Document 3Qdwb12gyeXGL0L93z3mLNBaD

INTERROGATORY NO. 50: Did Defendant, any predecessor or any related company, or any medical department or industrial hygiene division thereof, maintain a medical and/or scientific library at any time from 1940 to the present? If so: (a) State the dates such library existed; (b) State the number of volumes maintained therein; (c) State the number of employees, part-time or full-time, assigned to the maintenance of said library, and (d) Identify the person(s) within the corporate structure to whom said library employees reported throughout the existence of the library. ANSWER TO INTERROGATORY NO. 50: Abex objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, compound, vague and ambiguous Abex also objects to this interrogatory on the grounds that the term "any related company" is vague and ambiguous and calls for speculation. Abex further objects to this interrogatory to the extent it purports to seek information or matenals regarding time periods and products that are not at issue m these cases, on the ground that such information or matenals lack relevance and are not reasonably calculated to lead to the discovery of admissible evidence To the extent to which it purports to seek information or matenals regarding the working conditions of Abex employees, this interrogatory is objected to on the grounds that such information or materials lack relevance to the issues ansing m these cases and are not reasonably calculated to lead to the discovery of admissible evidence. Abex also objects to this interrogatory on the grounds that the information or matenals it purports to seek otherwise lack relevance to the issues ansing in these cases and are not reasonably calculated to lead to the discovery of admissible evidence. -121-