Document 329pJVK92aK2bvzgeoZOpwNx

Abex's asbestos-containing automotive friction products was chrysotile, the only type of asbestos Abex ever used for product production, which was resin-bonded and encapsulated, proper use of such products did not create or contribute to any adverse health effects. 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, or which are otherwise subject to the attorney-client privilege, protected by 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 it understands this interrogatory, Abex discontinued the manufacture and sale of asbestos- containing friction products m 1987 and no longer operates any friction product manufacturing facilities There are no current Abex employees, officers who worked for Abex, or directors who sat on its Board during the period Abex manufactured and sold friction products with personal knowledge of the information contained in all the records and documents that might be responsive to this interrogatory. Lloyd Hamlm served as Abex's Medical Director between 1941 and 1961 Dr. Hamlm pubhshed an article m 1946 in which he referenced asbestosis Dr Hamlm is deceased and Abex has no way to determine when, if ever, he or any other Abex official first received information responsive to this interrogatory. In addition, see Answer to Interrogatory Nos. 80 and 98. -181-