In connection with the incidence of lead poisoning amongst the operators, Abadan state than during the hottest months of 1944, high lead spirit was filled infrequently and this was probably the greatest single factor in preventing lead poisoning last year.

, 71,96 Advertisement, Dutch Boy White Lead (National Magazine) .............................................. 12DP, 47, 74 Advertisement, Dutch Boy White Lead, Oils and Colors....................84, 85 Advertisement, Dutch Boy White Lead Paint ......................................... 72 Advertisement for D.

JOSEPH LEAD COMPANY.

"Pacific Acadian September 2005 Date Sampled: j j ate jjecejve(j. 09-30-2005 Product: Method EP 04/2005:0438 talc EP 04/2005:0438 talc EP 04/2005:0438 talc EP 04/2005:0438 talc EP 04/2005:0438 talc EP 04/2005:0438 talc EP 04/2005:0438 talc EP 04/2005:0438 talc EP 04/2005:0438 talc EP 04/2005:0438 talc * EP 04/2005:0438 talc * EP 04/2005:0438 talc FCC V talc monograph FCC V talc monograph FCC V talc monograph FCC V talc monograph FCC V talc monograph FCC V talc monograph FCC V talc monograph USP28-NF23 talc monograph USP28-NF23 talc monograph USP28-NF23 talc monograph USP28-NF23 talc monograph USP28-NF23 talc monograph USP28-NF23 talc monograph USP28-NF23 talc monograph USP28-NF23 talc monograph USP28-NF23 talc monograph USP28-NF23 talc monograph * USP28-NF23 talc monograph Identification B Test Identification C Acidity/ Alkalinity Water-soluble substances Aluminum Calcium Iron Lead Magnesium Loss on Ignition Microbial Contamination, Aerobic Bacteria Microbial Contamination, Fungi Acid-soluble substances (as S04) Arsenic Free alkali (as NaOH) Lead Loss on Drying Loss on Ignition Soluble salts Identification B Identification C Acidity / Alkalinity Loss on Ignition Water-soluble substances Iron Lead Calcium Aluminum Magnesium Microbial Contamination, Aerobic Bacteria Date Analyzed: 10-27-2005 Results Pass Units Pass Pass <0.1 <0.1 0.2 <0.01 % % % % <1 ppm 18.2 % 5.2 % 705 e fu /g <10 efu /g 0.2 % <3 m g/kg <1 5 <0.1 5.2 0.1 Pass Pass Pass 5.2 <0.1 <0.01 <0.001 0,2 % m g/kg % % % % % % % % <0.1 % 18.3 % 705 efu /g THE ANALYSIS RESULTS DENOTED () WERE PERFORMED BY AN INDEPENDENT LABORATORY.

I 1 -Special. - Dry White Lead Carter White Lead Co., | Carter process purecarbonate { lead.

Ever} work or process in the manufacture of white lead, red lead, litharge, sugar of lead, arsenate of lead, lead chromate, led sulphate, lead nitrate or fluosilicate, is hereby declared to be especially dangerous to the health of the employes, who, while engaged in such work or process, are exposed to lead dusts, lead fumes, or lead solutions. (103 v. 819.)

In doing so, 14 Riley Stoker has complied with its obligations under applicable 15 rules of court to conduct a reasonable investigation in order to 16 prepare its responses, and objects to identifying individuals as 17 neither relevant nor reasonably calculated to lead to the discovery 18 of admissible evidence.

