Document VGrgnJ9j7rmZvgnaEKQyrb9Zg

SECOND AMENDED ANSWER TO INTERROGATORY NO. 97: See Objections and Answer to Interrogatory No. 96, which are incorporated by reference as though set forth herein in full. INTERROGATORY NO. 98: Identify any and all documents which Defendant, its predecessor(s) or any related company submitted to, or received from, the organizations listed in response to Interrogatory Nos. 94 and/or 97: (a) which refer to, relate to or reflect the subject of asbestos; (b) which refer to, relate to or reflect a relationship between asbestos exposure and any disease; and/or (c) which refer to, relate to or reflect the placement or providing of warnings with respect to hazardous products. SECOND AMENDED ANSWER TO INTERROGATORY NO. 98: Abex objects to this interrogatory on the grounds that it is over 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 on the grounds that the information or materials it purports to seek lack relevance to the issues arising in these cases and are not calculated to lead to the discovery of admissible evidence. To the extent it purports to seek information or materials regarding the working conditions of Abex employees, this interrogatory is further objected to on the grounds that such information or materials lack relevance to the issues arising in these cases and are not reasonably calculated to lead to the discovery of admissible evidence. Abex objects to this interrogatory to the extent to which it purports to seek information or materials that have been gathered, received, or prepared in the course of litigation, or which are 172