Document 7ENgZkkRwag8MDoMyXvbzQxE

) INTERROGATORY NO. 71: If your answer to interrogatory No. 70 is "Yes," identify each and every product upon which such a warning was placed and for each such product identified* (a) State, verbatim, each and every warning which ever appeared on said ____________ product,______ ______________ _______________________________________ (b) State the size, color and location of each such warning and describe the manner in which it was placed upon the product; (e) State the dates on which each such warning first and last appeared in ' said product, and, (f) Identify any and all documents referring to, relating to or reflecting the placing of any warning directly upon said products, including, but not limited to, decisions not to place such a warning. ANSWER TO INTERROGATORY NO. 71: 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 causation from plaintiffs to Abex Abex further objects to this interrogatory to the extent it purports to seek information or materials regarding time penods 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 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. -162-