Document bB1wyJK5KxkKNp18Z8Qjkv4jo

INTERROGATORY NO. 12: Has Defendant ever acquired from another corporation, company, or business, by any means other than those specified in Interrogatory No. 10, assets or rights to manufacture, sell, distribute or apply asbestos or asbestos-containing products? ANSWER TO INTERROGATORY NO. 12: 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 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 grounds that such information or materials lack relevance and are not reasonably calculated to lead to the discovery of admissible evidence. Abex further objects to this interrogatory to the extent to which it purports to seek information or materials that have been gathered, received or prepared in the course of litigation, or which are otherwise subject to the attorney-client pnvilege, protected by the attorney workproduct doctrine, the rule protecting materials prepared m anticipation of and/or m connection with litigation, or any other applicable pnvilege Subject to and without waiving these objections, and insofar as it understands this interrogatory, Abex discontmued the manufacture and sale of asbestos-containing friction products in 1987 and no longer operates any friction product manufactunng facilities. There are no current Abex employees, officers who worked for Abex, or directors who sat on its Board during the penod Abex manufactured and sold friction products with personal knowledge of the information contained m all the records and documents that might be responsive to this interrogatory. -27-