Document 91QeJrNzeBDBMb40Nevoxp3OD

9 INTERROGATORY NO. 47: Did any person prior to 1970, file a claim against any Workers' Compensation carrier covering Defendant alleging that he or she contracted a disease as a result of exposure to asbestos? If so, please state the following: (a) A list of each such claim by claimant's name, date filed, the caption and jurisdiction involved; (b) The disease alleged in each such claim; (c) A brief summary of the disposition of each such claim; and (d) The name, address and job classification of the person or persons having custody of the records pertaining to each such claim. RESPONSE TO INTERROGATORY NO. 47: See General Objections. Abex further objects to this interrogatory on the grounds that it is overly broad,'unduly burdensome, vague, ambiguous and speculative. Abex further objects to this interrogatory on the ground that the terms "disease," "exposure" and "asbestos" are undefined, and call for speculation. Objection is also made to the extent this interrogatory seeks information regarding Abex employees on the ground that such information 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 interrogatory 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 interrogatory on the ground that it assumes the truth of matters not established or matters not in evidence. Abex further objects to this interrogatory to the extent to which it purports to seek medical records or privileged personnel information, which Abex will not provide absent an appropriate waiver of the applicable privilege. -84-