Document BR8pGJr4gqpJ0n47OkYbngGm4

(b) state when such action was taken; (c) state what written material exists related to such action; (d) state the names, job titles and last known address of the individuals who undertook such actions. RESPONSE TO INTERROGATORY NO. 47.4: See General Objections. Abex further objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, vague, ambiguous and speculative. Objection is also made to this interrogatory on the ground that the terms "minimize," "eliminate," "risk," "occupational disease," "pneumoconiosis," "use," "exposed to the use," "asbestos-containing," "industrial insulation products" and "otherwise exposed" are undefined, and call for speculation. * Abex further objects to this interrogatory on the ground that it purports to shift the burden of establishing causation from plaintiffs to the defendant. Abex further objects to this interrogatory to the extent to which it seeks information regarding time periods and products that are not at issue in this case on 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 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 information that has been gathered, received or prepared in the course of the asbestos litigation, or which is otherwise subject to the attorney-client privilege, the attorney work-product doctrine. -88-