Document MoRLXqEo2VEDoqpgvpdvK4VdV

) ^^TERROGATORY NO. 54: Has Defendant, any predecessor or any related company, or any person or entity acting oq behalf thereof, including but not limited to, any insurance company, at any time, conducted any industrial hygiene surveys concerning any product identified in response to Interrogatory No. 19, including, but not limited to, surveys concerning the manufacture, processing, application, installation, use and/or removal ofsaid products? ANSWER TO INTERROGATORY NO. 54: 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 grounds that the term "any related company" is vague and ambiguous and calls for speculation Abex further objects to this interrogatory to the extent it purports to seek ^ ^^prmation or matenals regarding time penods, products and medical conditions that are not at issue in these cases, on the grounds 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 matenals regarding the working conditions of Abex employees, this interrogatory is objected to on the grounds that such information or matenals lack relevance to the issues ansing in these cases and are not reasonably calculated to lead to the discovery of admissible evidence. Abex also objects to this interrogatory on the ground that it assumes the truth of matters not established or matters not in evidence. Abex further objects to this interrogatory on the ground that it is 'oeculative inasmuch as it fails to distinguish among raw asbestos, asbestos contained -128-