Document 6wQor6k432zwaEddq28aNn8p1

INTERROGATORY NO. 58: Has Defendant, any predecessor or any related company, or any person or entity acting on behalf thereof, at any time, conducted any study(ies), of any kind, concerning the effects of the inhalation of asbestos dust or asbestos fibers on one using or being exposed to asbestos or any asbestos-containing product, including, but not limited to, those identified in response to Interrogatory Nos. 19 and 42? ANSWER TO INTERROGATORY NO. 58: Abex objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, compound, vague, ambiguous and speculative. Abex also objects to this interrogatory on the grounds that the term "relationship" is vague and ambiguous and calls for speculation Abex further objects to this interrogatory on the ground that it purports to shift the burden of establishing causation from plaintiffs to Abex. Abex 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 also objected to on the grounds that such information or matenals lack relevance to the issues ansing m these cases and are not reasonably calculated to lead to the discovery of admissible evidence Abex further objects to this interrogatory on the grounds that the information or matenals 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 objects to this mtenogatory on the grounds that it assumes the truth of matters not established or matters not in evidence -138-