Document RJ6nbyb1mZQbbb12rvwKJK9ka

raw asbestos or a finished product and the date of knowlecge that each of the diseases set out could develop from exposure to asbestos. ANSWER; Abex has never manufactured, sold or distributed any thermal insulation products. 30. If your answer to question 28 as m the affirmative, please explain whether the Threshold Limit Value is based on counts of all particles in the air or just the asbestos fibers m the air. ANSWER: See answer to No. 28. 31. When did defendant know that any governmental or private agency, or other entity, issued guidelines suggesting Threshold Limit Values for exposure to asbestos dust? If ever-. guideline; (a) Identify the agency or entity issuing the verbatim; (b) State the content of the guidelme(s) (c) State the date issued and the date you first knew the purpose of the guideline(s). ANSWER- Abex objects to this interrogatory on the grounds that it is overly broad, assumes facts not yet established and is not reasonably calculated to lead to the discovery of admissible evidence. Without waiving and subject to these objections, Abex is presently unaware of when it first received information concerning Threshold Limit Values. 32. Does the defendant contend that the asbestos products mined, manufactured, produced, processed, compounded, converted, sold, merchandised, supplied, distributed and/or otherwise place in the"stream of commerce by the defendant are not "hazardous substances", as defined in 15 U.S. Code, =1261 -26