Document 2n4wGzVEq6kZbVaorR0ow2b

Abex further objects to this request on the ground that it assumes the truth of.matters not established or matters not in evidence. Abex further objects to this request to the extent to which it purports to seek information that has been gathered, received or prepared in the course of the asbestos litigation, or which is otherwise subject to the attorney-client privilege, the attorney work-product doctrine, the rule protecting materials prepared in anticipation of and/or in connection with litigation, or any other applicable privilege. Subject to and without waiving these objections, and insofar as Abex understands this request, see objections and response to Interrogatory No. 41. REQUEST FOR PRODUCTION NO. 18: Please produce a true and correct copy of all written materials prepared by Defendant or Defendant's predecessors or any of Defendant's subsidiaries indicating how the products listed in response to Interrogatory No. 5 should be used or maintained by the ultimate user (this Request for Production relates to Plaintiffs' Interrogatory No. 43 previously propounded to Defendant). RESPONSE TO REQUEST FOR PRODUCTION NO. 18: See General Objections. Abex further objects to this request on the grounds that it is overly broad, unduly burdensome, vague, ambiguous and speculative. Objection is made to this request on the ground that the terms "written materials," "used," "maintained" and "ultimate user" are undefined, and call for speculation. Abex further objects to this request 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 request 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. -19-