Document M4wDxbXKnY2pxweGZq4Yy1OxM

INTERROGATORY NO. 21: After releasing for sale, distribution or marketing the products listed in answer to Interrogatories No. 5, did Defendant conduct any tests (either on animals or humans) to determine potential health hazards involved in the use of said materials and/or products? (a) The names of the products tested and the dates of said tests; (b) The name, address, and job classification of each person and/or agency conducting said tests; (c) The results of said tests; (d) Whether, as a result of any tests conducted, any products were removed from the market; (e) The names of all products removed from the market as a result of said tests. RESPONSE TO INTERROGATORY NO. 21: See General Objections. Abex further objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, compound, vague, ambiguous and speculative. Abex further objects to this interrogatory on the ground that the terms "distribution," "tests," "health hazards," "use" and "removed" are undefined or insufficiently defined, and call for speculation. Abex further objects to this interrogatory on the ground that it purports to shift the burden of establishing causation from plaintiffs to the defendant. Abex further objects to this interrogatory to the extent to which it seeks information regarding time periods and products that are not at issue in this case on the ground that such information lacks relevance, and is not reasonably calculated to lead to the discovery of admissible evidence. Abex further objects to this interrogatory on the ground that the information it seeks otherwise lacks relevance to the issues arising in this case, and is not reasonably calculated to lead to the discovery of admissible evidence. -47-