Document 93r4dEkdr0O0Ee30zVkLN4qJp
Without waiving these objections, see Response to Interrogatory
No. 19.
66. If your answer to any part of the above Inter rogatory 65 is in the affirmative, state:
(a) The nature and exact wording of such advice, warning, recommendation, etc.
(b) The complete identity of each source of such advice, warning, recommendation, etc.
(c) The date, time, place, manner and circum stances when such advice, warning, recommendation, etc. was given.
(d) The name, business address and telephone number, job title, residence address and telephone number of each and every witness to the plaintiff's reception of such advice, warning, recommendation, etc.
(e) The name, business address and telephone number, job title, residence address and telephone number of each and every co-worker or similar member of their trade and occupation who also received the same or similar advice, warn ing, recommendation, etc.
ANSWER: See Response to Interrogatory No. 65
67. State the name of all persons who have acted in the capacity as a medical librarian for the defendant since 1930, and give their current address, telephone number and current position with the company.
ANSWER: Abex Corporation has never employed any
personnel in the capacity of a medical librarian.
68. State whether you subscribed to or received copies of the Asbestos Workers magazine and state the years of subscription or receipt of this magazine.
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