Document K6rg9pY5GvL5YMpggxBOZ5j12

INTERROGATORY NO. 101: Identify any and all agreements, oral or written, between or among Defendant, any of the other defendants in this lawsuit, any organization, association or other entity including, but not limited to, those identified in your answer to Interrogatory No. 94 and/or any medical or scientific foundations, relating to the standardization of > (a) Specifications for asbestos cloth products; (b) Specifications for paper or burlap bags, or other packaging to be used for the transport and/or storage of asbestos cement, (c) Warning or caution labels to be applied to asbestos products and/or their packaging, cartons, containers, or boxes; (d) Methods of dissemination of public relations information to defendant's purchasers, advertisers, distributors, factory workers, contractors, insulators, users, consumers of asbestos products and/or the general public, (e) Safety equipment and/or protective clothing to be utilized while handling defendant's asbestos products; (f) Medical programs to be offered or sponsored by defendant. ANSWER TO INTERROGATORY NO. 101: Abex objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, compound, vague and ambiguous and calls for speculation. Pursuant to the Court's April 13, 2000 Order, Abex's answer to this interrogatory is limited to the years between 1930 and 1980 Abex also objects to this interrogatory on the ground that it purports to shift the burden of establishing product identification from plaintiffs to Abex. Abex further objects to this interrogatory to the extent it purports to seek information or materials regarding time periods and products that are not at issue in these cases, on the grounds that such information or materials lack relevance and are -234-