Document 2R3ZXKvOpe1JZ1Er5Mx59xJea

in the introductory paragraph to Plaintiff's Interrogatories. Abex objects to this Interrogatory as irrelevant, immaterial and not likely to lead to the discovery of admissible evidence. Without waiving this objection, Abex states that it has manufactured, sold and distributed asbestos-containing automotive friction products. (a) The trade names, brand names, logos and trademarks for Abex automotive and truck brake linings include but are not limite to the following: American Brakeblok, Abex, Esline, Stopper, Crossing Guard, 121 Super Brake, Logger, Protector and private labels such as Paccar, Trailmobile, Great Dane and Mack Truck. (b) Abex began producing and marketing automotive brake lining products from about 1926 to the present. (c) Each product is intended to stop a moving vehicle. (d) The composition is of chrysotile asbestos. The cuar titative percentage of asbestos in the products varies from 25% to 655 by weight. The appearance would be in the form of rigid blocks and' strips or in rolls as well as flat sheets. (e) Answering Defendant incorporates by reference hereir its Answer to Interrogatory No. 6(d) above. The products are generall dark gray or black in color. The products have always been sold in a solid form. (f) Friction Products Division, 2410 Papermill Road, Winchester, VA 22601. 18. (a) through (c) Abex has used corrugated cardboard and regular cardboard boxes to package their automotive brake products. These boxes vary in size, color and design. Various types of boxes a: