Document G0B4vyk6bDbvr0Jr1voXoVj7

automotive friction products was chrysotile, the only type of asbestos Abex ever used for product production, which was resm-bonded and encapsulated, proper use of such products did not create or contribute to any adverse health effects. Abex 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 also objects to this interrogatory to the extent to which it purports to seek information or materials that have been gathered, received or prepared m the course of litigation, or which are otherwise subject to the attorney-client privilege, protected by the attorney workproduct doctrine, the rule protectmg matenals prepared in anticipation of and/or in connection with litigation, or any other apphcable privilege Subject to and without waiving these objections, and insofar as it understands this interrogatory, Abex discontinued the manufacture and sale of asbestos- containing friction products m 1987 and no longer operates any friction product manufacturing facilities. There are no current Abex employees, officers who worked for Abex, or directors who sat on its Board during the period Abex manufactured and sold friction products with personal knowledge of the information contamed m all the records and documents that might be responsive to this interrogatory Upon information and belief, Lloyd Hamlin, medical director of Abex, attended a symposium at the Trudeau Institute in 1952, at which asbestos was publicly discussed before an audience of medical experts and public officials from around the world. -248-