Document R2dJ5Dx0xqn4bvxLknVpaog2a

Abex also objects to this interrogatory on the ground that it seeks to impose upon Abex a legal duty or obligation to which it was not subject. Abex further objects to this interrogatory to the extent to which it purports to seek information or materials that have been gathered, received or prepared m the course of litigation, or which are otherwise subject to the attorney-client privilege, protected by the attorney workproduct doctrine, the rule protecting materials prepared m anticipation of and/or in connection with litigation, or any other applicable privilege Subject to and without waiving these objections, and insofar as it understands this interrogatory, Abex is generally aware that it contributed momes for certain studies at the Saranac Laboratory, Saranac, New York Abex's documents reflect that any such studies performed by the Saranac Laboratory on behalf of Abex specifically pertained to siderosis and silicosis studies Plaintiffs' counsel in a different case have produced in discovery unauthenticated photocopies of documents purporting to show that Abex agreed m the 1930's to pay $250 per year for three years with respect to a single asbestos-related animal study at the Saranac Laboratory Abex's records do not confirm any such agreement, nor do Abex's records reflect any such payment -139-