Document Gz5nzJ3Q1v4vaBky5Ep0O0zrv

materials lack relevance to the issues arising in these cases and are not reasonably calculated to lead to the discovery of admissible evidence. 1 Abex also objects to this interrogatory on the ground that it assumes the truth of matters not established or matters not in evidence. Abex objects to this interrogatory on the ground that it is speculative inasmuch as it fails to distinguish among raw asbestos, asbestos contained in building insulation products and/or asbestos-containing automotive friction products, and/or among the different types of asbestos fibers. Because the asbestos fiber contained in Abex's asbestos-containing automotive friction products was chrysotile, the only type of asbestos Abex ever used for product production, which was resin-bonded and encapsulated, proper use of such products did not create or contribute to any adverse health effects. 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 work- product doctrine, the rule protecting materials prepared in anticipation of and/or m connection with litigation, or any other applicable pnvilege. Subject to and without waiving these objections, and insofar as Abex understands this interrogatory, see Answer to Interrogatory Nos. 36, 42, and 43.