Document 7OY7YZV29Ze6MwG0pqyxp1xZa

REQUEST FOR PRODUCTION NO. 7: Please produce a true and correct copy of each work order and contract that reflects contract business between Defendant and any of the job sites listed on Exhibit A, attached hereto, for the application of asbestos-containing products. RESPONSE TO REQUEST FOR PRODUCTION NO. 7: See General objections. Subject to and without waiving these objections, Abex responds: Not applicable. REQUEST FOR PRODUCTION NO. 8: Please produce a true and correct copy of each document relating to the design and preparation of the asbestos-containing products listed in Defendant's answer to Interrogatory No. 5. RESPONSE TO REQUEST FOR PRODUCTION NO. 8: See General objections. Abex further objects to this request on the grounds that it is overly broad, unduly burdensome, compound, vague and ambiguous. Objection is made to this request on the ground that the term "preparation" is undefined, and calls for speculation. Abex further objects to this request 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 request 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 request on the grounds that it is over broad, oppressive, harassing and otherwise unduly burdensome, and calls for speculation to the extent to which it requests knowledge, information or materials which are not within the personal possession or control of Abex, its employees or agents, or which may be ascertained or derived, if at all, only -11-