Document MJ5pBYEDEBYLGMoyzLEVOXXbz

INTERROGATORY NO. 55.; Have any products you identified in your response to Interrogatory Nos. 52 and 54 not performed as intended? Please list all such products that have not performed as intended. ANSWER: See Answers to Interrogatory Nos. 7, 52 and 54. INTERROGATORY NO. 56.: Did your company or its predecessor(s) or subsidiaries ever make, order, or arrange for any industrial hygiene surveys regarding asbestos or asbestos-containing dust? If so, give the date of such surveys and state who, or what entity, was responsible for completion of such surveys. ANSWER: Abex objects to this interrogatory on the grounds that it is burdensome and overly broad. Abex further objects to the extent this interrogatory seeks information concerning the working conditions of Abex employees, it is objected to on the grounds that such information lacks relevance to this case and is not reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving these objections Abex states, see Answer to Interrogatory No. 8. INTERROGATORY NO. 57.: As to either the threshold limit values or maximum allowable concentrations of asbestos dust and total dust provided by the American Conference of Governmental Industrial Hygienists, state: A. The year in which Defendant or any predecessor(s) or subsidiaries were first advised of such limits or concentrations; B. The name of the employee or official of the company receiving such advice; C. How Defendant received notice of such limits or concentrations. NYM36094. -42-