Document VJjXkeG047G8rbQr2MakL1Vqw

(j) The records retention policies concerning claims of the kinds specified in Part (a) of the defendant, and of any state agencies of which the defendant has knowledge in states where the defendant does business, and to which the defendant supplies information concerning claims of this kind. Also include any federal agencies which would receive notice directly or in the defendant's knowledge indirectly as a matter of the ordinary business of the federal government concerning claims of the aforementioned kind; (k) The disposition of said claim(s) including benefits paid or settlements reached or moneys voluntarily paid by your insurers, if any; (l) The last know address of the attorney representing the Claimant, if any. AMBWER TO INTERROGATORY NO. 36: Abex objects to this interrogatory on the grounds that it is overly broad, burdensome, and, in seeking information concerning Abex employees, lacks relevance to this case and is not reasonably calculated to lead to the discovery of admissible evidence. Abex further states that it never engaged any "contract units." 37. Have you ever been named as a party in any action for workmen's compensation benefits for injury, occupational disease, or death by any of your employees or their estates, or by any persons working as independent contractors for you or under your direction or their estates, or by any directors, managers, or persons involved on a casual labor or occasional worker independently contracted for basis in "contract units" operated by you or their estates where the disease, injury or death was asserted by the Plaintiff and/or claimant in the action to be based in whole or in part on the diseases; asbestosis, emphysema, chronic bronchitis, pulmonary fibrosis, dyspnea, carcinoma of the lungs, or mesothelioma and where the plaintiff and/or claimant in the course of his work experience used, handled, fabricated, installed, removed, mixed, cut, packed or transported asbestos products containing any percentage whatsoever of asbestos? If so, state as to each claim: (a) The identity of the Plaintiff and/or claimant and the disease(s) or injury(s) on which the action was premised; -28-