Document 5DpJwkdvz1Mv5KQQvEgBEoxb5

Abex further objects to this interrogatory to the extent to which it seeks information regarding time periods and products that are not at issue in this case on the ground that such information lacks relevance, and is not reasonably calculated to lead to the discovery of admissible evidence. Abex further objects to this interrogatory on the ground that the information it seeks otherwise lacks relevance to the issues arising in this case, and is not reasonably calculated to lead to the discovery of admissible evidence. Abex further objects to this interrogatory on the ground that it assumes the truth of matters not established or matters not in evidence. Abex further objects to this interrogatory to the extent to which it purports to seek information that has been gathered, received or prepared in the course of the asbestos litigation, or which is otherwise subject to the attorney-client privilege, 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 has employed industrial hygienists and medical directors whose job duties have included ensuring a safe working environment for all Abex employees. Because these personnel dealt with the working conditions of Abex employees, further information concerning them is not relevant to the issues arising, and is not reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving these additional objections, the following persons served as medical director for Abex Corporation: Lloyd E. Hamlin Charles C. Blackwell Frederich W. Knoch William F. Redman Dennis G. Egnatz 1941-1961 1961-1976 1976-1982 1982 1982-1987 -55-