Document 8OQB1RxqMNMq3nzZze9dXQBYm

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 interrogatory on the ground that it assumes the truth of matters not established or matters not in evidence. Abex further objects to this interrogatory 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 from a page-by-page review of the existing voluminous business records and documents of Abex. Subject to and without waiving these objections, and insofar as Abex understands this interrogatory, see objections and response to Interrogatory No. 31, above. INTERROGATORY NO. 34: Does Defendant maintain a library dealing with industrial hygiene, medicine, safety and engineering and/or research? If so, state: (a) The date each such library was established; (b) The location of each library; (c) The name(s) of the librarian(s) since 1930; (d) List all journals subscribed to by you concerning asbestos, industrial hygiene, medicine, safety, and/or engineering; (e) List all books and articles dealing with asbestos and asbestos-related diseases and the date acquired. RESPONSE TO INTERROGATORY NO. 34: See General Objections. Abex further objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, compound, vague, ambiguous and speculative. -67-