Document Nzwx750M0zNbxpggv0KZd8vR

1 2 13. Abex objects to this Interrogatory on the fol 3 lowing grounds: 4 1. Burden 5 2. Overly Broad 6 Without waiving these objections, Abex states that invoices in 7 dicating sales of asbestos-containing friction products manu 8 factured by Abex are on file in Virginia for some time beginning 9 in 1976 through 1986 only, and can be made available for inspec 10 tion and copying upon receipt of an appropriate document re 11 quest. Such invoices, for the most part, are arranged numeri 12 cally and chronologically by year, and not by customer, product 13 cr state. 14 14. See Answer to Interrogatory No. 13. 15 15. Abex objects to this Interrogatory on the fol 16 lowing grounds: 17 1. Burden 18 2. Overly Broad 19 3. Lack of Particularity 20 Without waiving these objections, Abex states that some rebrand 21 ing may have taken place; however Abex is without sufficient 22 knowledge and information as to the scope or nature of any such 23 rebranding. 24 16. Abex objects to this Interrogatory on the fol 25 lowing grounds: 26 1. Burden 27 28 i 13-