Document DGeMvYy66R6RGE7MbOVbR544

Abex also 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. Subject to and without waiving these objections, in the mid-1970s, and perhaps earlier. Abex commenced the placement of warning labels on its asbestos-containing automotive friction products. This label read as follows: CAUTION: CONTAINS ASBESTOS FIBERS. AVOID CREATING DUST. BREATHING ASBESTOS DUST MAY CAUSE SERIOUS BODILY HARM. Abex does not believe the wording of this warning was ever changed. INTERROGATORY NO. 65: If your answer to Interrogatory No. 64 is "Yes," identify each and every product upon which such a warning was placed, and with respect to each such product identified: (a) State the date on which any order directing that a warning be placed on said product first issued; (b) Identify any and all persons participating in the decision to issue that order, (c) State the first date on which such warning was actually placed on said product; (d) State the first date on which such product accompanied by such warning was first sold, distributed or installed; (e) State the exact wording of this first warning; (0 State the exact location and size of this first warning as it appeared on said product; (g) Identify any and all persons who participated in any phase of the drafting or design of said first warning, including, but not limited to, those who performed the actual drafting and design work, those who reviewed the work, those who edited the work and those who approved the warning; (h) State why you placed such warning on said product, including, but not limited to, whether you placed such warning on said product because you received a directive, command, suggestion, legal opinion, or any type of communication (written or otherwise) from any person, firm, corporation, governmental agency, committee, association, attorney or institute; and 105