Document Em6B65nQDgDdY2OJwRXj57dzn

When a plaintiff avails himself or herself of the offer to inspect the documents, Abex will remove any documents with respect to which it claims privilege, on a box-by-box basis, and will prepare and serve a privilege log on plaintiffwithin sixty (60) days after the last date upon which the documents were inspected. Any dispute as to the propriety of any objection can thereafter be resolved by the Court.INTERROGATORY NO. 131: From 1940 to present, state whether Defendant and/or predecessor or related company ever provided workers' compensation health, accident and disability and/or life insurance coverage for its employees, and if so: (a) Withdrawn by plaintiffor stricken by the Court; (b) State whether such insurance carriers) ever conducted any dust counts or studies, industrial hygiene surveys or other tests relating to any asbestos-containing products that Defendant's employees may have been working with or around; and, (c) If you response to subpart (b) hereof is in the affirmative, please indicate the date ofeach such count, study, survey or other test and identify all documents relating thereto. SECOND AMENDED ANSWER TO INTERROGATORY NO. 131: Abex objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, compound, vague and ambiguous and calls for speculation. Pursuant to the Court's April 13,2000 Order, Abex's answer to this interrogatory is limited to the years between 1930 and 1980. Abex also objects to this interrogatory to the extent it purports to seek information or materials regarding time periods and products that are not at issue in these cases, on the grounds that such information or materials lack relevance and are not reasonably calculated to lead to the discovery of admissible evidence. To the extent it purports to seek information or materials regarding the working conditions of Abex employees, this interrogatory is further objected to on 226