Document aQvkjnLpMDq51ammRXyQ2L4B

I 7> 1 1957-1977, Chicago, Illinois; (Railroad Products 2 Division ) 3 1974-Present, Salisbury, North Carolina. 4 (b) Please refer to response to subpart (a), above. 5 (c) OBJECTION. Subpart (c) is objected to on the 6 grounds that the subject interrogatories are propounded under the 7 case caption of Lawrence Kane V. Johns-Manville Corporation, 8 etc. , et al. "And All Related Cases." This defendant does not 9 know whcit the phrase "other defendants" refers to and it cer 10 tainly does not know the identity of "all defendants" in all 11 actions maintained by the plaintiff firm. Without waiving said 12 objection, and in the spirit of liberal discovery, this defendant 13 will respond that it has sold friction materials to various vehi 14 cle manufacturers and others. 15 (d) OBJECTION. Subpart (d) is objected to on the 16 grounds that it is overly broad, burdensome, vexatious and har 17 assing. The burden and expense to this defendant to compile the 18 information sought is not outweighed by the questionable evi 19 dentiary value of the information sought. Further, the inter 20 rogatory in its present form requests a compilation or abstract 21 of records which does not exist. Finally, sales records re 22 specting such information have been maintained only since 1976 by 23 Abex Corporation . 24 (e) OBJECTION. Subpart (e) to Interrogatory No. 4 is 25 objected to on the grounds it is vague, ambiguous and unintelli 26 gible with respect to the term "compensation paid." 27 (f) OBJECTION. Subpart (f) is objected to on the n:o 28 grounds that it is. vague, ambiguous and unintelligible with