Document a473jqYRq7kkGgd0aJjReY9Ye

INTERROGATORY NO. 54; Has Defendant, any predecessor or any related company, or any person or entity actmg op behalf thereof, including but not limited to, any insurance company, at any time, conducted any industrial hygiene surveys concerning any product identified m response to Interrogatory No 19, including, but not limited to, surveys concemmg the manufacture, processing, application, installation, use and/or removal of said products? ANSWER TO INTERROGATORY NO. 54: Abex objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, compound, vague and ambiguous and calls for speculation Pursuant to the Court's April 13, 2000 Order, Abex's answer to this interrogatory is limited to the years between 1930 and 1980. Abex also objects to this interrogatory on the grounds that the term "any related company" is vague and ambiguous and calls for speculation Abex further objects to this interrogatory to the extent it purports to seek information or materials regarding time penods, products and medical conditions that are not at issue in these cases, on the grounds 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 workmg conditions of Abex employees, this interrogatory is 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 also objects to this interrogatory on the ground that it assumes the truth of matters not established or matters not m evidence. Abex further objects to this interrogatory on the ground that it is speculative inasmuch as it fails to distinguish among raw asbestos, asbestos contained -128-