Document bBkLDj0QzdX6zxx3RQ0N9NamO

requests knowledge, information or materials which are not within the personal possession or control of Abex, its employees or agents, or which may be ascertained or derived, if at all, only from a page-by-page review of the existing voluminous business records and documents of Abex. t Subject to and without waiving these objections, Abex ceased the manufacture and sale of its asbestos-containing automotive friction products in 1987. See also objections and response to Interrogatory No. 8, above. INTERROGATORY NO. 14: What is the name, address and job title of each individual who participated in the design and preparation of manufacturing specifications for each such product listed above in answer to Interrogatory No. 5? RESPONSE TO INTERROGATORY NO. 14: See General Objections. Abex further objects to this interrogatory on the grounds that it is overly broad and unduly burdensome. Abex further objects to this interrogatory on the ground that the term "preparation" is undefined, and calls for speculation. Abex further objects to this interrogatory to the extent to which it seeks information regarding time periods and products that are not at issue in this case on the ground that such information lacks relevance, and is not reasonably calculated to lead to the discovery of admissible evidence. Abex further objects to this interrogatory on the ground that the information it seeks otherwise lacks relevance to the issues arising in this case, and is not reasonably calculated to lead to the discovery of admissible evidence. Abex further objects to this interrogatory on the grounds that it is over broad, oppressive, harassing and otherwise unduly burdensome, and calls for speculation to the extent to which it requests knowledge, information or materials which are not within the personal possession or -38-