Document N7vVmvMjOxoNMEL7jXmZZ8JR

existing business records and documents of Abex, which number in excess of three million, are preserved in the order in which they were found. There was never a central corporate filing system of Abex documents and there is no Abex employee who has personal knowledge of all the information contained in all the documents. Abex will respond to this interrogatory by making available for r? inspection and copying relevant, responsive, non-privileged ;> documents'. These documents will be made available through Abex counsel at a mutually convenient time and at a location conducive to production. (d) Asbestos-containing automotive brake lining, manufactured by Abex were shaped into curved, linear segments in such dimensions as required by the specifications, characteristics and uses established by the manufacturer of the vehicle or the equipment on which the lining was applied. (e) Abex friction products specifically, its brake linings, are generally designed to assist in the stopping or control of a moving object. (f) Asbestos-containing automotive friction products manufactured and sold by Abex were generally packaged in cardboard boxes according^to: size. The brand name appeared" on the package as did the product name. Abex further states that in the mid-1970's-at the^latest, and perhaps earlier, Abex commenced the placement of warning labels on its asbestos-containing automotive friction products. This label reads as follows: NY1-90895. 04/20/95 SilBpm Caution Contains Asbestos Fibers Avoid Creating Dust 19