Document YG1dDGjObwrLBqXwbNkDjenLn

(e) A list of all asbestos-containing products that you sold to each location from 1945 to 1980. (f) The amount of each asbestos product sold to each location during this period. (g) Please identify all documents relating to this distributor for the particular location. RESPONSE TO INTERROGATORY NO. 8: See General Objections. Abex further objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, compound, vague and ambiguous. Objection is made to this interrogatory on the ground that the terms "distributed," "packaged," "labeled," "distributors," "location" and "this distributor" are undefined or insufficiently defined, and call for speculation. Abex further objects to this interrogatory on the ground that it purports to shift the burden of establishing product identification from plaintiffs to Abex. Abex further objects to this interrogatory to the extent to which it seeks information regarding time periods, products and work sites that are not at issue in this case on the ground that such information lacks relevance, and is not reasonably calculated to lead to the discovery of admissible evidence. Abex further objects to this interrogatory on the ground that the information it seeks otherwise lacks relevance to the issues arising in this case, and is not reasonably calculated to lead to the discovery of admissible evidence. Abex further objects to this interrogatory on the grounds that it is over broad, oppressive, harassing and otherwise unduly burdensome, and calls for speculation to the extent that it requests information which is not within the personal knowledge, possession or control of Abex, its employees or agents, or which may be ascertained or derived, if at all, only from a page-bypage review of the existing voluminous business records and documents of Abex. Abex's -21-