Document 2No6w7dLd2obRmbYjDX4zE3ja

Abex further objects to this interrogatory to the extent to which it seeks information regarding time periods and products that are not at issue in this case on the ground that such information lacks relevance, and is not reasonably calculated to lead to the discovery of admissible evidence. Abex further objects to this interrogatory on the ground that the information it seeks otherwise lacks relevance to the issues arising in this case, and is not reasonably calculated to lead to the discovery of admissible evidence. Abex further objects to this interrogatory on the ground that it assumes the truth of matters not established or matters not in evidence. Abex further objects to this interrogatory on the grounds that it is over broad, oppressive, harassing and otherwise unduly burdensome, and calls for speculation to the extent to which it requests knowledge, information or materials which are not within the personal possession or control of Abex, its employees or agents, or which may be ascertained or derived, if at all, only from a page-by-page review of the existing voluminous business records and documents of Abex. Subject to and without waiving these objections, and insofar as Abex understands this interrogatory, see objections and response to Interrogatory No. 8, above. INTERROGATORY NO. 20: Were any design changes or modifications made as a result of such tests listed in answer to Interrogatory No. 18 hereinabove (sic)? If so, please state: (a) The trade name of the product changed or modified; (b) The nature of the change made and the date of such changes or modifications; (c) The name, address, and job classification of each person in charge of making a change. -45-