Document Yj2jdqYaVBbmO6bkMdmNkxLVK

b. member of the families of workers; If your answer is "yes", state what that knowledge is and when it was received. ANSWER TO INTERROGATORY NO. 28: Abex objects to this interrogatory on the grounds that it fails to distinguish among the different types of raw asbestos fiber, asbestos- containing building products and asbestos-containing automotive friction products. Abex further objects to this interrogatory on the grounds that it seeks a medical opinion which Abex is not qualified to render. This interrogatory is more suitably addressed to an expert witness Abex will designate at the appropriate time. Abex further states that because the asbestos in Abex's asbestos-containing automotive friction products is resin-bonded and encapsulated, it did create or contribute to a health hazard. 29. Have you ever conducted or financed any studies of the dust levels of asbestos produced when your asbestos products were used, installed or removed from a prior installation. a. whether or not you have conducted such studies state whether you ever considered doing so and for each such occasion when such consideration was given, state the date, form, and results of each such consideration. b. if the consideration occurred at a meeting, the names and present business and home addresses of those attending; c. the location and identity of any records of such considerations. ANSWER TO INTERROGATORY NO. 29: To the best of current knowledge and belief, no. 30. State the names and addresses of all professional, trade, industrial and safety, hygiene, health -23-