Document Jrp0n5x8ExdmvnEB7019q8pK2

INTERROGATORY NO. 30.2 Has Defendant, or any engineer, industrial hygienist or physician in Defendant's employ, been a member in any professional group, trade group or any of the following groups: American Ceramics Society Asbestos Textile Institute National Insulation Manufacturers Association Thermal Insulation Manufacturers Association Quebec Asbestos Mining Association Asbestos Information Association Industrial Health Foundation Industrial Hygiene Foundation Iron and Steel Institute National Safety Counsel Refractories Institute Air Hygiene Foundation of America, Inc. Sprayed Mineral Fiber Association American Society of Mechanical Engineers If the answer is yes, state the following: (a) The name of the group or groups in which Defendant or individual(s) were members; (b) The name and position individual(s) within the Defendant, as defined, who were members; (c) The years Defendant or individual(s) were members of the groups; (d) Whether Defendant paid the individuals) dues or membership fees or reimbursed the individual(s) for dues or membership fees in the group. RESPONSE TO INTERROGATORY NO. 30.2: See General Objections. Abex further objects to this interrogatory on the grounds that it is overly broad, unduly burdensome and compound. Abex further objects to this interrogatory on the ground that it purports to shift the burden of establishing causation from plaintiffs to the defendant. -61-