Document Zrn51vorbm1B146aQgDe5ox0

INTERROGATORY NO. 85: If your answer to Interrogatory No. 84 is `Yes," identify each such occasion on which Defendant so educated or informed its employees, distributors or purchasers, as follows: (a) Identify the persons or parties which you educated or informed; (b) State when, where and in what manner they were educated or informed; (c) Identify any and all documents referring to, relating to or reflecting the communication or other dissemination of such information; and (d) Identify any and all persons who so educated or informed said employees, distributors, purchasers or persons working in the vicinity of application or who participated in the same in any way including, but not limited to, assembling, drafting, writing, rewriting, preparing or conveying such information in any format. ANSWER TO INTERROGATORY NO. 85: Abex objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, compound, vague and ambiguous and calls for speculation, j Abex also objects to this interrogatory on the grounds that the term "such occasion" is vague and ambiguous and calls for 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 materials regarding time periods and products that are not at issue in these cases, on the ground that such information or materials lack relevance and are not reasonably calculated to lead to the < discovery of admissible evidence. To the extent it purports to seek information or materials regarding the working conditions of Abex employees, this interrogatory is also objected to on the grounds that such information or materials lack relevance to the issues arising in these cases and are not reasonably calculated to lead to the discovery of admissible evidence. Abex further -197-