Document XzzONjLMVY7e3JzzRryjdxryJ

Saranac Laboratory. Abex records do not confirm any such agreement, nor do Abex records reflect any such payment. INTERROGATORY NO. 36: When was Defendant first aware of reports of studies of the Trudeau Foundation at Saranac Lake, New York, entitled "Effects of the Inhalation of Asbestos Dust in the Lungs of Asbestos Workers" by A.J. Lanza, Assistant Medical Director published in the J. Public Health Report, Vol. 50, No. 1, dated January 4,1935 ("Lanza Report")? RESPONSE TO INTERROGATORY NO. 36: See General Objections. Abex further objects to this interrogatory on the grounds that it is overly broad, unduly burdensome and speculative. Abex further objects to this interrogatory on the ground that it purports to shift the burden of establishing causation from plaintiffs to the defendant. Abex further objects to this interrogatory on the ground that the information it seeks lacks relevance to the issues arising in this case, and is not calculated to lead to the discovery of admissible evidence. Abex further objects to this interrogatory on the ground that it assumes the truth of matters not established or matters not in evidence. Abex further objects to this interrogatory to the extent to which it purports to seek information that has been gathered, received or prepared in the course of the asbestos litigation, or which is otherwise subject to the attorney-client privilege, the attorney work-product doctrine, the rule protecting materials prepared in anticipation of and/or in connection with litigation, or any other applicable privilege. Subject to and without waiving these objections, Abex does not know when, if ever, its management became aware of the above-referred article. -70-