Document 85JZoX876qnjDLBbq3MzBj7Ny

PLAINTIFF'S EXHIBIT IN THE COURT OF COMMON PLEAS OF PHILADELPHIA COUNTY CIVIL SECTION: TRIAL DIVISION RICHARD SANDS and PATRICIA SANDS, h/w VS. ABEX CORPORATION JULY TERM, 1985 NO. 3259 ASBESTOS CASE ABEZ CORPORATION'S ANSWERS TO PLAINTIFF'S INTERROGATORIES AND REQUESTS FOR PRODUCTION TO DEFENDANT - SET I INTRODUCTION AND GENERAL OBJECTIONS Abex Corporation ("Abex"), by and through its attorneys of record, Clayton H. Thomas, Jr. & Associates, generally objects to these interrogatories on the grounds that they are unduly burdensome, oppressive, vague, overly broad as to time, scope and location, lack particularity, and are repetitive. The use of the words "any," "all" and "each" is overly broad and is objected to. Many of the interrogatories in this set designate extensive periods of time or request information without any limitation or specification of particular periods of time. As a result of the failure by plaintiff to specify relevant time periods, many of the interrogatories fail to distinguish relevant from irrelevant matter. Many of these interrogatories call for Abex to characterize the state of knowledge or awareness of a corporation at any given time with regard to a particular fact, event or subject. Abex can only respond to such interrogatories, if at -1-