Document N2LBa4LbX1pLV4ajoRMq0O5vQ

INTERROGATORY NO. 96: Did any officer, employee, agent or representative of Defendant, of any predecessor, or of any related company, serve, at any time, as: (a) an officer, director or official of any trade organization, association or entity identified in response to Interrogatory No. 94? (b) a member of any committee or subcommittee of any trade organization, association or entity identified in response to Interrogatory No. 94? (c) the chair of any committee or subcommittee of any trade organization, association or entity identified in response to Interrogatory No. 94? (d) the representative or liaison for any trade organization, association or entity identified in response to Interrogatory No. 94 to any other trade organization, association or entity, including, but not limited to, A.T.I, I.H.F., N.LM.A, AIA, N.I.C.A, T.I.M.A, Q.A.MA., N.A.C. N.S.C, A.C.S., N.B.M.D.A., N.I.A., S.M.F.M.A.? ANSWER TO INTERROGATORY NO. 96: Abex objects to this interrogatory on the grounds that it is over broad, unduly I 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 on the grounds that the information or materials it purports to seek lack relevance to the issues arising in these cases and are not 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 objected to on the grounds that such information or materials lack relevance to the issues -223-