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