Document XzkLaLa8kw0keLJq5Lba5yBGK

2. Lack of Particularity Without waiving these objections, see Answer to Interrogatory No. 10(i). 27. Abex objects to this Interrogatory on the fol lowing grounds: 1. Burden 2. Overly Broad Without waiving these objections, Abex states that invoices rhich may or may not indicate sales to plaintiff's jobsites are 11 jn file in Virginia for some time beginning in 1976 through 1986 12 mly, and can be made available for inspection and copying upon 13 receipt of an appropriate document request. Such invoices, for 14 :he most part, are. arranged numerically and chronologically by 15 ^ear, and not by customer, product or state. 16 28. Abex objects to this Interrogatory on the fol 17 lowing grounds: 18 1. Burden 19 2. Overly Broad 20 Without waiving these objections, Abex states that it is without 21 sufficient knowledge and information as to each person, if any, tfhose job duty may have included selling asbestos-containing products manufactured by Abex to plaintiff's jobsites. DATED: September 16, 1986 SULLIVAN, ROCHE ^JOHNSON ROBERT E. PATERSON Attorneys for Abex Corporation -16-