Document 50gYo23JnX1JoNYY6x726R3y5

INTERROGATORY NO. 31: Was each of the asbestos-containing products listed in response to Interrogatory No 19 generally expected to reach, or was each packaged to reach, the consumer or user, without substantial change in the condition in which it was sold'? ANSWER TO INTERROGATORY NO. 31: 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 or 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 m these cases and are not reasonably calculated to lead to the discovery of admissible evidence. Abex also objects to this interrogatory on the ground that it assumes the truth of matters not established or matters not m evidence. Subject to and without waiving these objections, and insofar as it understands this interrogatory, Abex responds that generally the asbestos-contaming products it manufactured were not intended to be ground, arced, beveled or sanded in the application or installation of these products Upon information and belief, some products were generally intended to reach the ultimate end-user m substantially the same condition as sold by Abex, while other products were -74-