Document MeV3Jre9mXRVw7N8zY0qM1Bk

INTERROGATORY NO. 84: As to any knowledge or information referred to in Interrogatories 79-83, did Defendant, at anytime, educate or inform its employees, distributors, purchasers or any persons working in the vicinity where any asbestoscontaining product was being applied or installed as to the hazards known to Defendant or about which Defendant had information, and as to the safety precautions necessary to guard against cancer and other diseases arising from the use and handling of the products identified in response to Interrogatory No 19? ANSWER TO INTERROGATORY NO. 84: Abex objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, compound, vague and ambiguous and calls for speculation. Abex also objects to this interrogatory on the grounds that the term "any persons" is vague and ambiguous and calls for speculation. Abex further objects to this interrogatory on the ground that it purports to shift the burden of establishing causation from plaintiffs to Abex Abex 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 ground that such information or matenals lack relevance and are not reasonably calculated to lead to the discovery of admissible evidence. To the extent it purports to seek information or materials regarding the working conditions of Abex employees, this interrogatory is also objected to on the grounds that such information or matenals lack relevance to the issues ansing m these cases and are not reasonably calculated to lead to the discovery of admissible evidence Abex further objects to this interrogatory on the grounds that the information or matenals it purports to seek otherwise lack relevance to the issues arising in these cases and are not reasonably calculated to lead to the discovery of admissible evidence