Document R2JggBJaX5pZeexEQOobeV2Vv

INTERROGATORY NO. 65: If your answer to Interrogatory No 64 is "Yes," identify each and every product upon which such a warning was placed, and with respect to each such product identified' (a) State the date on which any order directing that a warning be placed on said ---------- product, first-issued;___________________________________________________ (b) Identify any and all persons participating in the decision to issue that order; (c) State the first date on which such warning was actually placed on said product; (d) State the first date on which such product accompanied by such warning was first sold, distributed or installed; (e) State the exact wordmg of this first warning; (f) State the exact location and size of this first warning as it appeared on said product; (g) Identify any and all persons who participated in any phase ofthe drafting or design of said first warning, including, but not limited to, those who performed the actual drafting and design work, those who reviewed the work, those who edited the work and those who approved the warning, 00 State why you placed such warning on said product, mcluding, but not limited to, whether you placed such warning on said product because you received a directive, command, suggestion, legal opinion, or any type of communication (written or otherwise) from any person, firm, corporation, governmental agency, committee, association, attorney or institute, and (i) Identify any and all documents referring to, relatmg to or reflecting, said warning, its drafting, and/or the decision to place the warning on said product, includmg, but not limited to, any communication as described m subpart (h) of this interrogatory ANSWER TO INTERROGATORY NO. 65: Abex objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, compound, vague and ambiguous and calls for speculation -151-