUMBERED BOLTS AND NUTS ARE SHOWN FOR AN APPLICATION THE TOP LISTINGS ARE THE RIGHT HAND THREADS, Car & Year Models Front Drums Front Bolt Front Rear O Nut a Drums Rear i x Rear Bolt o Nut O FAIRLANE (Cont.) 1966 All Models 54, 62, 63 w/8 Cvl. 390 Eng. 1962-65 All w/10" x 2" H.D.

**C's>.0 Monsanto Mo*inami*looTiONt J* T Payne, (SS--18), Texas City, Tgxss ur!