Document 3NvV9kyM7av7mOqgMm2zkDyJO

in building insulation products and/or asbestos-containing automotive friction products, and/or among the different types of asbestos fibers. Because the asbestos fiber contained in 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 objects to this interrogatory to the extent to which it purports to seek information or matenals 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 workproduct doctrine, the rule protecting matenals prepared in anticipation of and/or in connection with litigation, or any other applicable pnvilege. Abex also further objects to this interrogatory to the extent to which it purports to seek medical records or privileged personnel information, which Abex will not provide absent an appropriate waiver of the applicable privilege. Subject to and without waiving these objections, and insofar as Abex understands this interrogatory, see Answer to Interrogatory No. 91. , -218-