CHESTERTON COMPANY et al DEFENDANT KUBOTA CORPORATION'S RESPONSES TO PLAINTIFFS REQUESTS FOR ADMISSION SET ONE 15 Defendants ) 29 ) 16 __) Action Filed July 2009 17 PROPOUNDING PARTIES RHODA EVANS AND BOBBY EVANS 18 RESPONDING PARTY KUBOTA CORPORATION 19 SET NO ONE 20 Defendant KUBOTA CORPORATION Defendant or KUBOTA hereby responds 21 to Plaintiffs Rhoda Evans and Bobby Evans Plaintiffs Request for Admissions Set No. as 22 follows 23 PRELIMINARY STATEMENT 24 25 These responses are made solely for the purpose of and in relation to this action Each 26 answer is given subject to all appropriate objections including but not limited to objections 27 concerning competency relevancy materiality propriety and admissibility which would require 28 the exclusion of any statement contained herein where made by a witness present and testifying $$$ 1 TO AINITICES DEQUESTS FOR ADMISSION SET ONE reserved and may be interposed at the 1 in court All such objections and grounds therefore are || 2 time of trial has not fully completed its investigation of It should be noted that this responding party 3 completed its discovery in this matter and has not 4 the facts relating to this case has not yet fully contained herein are based only upon such for trial All of the answers preparation 5 || completed its known to this which are presently available to and specifically 6 information and documents to such responding and disclose only those contentions which presently occur 7 responding party discovery independent investigation legal research and It is anticipated that further || 8 party add meaning to the known facts as well as establish 9 || analysis will supply additional facts lead to substantial and legal contentions all of which may 10 entirely entirely new factual conclusions from the contentions herein set forth 11 || additions to changes in and variations cement pipe in 1975 and during the As Responding Party ceased the sale of asbestos 12 have left the employ of the asbestos 13 || ensuing 35 years potentially knowledgeable witnesses 14 of Kubota Corporation or have become deceased and through standard cement pipe division || have been destroyed i 15 company record destruction policies potentially responsive documents lacks sufficient information and belief to respond to man should be noted that Responding Party are made on behalf of Kubota Corporation onl of the requests for admissions These responses 18 during the time asbestos cement pipe was exported to th with regard to information existing || 19 20 || United States to Kubota Corporation's right 21 The following responses are given without prejudice 24 discovered facts which this responding party may la 22 produce evidence of any subsequently and all answers her reserves the right to change any recall Kubota Corporation accordingly ascertained analyses are made legal research is completed : as additional facts are 25 contentions are made || 26 faith effort to supply as much fac The answers contained herein are made in a good 27 specification of legal contentions as is presently known but shoul 28 information and as much FOR ADMISSION SET ONE RESPONSES PLAINTIFFS PLAINTIFFS REQUESTS no way be to the prejudice of Kubota Corporation in relation to further discovery research or 2 any answers to herein no admission of any nature whatsoever is to be implied or inferred The 3 fact that any request for admission herein has been partially answered should not be taken as an 4 admission to the entire request or that such answer constitutes evidence of any facts thus set 5 forth or assumed All answers must be construed as given on the basis of present recollection 6 Any request for admission deemed as continuing is objected to as oppressive over burdensome 7 improper and not in compliance with Code of Civil Procedure Sections 2033 et seq and will not be regarded as continuing in nature RESPONSES PLAINTIFFS REQUESTS FOR ADMISSION 10 REQUEST FOR ADMISSION NO 1 11 Admit that on approximately June 29 2005 you made an announcement regarding the 12 occurrence of many occupational victims of asbestos as well as the victims of asbestos dust from 13 environmental exposure around the Kanzaki plant 14 RESPONSE REQUEST FOR ADMISSION NO 1 15 terms 16 Objection This request is vague and ambiguous with regard to the many 17 occupational victims of asbestos and victims of asbestos dust is overly broad irrelevant and 18 is not reasonably calculated to lead to the discovery of admissible evidence The request is 19 propounded to oppress and harass KUBOTA 20 REQUEST FOR ADMISSION NO 