Document Rj1E3yeYX4Od1jJkQ7O7yeQyv

INTERROGATORY NO. 123: If your answer to Interrogatory No 122 is "Yes," then with respect to each such inspection, test or survey. (a) Identify the governmental entity conducting the same; (b}---State-the dates(s).Qt^wl^chAe-sajm-was^oMucled;----- _.--. .. .. (c) Describe the nature of the inspection, test or survey including, but not limited to, the results or conclusions thereof; and (d) Identify any and all documents referring to, relating to or reflecting the same ANSWER TO INTERROGATORY NO. 123: Abex objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, compound, vague and ambiguous and calls for speculation Pursuant to the Court's April 13, 2000 Order, Abex's answer to this interrogatory is limited to the years between 1930 and 1980 Abex also objects to this interrogatory to the extent it purports to seek information or matenals regarding time periods, products and medical conditions that are not at issue m these cases, on the grounds that such information or matenals 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 in evidence. -277-