Document DGaGrY1Gp5gBXwjQ1qggKk4j5

discovery of admissible evidence To the extent to which it purports to seek information or materials regarding the working conditions of Abex employees, this interrogatory is also objected to on the grounds that such information or materials lack relevance to the issues arising in these cases and are not reasonably calculated to lead to the discovery of admissible evidence Abex further objects to this interrogatory on the grounds that the information or matenals it purports to seek otherwise lack relevance to the issues arising m these cases and are not reasonably calculated to lead to the discovery of admissible evidence. Abex objects to this interrogatory on the grounds that it assumes the truth of matters not established or matters not in evidence. Abex also objects to this interrogatory on the ground that it is speculative inasmuch as it fails to distinguish among raw asbestos, asbestos contained in building insulation products and/or asbestos-containing automotive friction products, and/or among the different types of asbestos fibers. Because the asbestos fiber contained in Abex's asbestos-containing automotive friction products was chrysotile, the only type of asbestos Abex ever used for product production, which was resin-bonded and encapsulated, proper use of such products did not create or contribute to any adverse health effects. Abex further objects to this interrogatory on the ground that it seeks to impose upon Abex a legal duty or obligation to which it was not subject. Abex objects to this interrogatory to the extent to which it purports to seek information or matenals that have been gathered, received or prepared in the course of litigation, or which are otherwise subject to the attorney-client pnvilege, protected by the attorney work- -242-