Document Ra2x0Kqzgyq8gv0vDkmy1N4y8

7. What is the name, address and job title of each individual who participated in the design and preparation of manufacturing specifications for each such product listed in response to Interrogatory No. 5 to Plaintiff's First Set of Interrogatories? ANSWER: Abex objects to this interrogatory on the grounds that it is hopelessly overly broad and burdensome. Abex further objects on the grounds that, in seeking information concerning products to which the plaintiff does not-allege her decedent was e>q5osed, this interrogatory lacks relevance to this case and is not reasonably calculated to lead to the discovery of admissible evidence. 8. As to ea^n product listed in response to Interrogatory No. 5 to Plaintiff's First Set of Interrogatories, please describe how each product was to be cut, shaped, scribed, mixed and applied on the job. (In answering this question, give particular reference as to whether or not the materials were to be sawed, cut, or ground on the job.) ANSWER: Abex objects to this interrogatory on the grounds that it is overly broad, burdensome .and assumes facts not established. Abex further objects on the grounds that, in seeking information concerning products to which, the plaintiff does not allege her decedent was exposed, this interrogatory lacks relevance ifb this case and is not reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving these objections, Abex's asbestos-containing automotive friction Darts were generally sold in ready-to-use font. 9. Based upon the material contents of your asbestoscontaining brake lining products, the method of manufacturing, and the method of application, please state which of your asbestoscontaining brake lining products as listed in Interrogatory No. 5 to Plaintiff's First Set of Interrogatories could be applied by a worker without creating dust. NYIC0419 7- -