Document 6RZ0p0B3LpxbKMxorvqORD8k9

I 1 2 burdensome, oppressive and overly broad as to time, scope and 3 Location, lack particularity, and are repetitive. The use of 4 the word "any" and "all" is overly broad and is objected to. 5 Objection is also made to the extent these Interrogatories as 6 sume the truth of facts not in evidence, and on the grounds that 7 they seek information which is not relevant to the subject mat 8 ter of the action and not reasonably calculated to lead to the 9 discovery of admissible evidence. 10 Objection is also made to these Interrogatories to the 11 axtent that they seek privileged, confidential, or proprietary 12 "trade secret" or other information or materials which have been 13 gathered or prepared in the course of the asbestos litigation, 14 or which is otherwise subject to the attorney-client privilege, 15 the attorney work-product privilege, the rule protecting materi 16 als prepared in anticipation of and/or in connection with 17 litigation, or any other applicable privilege. 18 Abex objects to plaintiff's Definitions as set forth 19 in the Interrogatories, and to each and every interrogatory to 20 which any of such definitions are applicable, upon the ground 21 that plaintiff by such definitions purports to call upon Abex to 22 answer otherwise than as required by the provisions of the Code 23 of Civil Procedure and upon the further ground that the Inter 24 rogatories are by reason of such definitions rendered overly 25 broad, unduly burdensome, oppressive, harassing, shotgun, vexa 26 tious and boilerplate in nature, and purport to call for infor- 27 28 -2-