Document OE3ZEkdzL7N0BRZ1b5ZpbDGGM

litigation, or any other applicable privilege. Subject to and without waiving these objections, and insofar as Abex understands this interrogatory, yes. INTERROGATORY NO, 5S: Ifyour answer to Interrogatory No. 54 "Yes," with respect to each such survey: (a) Identify the produces) which was used in the survey; (b) Identify any and all person(s), firm(s) or entity(ies) conducting or participating in the conducting of said survey; (c) State the date(s) of said survey; (d) Describe the methodology, results and conclusions of said survey; (e) Identify any and all documents referring to, relating to, or reflecting said survey or the results and conclusions thereof; and, (f) Identify any and all persons to whom such document may have been sent. SECOND AMENDED ANSWER TO INTERROGATORY NO. SS; 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 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 grounds that such information or materials lack relevance and are not reasonably calculated to lead to the discovery of admissible evidence. Abex further objects to this interrogatory oh the grounds that the information or materials it purports to seek lack relevance to the issues arising in these cases and are not reasonably calculated to lead to the discovery of admissible evidence. Abex objects to this interrogatory to the extent to which it purports to seek information or 89