Document XzdQj7dnqnDnN5Ogmazx7njrw
subject matter of this lawsuit or which may lead to the discovery of information material to the subject matter of this lawsuit.
ANSWER to Q118.
Defendant objects to this interrogatory because it is
over broad and unduly burdensome. Without prejudice to or waiver
of this objection, see answers to Interrogatories Nos. 1-117,
above. Furthermore, defendant states that discovery in this
matter is ongoing therefore defendant reserves the right to
supplement its answer and will timely identify any witnesses to
plaintiff prior to trial and pursuant to any discovery schedule
ordered by this Court.
Dated:
Buffalo, New York
Yours, etc..
Office and P. 0. Address 1200 Liberty Building Buffalo, New York 14202
TO:
THORTON & EARLY Liaison Counsel for NDAL Plaintiffs 200 Portland Street Boston, Massachusetts 02114
HENDERSON & GOLDBERG Liaison Counsel for NDAL Plaintiffs 1030 5th Avenue Pittsburgh, Pennsylvania 15219
102