Document Z4qEYonBmbeZ9w652qmJ5gJo8

Abex further objects to this request 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, see objections and response to Request For Production No. 1, above. REQUEST FOR PRODUCTION NO. 32: Please produce a true and correct copy of all documents referring, relating or pertaining to the Quebec Asbestos Mining Association (QAMA) in the custody, possession or control of this Defendant. RESPONSE TO REQUEST FOR PRODUCTION NO. 32: See General Objections. Abex further objects to this request on the grounds that it is overly broad, unduly burdensome and speculative. Abex further objects to this request on the ground that it purports to seek information about entities other than Abex. Abex further objects to this request on the ground that it purports to shift the burden of establishing causation from plaintiffs to Abex. Abex further objects to this request 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 request 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. -35-