FRICTION PRODUCTS GROUP WINCHESTER, VIRGINIA APPENDIX #1 FIELD SAMPLE #16 FIELD SAMPLE #17 FIELD SAMPLE 18 Fiber count>-5p/ml-l.'24 Lab No. - 1854 Loc.

FRICTION PRODUCTS GROUP WINCHESTER, VIRGINIA APPENDIX #1 FIELD SAMPLE #22 FIELD SAMPLE #23 FIELD SAMPLE #24 Filler count75,u/ml-0.00 Lab No. - 1860 Loc. - Blank Date - 10-2-74 Fiber count^S/i/ml-2.02 Fiber count>5n/ml- Lab No. - 1861 Lab.

1 1 INTERROGATORY NO. 30; 2 If the answer to the preceding interrogatory is in the af 3 firmative, please state: 4 (a) The nature and content of the information referred 5 to in the preceding interrogatory; 6 (b) When the defendant was furnished the information; 7 (c) From whom the defendant received the information. 8 RESPONSE: 9 Not applicable. 10 INTERROGATORY NO. 31: 11 Has any other defendant herein furnished the answering de 12 fendant with the results of any research, tests, medical studies 13 or experiments regarding any connection between asbestos exposure 14 and the development of pulmonary disease, including lung cancer 15 and asbestosis, since 1930?

0 1 INTERROGATORY NO. 41: 2 Please state the names of all organizations, groups, 3 inter-company or industrial organizations that defendant has been 4 a member of which conducted studies or research on the relation 5 ship between exposure to asbestos or asbestos-containing products 6 and asbestosis and lung cancer from 1930 to 1972. 7 RESPONSE: 8 OBJECTION.

"'l 1 INTERROGATORY NO. 56; 2 Has the defendant sponsored, since 1930, any meetings, semi 3 nars, conferences, or conventions where the subject of occupa 4 tional health and/or exposure to asbestos was discussed?

trade associations of which Abex was member, would have been funded out of dues payable by each member company or corpora tion. 49.

compensation claims within the above-described criteria between the years 1930 and 1978, state: (a) The date you received notice of the claim; (b) The identity of the person making the claim; or on whose behalf the claim was made; (c) The specific disease or illness complained of.

(3) (4) (5) (6) worn during all procedures starting with the removal of wheels and including reassembly.

"A 1 In 1943, The American Brake Shoe and Foundry Company changed 2 its name to American Brake Shoe Company.

1 INTERROGATORY NO. 9; 2 Has defendant, at any time from 1930 to the present, engaged 3 in the processing, marketing and/or sale of products containing 4 asbestos fibers?

h 1 INTERROGATORY NO. 106; 2 Please state whether the defendant at any time between 1930 3 and 1972 had an International Division. 4 RESPONSE: 5 Yes . 6 INTERROGATORY NO. 107: 7 If the answer to the preceding interrogatory is affirmative, 8 please state when the International Division was created and 9 where it has been headquartered from its inception. 10 RESPONSE: 11 Abex International, S.A., headquartered in Geneva, was 12 incorporated in 1965 in Switzerland. 13 INTERROGATORY NO. 108: 14 Please state whether the defendant has ever had a division 15 which exported raw asbestos or asbestos-containing products.

cV.

121 Super Brakes Protector Stopper Velvetouch Organik RESPONSE TO INTERROGATORY NO. 5 SUBPART Abex further objects to this subpart on the grounds that it is over broad, oppressive, harassing and otherwise unduly burdensome, and calls for speculation to the extent that it requests information which is not within the personal knowledge, possession or control of Abex, its employees or agents, or which may be ascertained or derived, if at all, only from a page-bypage review of the existing voluminous business records and documents of Abex.

''">N protecting materials prepared in anticipation of and/or in connection with litigation, or any other applicable privilege.

BULLETIN No. 19 Mechanic'b Complaints Drums Won't Go On Page 5 Causes Tapered blocks incorrectly positioned.