Document 9JZqO4jbkjXKmNkvDorvNzEOD

INTERROGATORY NO. 34.: Does Defendant or any of its subsidiaries or predecessor currently have possession of any writings or contracts on those rebranding agreements set forth in the answer to Interrogatory No. 32? If the answer is affirmative, state: A. The name, address, and job title of each person having custody of each of those documents and their current location. B. A brief description of each such document including the dates and the parties signatory. ANSWER: See Answers to Interrogatory Nos. 33 and 7. INTERROGATORY NO 35.: Prior to 1968, did any person file a claim against a Worker's Compensation carrier covering Defendant or any of its subsidiaries or predecessors alleging that he/she contracted a disease from inhaling asbestos fibers? if so, provide: A. A list of the claims, including each claimant's name, address and the date each claim was filed, and including the caption and jurisdiction of the claim. B. The disease alleged in each such claim. C. A brief summary of the disposition of each such claim. D. The name, address and title of the person having custody of the records pertaining to each such claim. ANSWER: Abex objects to this interrogatory on the grounds that it is overly broad, burdensome, and, in seeking information regarding Abex employees, lacks relevance to this case and is not reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving these objections Abex states that Abex is not aware of any pre-1968 claims fitting such a description. NY1-I36094. -30-