Document ZJ04am9dMJ43BD6Djg27BZ6zZ

INTERROGATORY NO. 86: Did Defendant or any predecessor entity perform, direct to be performed, finance in whole or in part, sponsor in whole or in part or receive the results of, any studies or tests concerning the relationship between asbestos exposure and asbestosis, cancer and/or mesothelioma? ANSWER TO INTERROGATORY NO. 86: Abex objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, compound, vague, ambiguous and speculative. Abex also objects to this interrogatory on the grounds that the term "relationship" is vague and ambiguous and calls f6r speculation. Abex further objects to this interrogatory on the ground that it purports to shift the burden of establishing causation from plaintiffs to Abex Abex objects to this interrogatory to the extent it purports to seek information or matenals regarding time periods and products that are not at issue m these cases, on the ground that such information or matenals lack relevance and are not reasonably calculated to lead to the discovery of admissible evidence To the extent to which it purports to seek information or matenals regarding the working conditions of Abex employees, this interrogatory is also objected to on the grounds that such information or matenals lack relevance to the issues ansing in these cases and are not reasonably calculated to lead to the discovery of admissible evidence Abex further objects to this interrogatory on the grounds that the information or matenals it purports to seek otherwise lack relevance to the issues ansing m these cases and are not reasonably calculated to lead to the discovery of admissible evidence. Abex objects to this interrogatory on the grounds that it assumes the truth of matters not established or matters not m evidence -202-