Document QXZQLY8wM2VnVLX74ae8dd198

f j / j to seek lack relevance to the issues arising in these cases and are not calculated to lead to the discovery of admissible evidence. Abex also objects to this request on the ground that plaintiffs do not allege plaintiffs and/or plaintiffs' decedents were employees of Abex or ever present at any Abex facility. Abex further objects to this request on the ground that it assumes the truth of matters not established or matters not in evidence. Abex objects to this interrogatory on the ground that it is speculative inasmuch as it fails to distinguish among raw asbestos, asbestos contained in building insulation products and/or asbestos-containing automotive friction products, and/or among the different types of asbestos fibers. Because the asbestos fiber contained in Abex's asbestos-containing automotive friction products was chrysotile, the only type of asbestos Abex ever used for product production, which was resin-bonded and encapsulated, proper use of such products did not create or contribute to any adverse health effects. Abex also objects to this request to the extent to which it purports to seek information or materials that have been gathered, received or prepared in the course of litigation, or which are otherwise subject to the attorney-client privilege, protected by the attorney work-product doctrine, the rule protecting materials prepared in anticipation of and/or in connection with litigation, or any other applicable privilege. Abex further objects to this request to the extent to which it purports to seek medical records or privileged personnel information, which Abex will not provide absent an appropriate waiver of the applicable privilege. -209-