Document 2jq18BV8qdpyqR8awmeBpZVO6

present employee who claims he/she was suffering, or had suffered from: (a) asbestos!s; (b) lung cancer, (c) mesothelioma; SECOND AMENDED ANSWER TO INTERROGATORY NO. 92; See Objections and Answer to Interrogatory No. 91, which are incorporated by reference as though set forth herein in full. INTERROGATORY NO. 93; Identify any and all material safety data sheets concerning the products listed in response to Interrogatory Nos. 19 and 42 prepared, at any time, by, or on behalf of. Defendant, and predecessor or any related company. SECOND AMENDED ANSWER TO INTERROGATORY NO. 93: Abex objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, compound, vague and ambiguous and calls for speculation. Abex also objects to this interrogatory on the ground that it purports to shift the burden of establishing product identification from plaintiffs to Abex. Abex further objects to this interrogatory to the extent it purports to seek information ot 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. Abex objects to this interrogatory on the grounds that the information or materials it purports to seek otherwise lack relevance to the issues arising in these cases and are not reasonably calculated to lead to the discovery of admissible evidence. Abex also objects to this interrogatory to the extent to which it purports to seek information or materials that have been gathered, received, or prepared in the course of litigation. 162