2 21 Admit that approximately 75 former workers of the Kanzaki Plant developed 22 a mesothelioma as result of their exposure to the plant's containing products and have 23 24 died as a result of this fatal disease 25 RESPONSE REQUEST FOR ADMISSION NO 2 26 Objection This request is vague and ambiguous with regard to the terms former 27 workers of the Kansaki Plant and containing products is overly broad irrelevant and 28 $$ $$$ 3 RESPONSES TO DI INTIEES REQUESTS FOR ADMISSION SET ONE is not reasonably calculated to lead to the discovery of admissible evidence The request is propounded merely to oppress and harass KUBOTA In addition the request and its accompanying Form Interrogatory No. 17.1 calls for information that invades the privacy 4 privilege of third parties and their families 5 REQUEST FOR ADMISSION NO 3 6 Admit that you have compensated the surviving families of deceased workers of the Kanzaki Plant who developed mesothelioma as a result of their exposure to the plant's asbestos- containing products 10 RESPONSE REQUEST FOR ADMISSION NO 3 11 Objection This request is vague and ambiguous with regard to the terms surviving 12 families deceased workers of the Kanzaki Plant and containing products is overly 13 broad irrelevant and is not reasonably calculated to lead to the discovery of admissible evidence 14 The request is propounded merely to oppress and harass KUBOTA In addition the request and 15 No. 17.1 calls for information that invades the privacy 16 its accompanying Form Interrogatory 17 privilege of third parties and their families Should KUBOTA be ordered to respond to this 18 said order will force KUBOTA to breach its confidentiality contract with third parties request 19 REQUEST FOR ADMISSION NO 4 20 Admit that residents of Amagasaki City Japan developed fatal mesothelioma during and 21 after the years the Kanzaki Plant produced containing products as a result of exposure 22 to the Kanzaki Plant's containing products 23 24 RESPONSE REQUEST FOR ADMISSION NO 4 25 Objection This request is vague and ambiguous with regard to the terms residents of 26 Amagasaki City Japan Kanzaki Plant and containing products is overly broad 27 irrelevant and not reasonably calculated to lead to the discovery of admissible evidence The 28 $$ 4 DESPONSES PI AINTIFFS REQUESTS FOR ADMISSION SET ONE request is propounded merely to oppress and harass KUBOTA In addition the request and its accompanying Form Interrogatory No. 17.1 calls for information that invades the privacy privilege of third parties REQUEST FOR ADMISSION NO 5 Admit that from 1962 through 1975 approximately 240,000 tons of asbestos was used at the Kanzaki Plant in the production of asbestos water pipes and building material RESPONSE REQUEST FOR ADMISSION NO 5 Objection This request is vague and ambiguous with regard to the terms Kanzaki 10 Plant and asbestos water pipes and building material With regard to the years 1962 to 11 1967 prior to Bobby Evans employment with LOS ANGELES DEPARTMENT OF WATER 12 AND POWER this request is overly broad and irrelevant and is not reasonably calculated to lead 13 to the discovery of admissible evidence The request is propounded merely to oppress and harass 14 KUBOTA 15 16 Without waiving these objections Defendant responds as follows 17 Deny 18 REQUEST FOR ADMISSION NO 6 19 Admit that from 1962 through 1975 YOU were informed and had documentation 20 regarding the HAZARDS ASSOCIATED WITH ASBESTOS EXPOSURE and ASBESTOS 21 CONTAINING MATERIAL 22 RESPONSE REQUEST FOR ADMISSION NO 6 23 24 Objection This request is compound with regard to the terms from 1962 to 1975 and 25 and ASBESTOS CONTAINING MATERIAL The request is vague and ambiguous with 26 regard to the term documentation and the term ASBESTOS CONTAINING MATERIAL 27 With regard to the years 1962 to 1967 prior to Bobby Evans employment with LOS 28 5 DESDONSES TO INT^ FESREQUESTS REQUESTS FOR ADMISSION SET ONE ANGELES DEPARTMENT OF WATER AND POWER this request is overly broad and irrelevant and is not reasonably calculated to lead to the discovery of admissible evidence The request is propounded merely to oppress and harass KUBOTA 4 Without waiving these objections Defendant responds as follows 5 Through the passage of time and demise of its employees KUBOTA is unable to more 6 completely respond to this interrogatory but shortly before its enactment KUBOTA became aware of a 1960 Japanese Pneumoconiosis Act that addressed pneumoconiosis and asbestosis resulting from long term exposures to asbestos at manufacturing facilities but not lung cancer

