Document bO7E0nyDe4Oz4N042rR6x9RZ1

INTERROGATORY NO. 70: Did Defendant, any predecessor, or any related company ever place any warning directly upon any of the products listed in response to Interrogatory Nos 19 and 42? ANSWER TO INTERROGATORY NO. 70: 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 grounds that the term "any related company" is vague and ambiguous and calls for speculation. Abex further objects to this interrogatory on the ground that it purports to shift the burden of establishing causation from plaintiffs to Abex Abex objects to this interrogatory to the extent it purports to seek information or matenals regarding time penods and products that are not at issue in these cases, on the ground that such information or matenals lack relevance and are not reasonably calculated to lead to the discovery of admissible evidence Abex also objects to this interrogatory on the grounds that the information or matenals it purports to seek otherwise lack relevance to the issues ansing m these cases and are not reasonably calculated to lead to the discovery of admissible evidence. Abex further objects to this interrogatory on the grounds that it assumes the truth of matters not established or matters not m evidence. Abex 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 Subject to and without waiving these objections, and insofar as Abex understands this interrogatory, see Answer to Interrogatory No. 64. -161-