Document 2Vw61EGxnrjBJgLkRM7EOE8r

(b) Specifications for paper or burlap bags, or other packaging to be used for the transport and/or storage of asbestos cement; (c) Warning or caution labels to be applied to asbestos products and/or their packaging, cartons, containers, or boxes; (d) Methods of dissemination of public relations information to defendant's purchasers, advertisers, distributors, factory workers, contractors, insulators, users, consumers of asbestos products and/or the general public; (e) Safety equipment and/or protective clothing to be utilized while handling defendant's asbestos products; (1) Medical programs to be offered or sponsored by defendant. SECOND AMENDED ANSWER TO INTERROGATORY NO. 101: Abex objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, compound, vague and ambiguous and calls for speculation. Pursuant to the Court's April 13,2000 Order, Abex's answer to this interrogatory is limited to the years between 1930 and 1980. Abex also objects to this interrogatory to the extent it purports to seek information or materials regarding time periods and products that are not at issue in these cases, on the grounds that such information or materials lack relevance and are not reasonably calculated to lead to the discovery of admissible evidence. To the extent it purports to seek information or materials regarding the working conditions of Abex employees, this interrogatory is further objected to on the grounds that such information or materials lack relevance to the issues arising in these cases and are not reasonably calculated to lead to the discovery of admissible evidence. Abex objects to this interrogatory on the grounds that the information or materials it purports to seek lack relevance to the issues arising in these cases and are not reasonably calculated to lead to the 177