CHESTERTON COMPANY et al ) CORPORATION'S RESPONSES TO ) PLAINTIFFS REQUESTS ) FOR ADMISSION SET ONE 15 Defendants ) ) 16 ) Action Filed July 29 2009 17 PROPOUNDING PARTIES RHODA EVANS AND BOBBY EVANS 18 RESPONDING PARTY KUBOTA CORPORATION 19 SET NO ONE 20 Defendant KUBOTA CORPORATION Defendant or KUBOTA hereby responds 21 22 to Plaintiffs Rhoda Evans and Bobby Evans Plaintiffs Request for Admissions Set No. 1 as follows 23 24 PRELIMINARY STATEMENT 25 These responses are made solely for the purpose of and in relation to this action Each 26 answer is given subject to all appropriate objections including but not limited to objections 27 concerning competency relevancy materiality propriety and admissibility which would require 28 the exclusion of any statement contained herein where made by a witness present and testifying in court All such objections and grounds therefore are reserved and may be interposed at the time of trial It should be noted that this responding party has not fully completed its investigation of the facts relating to this case has not yet fully completed its discovery in this matter and has not completed its preparation for trial All of the answers contained herein are based only upon such information and documents which are presently available to and specifically known to this responding party and disclose only those contentions which presently occur to such responding party It is anticipated that further discovery independent investigation legal research and analysis will supply additional facts add meaning to the known facts as well as establish 10 entirely new factual conclusions and legal contentions all of which may lead to substantial 11 additions to changes in and variations from the contentions herein set forth 12 As Responding Party ceased the sale of asbestos cement pipe in 1975 and during the 13 ensuing 35 years potentially knowledgeable witnesses have left the employ of the asbestos 14 cement pipe division of Kubota Corporation or have become deceased and through standard 15 company record destruction policies potentially responsive documents have been destroyed it 16 should be noted that Responding Party lacks sufficient information and belief to respond to many 17 18 of the requests for admissions These responses are made on behalf of Kubota Corporation only 19 with regard to information existing during the time asbestos cement pipe was exported to the 20 United States 21 The following responses are given without prejudice to Kubota Corporation's right to 22 produce evidence of any subsequently discovered facts which this responding party may later 23 recall Kubota Corporation accordingly reserves the right to change any and all answers herein 24 as additional facts are ascertained analyses are made legal research is completed and 25 contentions are made 26 27 The answers contained herein are made in a good faith effort to supply as much factual 28 information and as much specification of legal contentions as is presently known but should in no way be to the prejudice of Kubota Corporation in relation to further discovery research or any answers to herein no admission of any nature whatsoever is to be implied or inferred The fact that any request for admission herein has been partially answered should not be taken as an admission to the entire request or that such answer constitutes evidence of any facts thus set forth or assumed All answers must be construed as given on the basis of present recollection Any request for admission deemed as continuing is objected to as oppressive over burdensome 6 improper and not in compliance with Code of Civil Procedure Sections 2033 et seq and will 8 not be regarded as continuing in nature 9 RESPONSES PLAINTIFFS REQUESTS FOR ADMISSION 10 REQUEST FOR ADMISSION NO 1 11 Admit that on approximately June 29 2005 you made an announcement regarding the 12 occurrence of many occupational victims of asbestos as well as the victims of asbestos dust from 13 Kanzaki environmental exposure around the 14 plant RESPONSE REQUEST FOR ADMISSION NO 1 15 16 Objection This request is vague and ambiguous with regard to the terms many 17 occupational victims of asbestos and victims of asbestos dust is overly broad irrelevant and 18 is not reasonably calculated to lead to the discovery of admissible evidence The request is 19 propounded to oppress and harass KUBOTA 20 REQUEST FOR ADMISSION NO 2 21 Admit that approximately 75 former workers of the Kanzaki Plant developed 22 23 mesothelioma as a result of their exposure to the plant's containing products and have 24 died as a result of this fatal disease 25 RESPONSE REQUEST FOR ADMISSION NO 2 26 Objection This request is vague and ambiguous with regard to the terms former 28 workers of the Kansaki Plant and containing products is overly broad irrelevant and 28 is not reasonably calculated to lead to the discovery of admissible evidence The request is propounded merely to oppress and harass KUBOTA In addition the request and its accompanying Form Interrogatory No. 17.1 calls for information that invades the privacy privilege of third parties and their families REQUEST FOR ADMISSION NO 3 Admit that you have compensated the surviving families of deceased workers of the Kanzaki Plant who developed mesothelioma as a result of their exposure to the plant's asbestos- containing products 10 RESPONSE REQUEST FOR ADMISSION NO 3 11 Objection This request is vague and ambiguous with regard to the terms surviving 12 families deceased workers of the Kanzaki Plant and containing products is overly 13 broad irrelevant and is not reasonably calculated to lead to the discovery of admissible evidence 14 15 The request is propounded merely to oppress and harass KUBOTA In addition the request and 16 its accompanying Form Interrogatory No. 17.1 calls for information that invades the privacy 17 privilege of third parties and their families Should KUBOTA be ordered to respond to this 18 request said order will force KUBOTA to breach its confidentiality contract with third parties 19 REQUEST FOR ADMISSION NO 4 20 Admit that residents of Amagasaki City Japan developed fatal mesothelioma during and 21 after the years the Kanzaki Plant produced containing products as a result of exposure 22 23 to the Kanzaki Plant's containing products 24 RESPONSE REQUEST FOR ADMISSION NO 4 25 Objection This request is vague and ambiguous with regard to the terms residents of 26 Amagasaki City Japan Kanzaki Plant and containing products is overly broad 27 irrelevant and not reasonably calculated to lead to the discovery of admissible evidence The 28 request is propounded merely to oppress and harass KUBOTA In addition the request and its accompanying Form Interrogatory No. 17.1 calls for information that invades the privacy privilege of third parties REQUEST FOR ADMISSION NO 5 Admit that from 1962 through 1975 approximately 240,000 tons of asbestos was used at the Kanzaki Plant in the production of asbestos water pipes and building material RESPONSE REQUEST FOR ADMISSION NO 5 Objection This request is vague and ambiguous with regard to the terms Kanzaki 10 Plant and asbestos water pipes and building material With regard to the years 1962 to 1967 11 prior to Bobby Evans employment with LOS ANGELES DEPARTMENT OF WATER 12 AND POWER this request is overly broad and irrelevant and is not reasonably calculated to lead 13 to the discovery of admissible evidence The request is propounded merely to oppress and harass 14 KUBOTA 15 16 Without waiving these objections Defendant responds as follows 17 Deny 18 REQUEST FOR ADMISSION NO 6 22 Admit that from 1962 through 1975 YOU were informed and had documentation 20 regarding the HAZARDS ASSOCIATED WITH ASBESTOS EXPOSURE and ASBESTOS 21 CONTAINING MATERIAL 22 23 RESPONSE REQUEST FOR ADMISSION NO 6 24 Objection This request is compound with regard to the terms from 1962 to 1975 and 25 and ASBESTOS CONTAINING MATERIAL The request is vague and ambiguous with 26 regard to the term documentation and the term ASBESTOS CONTAINING MATERIAL 27 With regard to the years 1962 to 1967 prior to Bobby Evans employment with LOS 28 ANGELES DEPARTMENT OF WATER AND POWER this request is overly broad and irrelevant and is not reasonably calculated to lead to the discovery of admissible evidence The request is propounded merely to oppress and harass KUBOTA Without waiving these objections Defendant responds as follows Through the passage of time and demise of its employees KUBOTA is unable to more completely respond to this interrogatory but shortly before its enactment KUBOTA became aware of a 1960 Japanese Pneumoconiosis Act that addressed pneumoconiosis and asbestosis resulting from long term exposures to asbestos at manufacturing facilities but not lung cancer or 10 mesothelioma and on that basis admits the request KUBOTA believes it first learned of 11 asbestos related cancer and mesothelioma hazards shortly before promulgation of the 1975 12 Japanese Ordinance on Prevention of Hazards Caused by Specific Chemical Substances and on 13 this basis denies the request 14 15 REQUEST FOR ADMISSION NO 7 16 Admit that from 1962 through 1975 precaution

RESPONSE: Defendant asserts the general objections previously made and would further object that the request for production is overly broad, vague, ambiguous, unduly burdensome, and is not reasonably calculated to lead to the discovery of admissible evidence.

-angie process O m is lead dust.

As used herein, all objections as to relevance shall mean that information or documents requested are irrelevant to the subject matter involved in the pending action and are not reasonably calculated to lead to the discovery of admissible evidence. 3.

Lead poisoning continues to be a problem; this report cites about 65 incidents of lead poisoning among workers' families.

Chicago New York /MONG the other O'*- products we man ufacture, in addition to white-lead, are red-lead, litharge,orange mineral, basic lead sulphates and lead acetates.

On the other hand the Rrilid gov ernment announced that it would dn pose of *0,000 iom of lead from it* stockpile.