Document OE6Zj83dn5Kx9DaJMjxKo5VDe

INTERROGATORY NO. 21: Were any of the products, which were listed in response to Interrogatory No 19 as having been specified, sold, distributed, applied or installed by Defendant, its predecessor or related company(ies), purchased from another company and relabeled for sale or distribution by Defendant, its predecessors or related companies? If so, identify those products, and with respect to each: (a) Identify the company from which Defendant, its predecessor or related company purchased the product; and (b) Identify the company which manufactured the product; and, (c) State the date(s) during which said re-labeled product was sold, distributed or applied. ANSWER TO INTERROGATORY NO. 21: 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 matenals regarding time penods and products 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 Abex further objects to this interrogatory on the grounds that the information or matenals it purports to seek otherwise lack relevance to the issues ansing in these cases and are not reasonably calculated to lead to the discovery of admissible evidence Subject to and without waiving these objections, and insofar as it understands this interrogatory, Abex has not found any documents whereby Abex agreed to rebrand and sell under its own name asbestos-containing brake products manufactured by someone else In addition, see Answer to Interrogatory No 10 -55-