Document EqwVY7JyKaeRakGZ8m3Z51oeN

INTERROGATORY NO. 121: If your answer to Interrogatory No. 120, is "Yes," with respect to each such violation (a) Withdrawn by plaintiff or stricken by the Court. ______ (b) State the date of the citation, warning, fine, sanction or write-up;_________ (c) Describe the violation and state the date(s) during which it occurred; (d) Identify the statute, law, rule, ordinance, code or order to which it occurred; (e) State what, if any, specific fine, penalty, or sanction was imposed; (f) State the date in which and the manner in which said violation was corrected; (g) Identify any and all officials of Defendant, its predecessor or its related company having knowledge or notice of said violation and state the date on which said knowledge or notice was received; and (h) Identify any and all documents referring to, relating to or reflecting said violation. ANSWER TO INTERROGATORY NO. 121: Abex objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, vague and ambiguous. 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 on the grounds that the information or matenals it purports to seek lack relevance to the issues arising in these cases and are not calculated to lead to the discovery of admissible evidence To the extent it purports to seek information or matenals regarding the working conditions of Abex employees, this interrogatory is further objected to on the grounds that such information or matenals lack relevance to the -270-