Document 99EEMzRLBG06aDQzKrd0qqNbV

medical department also used the New York Academy of Medicine Library for references not available in its own collection. To the extent that additional information responsive to this Interrogatory is in the possession of Union Carbide, this information is located in the repositories maintained by Union Carbide's counsel. INTERROGATORY NO. 51: Identify any and all scientific or medical periodicals to which Defendant, any predecessor or any related company, or any medical department or industrial hygiene division thereof, subscribed from 1940 to the present, and for each periodical state the dates of such subscriptions. RESPONSE: See General Objections Nos. 1-8. Union Carbide further objects to this Interrogatoiy on the grounds that it is unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Subject to its objections, Union Carbide responds as follows: See Union Carbide's Response to Interrogatory No. 50, including all objections set forth therein. To the extent that additional information responsive to this Interrogatory is in the possession of Union Carbide, this information is located in the repositories maintained by Union Carbide's counsel. INTERROGATORY NO. 52: Has Defendant, any predecessor or any related company, at any time since 1940: (a) been a member of a medical and/or scientific library or library association? (b) been a member of any organization or association which maintained a medical and/or scientific library? (c) been a member of any organization or association through which members obtained the use of, or access to, a medical and/or scientific library? RESPONSE: See General Objections Nos. 1-8. Union Carbide further objects to this Interrogatory on the grounds that it is overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Subject to its objections. Union Carbide responds as follows: See Union Carbide's Response to Interrogatory No. 50, including all objections set forth therein. To the extent that additional information responsive to this Interrogatory is in the possession of Union Carbide, this information is located in the repositories maintained by Union DOCSNYIM0120I8.1 36