Document DdgN5OvK4zrLjx4JgrRD3pXdM

is not defined and Abex cannot answer this interrogatory absent such definition. 38. If you or your insurance carrier have ever paid out money voluntarily, or by agreement, or in settlement, on a claim for the following diseases; asbestosis, emphysema, chronic bronchitis, pulmonary fibrosis, dyspnea, carcinoma of the lungs, or mesothelioma between the years 1930 and 1978, specify for each instance: (a) The amount paid out; (b) Who paid it; (c) Who received the payment; (d) The date of the payment(s); (e) Whether, if agreement went on file with any administrative body, and if so, filing; it was an agreement, the court, agency, or the date and location of the (f) The current location of any document(s) evidencing such voluntary payment, and the name, and address of their present custodian, and the time and place where counsel for plaintiff may examine and copy such document(s). ANSWER: Abex objects to this interrogatory on the grounds that it is overly broad as to time, burdensome, irrelevant to this case and not reasonably calculated to lead to the discovery of admissible evidence. 39. If you or your insurance carrier have ever paid out money, voluntarily, or by agreement, or in settlement to any employee contractor, contract unit worker, contract unit manager, or casual, or incidental laborer for a claim based on the following diseases; asbestosis, emphysema, chronic bronchitis, pulmonary fibrosis, dyspnea, carcinoma of the lungs, or mesothelioma, state as to each recipient of such funds: -33-