Document Ex1zb48jLwdgzQ57mv3JNRJv0

AA ] INTERROGATORY NO. 1: 2 State the name, present address, and capacity of title of 3 the individual signing these Interrogatories on behalf of the 4 answering defendant. S RESPONSE; 6 A. H. Casey, Jr., Abex Corporation, Six Landmark Square, 7 Stamford, Connecticut 06904, is verifying the answers to inter 8 rogatories . 9 INTERROGATORY NO. 2: 10 Please state the address of your principal place of business 11 and whether you have assumed the assets and/or liabilities of any 12 predecessor corporation or entity. Answer these Interrogatories 13 for each such acquired company which manufactured products con 14 taining asbestos. 15 RESPONSE; 16 OBJECTION. Interrogatory No. 2 is objected to on the 17 grounds that it is overly broad, vague, ambiguous and unintelli 18 gible. Without waiving said objection, and in the spirit of 19 liberal discovery, defendant responds that the American Brake 20 Shoe and Foundry Company, a Delaware Corporation, was incorpo21 rated in 1916. In 1926, The American Brake Shoe and Foundry l 1 22 Company caused to be incorporated a New York Corporation entitled j 23 American Brake Materials Corporation. In 1933, American Brake i 24 Materials Corporation changed its name to American Brakeblok i i i 25 Corporation. In 1937, American Brakeblok Corporation merged with j j ')/. the .American Brake Shoe and Foundry Company and was thereafter ! 27 operated as the American Brakeblok Division of that company. 70 28 III , . I i i i