Document Ra1kzz11qnqEE7y4VzgjRbjzv

INTERROGATORY NO. 55: If your answer to Interrogatory No 54 "Yes," with respect to each such survey. (a) Identify the product(s) which was used in the survey, (b) Identify any and-all person(s), firm(s) or entity(ies) conducting or participating in the conducting of said survey; (c) State the date(s) of said survey; (d) Describe the methodology, results and conclusions of said survey; (e) Identify any and all documents referring to, relating to, or reflecting said survey or the results and conclusions thereof; and, (f) Identify any and all persons to whom such document may have been sent ANSWER TO INTERROGATORY NO. 55: 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 materials regarding time periods, products and medical conditions that are not at issue in these cases, on the grounds that such information or materials lack relevance and are not reasonably calculated to lead to the discovery of admissible evidence To the extent it purports to seek information or matenals regarding the working conditions of Abex employees, this interrogatory is further objected to on the grounds that such information or matenals lack relevance to the issues ansing in these cases and are not reasonably calculated to lead to the discovery of admissible evidence Abex objects to this interrogatory on the ground that it assumes the truth of matters not established or matters not m evidence -130-