Document 59vGz5pLr0aarjZe5RJk6bvJ

relevance to this case and is not reasonably calculated to lead to the discovery of admissible evidence. Abex further states that it never engaged any "contracting unit worker," "employee contractor" or "contracting unit manager." 40. State whether you or your insurance carrier has voluntarily or by agreement paid to any employee benefits for accident, sickness, health, disability, or retirement, by reason of exposure to asbestos products. If so, state as to each: (a) The identity of such employee; (b) The identity of the employee's attorney; (c) The identity of the insurance carrier(s) making such payment; (d) The dates the claims were made as to each separate claim by each employee; (e) The date payment was made; (f) The current location of any documents evidencing such payments, the name and address of their present custodian and the time and place where counsel for the plaintiff can examine and copy such documents. ANSWER TO INTERROGATORY NO. 40: Abex objects to this interrogatory on the grounds that it is overly broad, burdensome, and, in seeking information concerning Abex employees, lacks relevance to this case and is not reasonably calculated to lead to the discovery of admissible evidence. 41. State the names and addresses of all your insurance carriers for workmen's compensation and occupational disease compensation from 1930 through 1985, and your insurance carrier for this action, and as to each insurance carrier, state the periods when such coverage was provided and the amount provided, and the name(s) and coverage amounts of your carrier(s) in this action. If there is a dispute between you and certain carriers as to coverage, please answer this question as to: -31-