Document Exm84j9Kwm0yMBe16p0OnmY54

cases and are not reasonably calculated to lead to the discovery of admissible evidence. Abex further objects to this interrogatory on the grounds that the information or materials it purports to seek otherwise lack relevance to the issues arising in these cases and are not reasonably calculated to lead to the discovery of admissible evidence. Abex objects to this interrogatory on the grounds that it assumes the truth of matters not established or matters not in evidence. 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. Abex further objects to this interrogatory to the extent to which it purports to seek information or materials that have been gathered, received or prepared in the course of litigation, or which are otherwise subject to the attorhey-client privilege, protected by the attorney workproduct doctrine, the rule protecting materials prepared in anticipation of and/or in connection with litigation, or any other applicable privilege. Subject to and without waiving these objections, and insofar as Abex understands this interrogatory, see Answer to Interrogatory No. 86. -205-