Document JrJXJ4oaGjnxg90vrbZ4bza7Z

SUPREME COURT OF THE STATE OF NEW YORK EIGHTH JUDICIAL DISTRICT 1 * -- c. l) ACT-T; l-V.\:CG01/-!G$ KAY 1 5 2007 IN RE: EIGHTH JUDICIAL DISTRICT ASBESTOS LITIGATION EJDAL MASTER FILE cfSlc liUHTf*\rJ` MASTER INDEX NO. H-95716 OFFICE This Document Applies to All Cases ANSWERS OF PNEUMO ABEX LLC, SUCCESSOR IN INTEREST TO ABEX CORPORATION, TO PLAINTIFFS' FIRST STANDARD SET OF LIABILITY INTERROGATORIES PRELIMINARY STATEMENT AND GENERAL OBJECTIONS Defendant Pneumo Abex LLC, successor in interest to Abex Corporation (hereinafter "Abex"), by and through its attorneys of record. Smith Abbot, L.L.P., hereby responds to these interrogatories, as follows: 1. Abex objects to these interrogatories on the grounds that they are overly broad, unduly burdensome, compound, vague and ambiguous and call for speculation. 2. Abex also objects to these interrogatories on-the grounds that they are premature, argumentative, oppressive, harassing, duplicative, repetitive and complex. 3. Abex fiirther objects to these interrogatories on the ground that they puiport to shift the burden ofestablishing product identification from plaintiffs to Abex.4. Abex objects to these interrogatories on the ground that they purport to shift the burden of establishing causation from plaintiffs to Abex. 5. Abex also objects to these interrogatories on the grounds that they are compound, contain numerous terms that are vague and ambiguous and call for speculation. 6. Abex further objects to these interrogatories to the extent they purport to seek information or materials unrelated to Abex's alleged liability in these actions and are not SCF-EC-6025