Document aq9e15dzakLYqOkNnDJRrJre

INTERROGATORY NO. 68: Prior to the date on which Defendant first directed that a warning accompany any product identified in response to Interrogatory Nos. 19 and 42, did any person, firm, organization or other entity, within or without your employ, suggest, recommend, counsel, advise, or otherwise indicate in any manner, that a warning should accompany any or all of such products or asbestos-containing products generally?____________ ANSWER TO INTERROGATORY NO. 68: Abex objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, compound, vague and ambiguous and calls for speculation. Abex also objects to this interrogatory on the ground that it purports to shift the - burden of establishing causation from plaintiffs to Abex Abex further objects to this interrogatory to the extent it purports to seek information or materials regarding time penods 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 Abex objects to this interrogatory on the grounds that the information or materials it purports to seek otherwise 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 grounds that it assumes the truth of matters not established or matters not in evidence Abex further objects to this interrogatory on the ground that it seeks to impose upon Abex a legal duty or obligation to which it was not subject. Abex discontinued the manufacture and sale of asbestos-containing friction products m 1987 and no longer operates any friction product manufacturing facilities There are no current Abex employees, officers who worked for Abex, or directors who sat on its Board