Document Rj6mn9eBLXBQKKL5e9Mn60N5v

(j) Janssen & Shaefer - Division of R. A. Cullinan & Sons, Inc. (k) R. A. Cullinan & Sons, Inc., Tremont, IL (l) C. A. Powley & Company, East Peoria, IL RESPONSE: Defendant objects to this interrogatory as over broad to the extent it requests documents for years other than 1960-1975. Plaintiff's deposition reveals that his exposure to asbestos was limited to the arcing of brake shoes, and such work was performed only from the mid sixties through 1975. Defendant further objects to this request in that is unduly burdensome in that it is estimated that at least 2 weeks' work would be re quired to search for the documents requested here, plus costs for reproduction and transportation. Defendant further responds by stating that it currently has such records only for the years 1976 to the present. For prior years it has only summaries which do not reflect in detail the type of products so purchased by Defendant from.any co-defendant. ABEX CORPORATION, Defendant SUBSCRIBED AND SWORN r,0 before me this //L c ay of May, 1983. 7,'V, /L Hv o { !/r Notary Public SWAIN, JOHNSON & GARD ROBERT W. SCOTT 1900 Savings Center Tower 411 Hamilton Boulevard Peoria, Illinois' 61602 (309) 673-0741 6