Document bjjMZ7orRn13XrxRvnRz5mq6

INTERROGATORY NO. 52: Has Defendant, any predecessor or any related company, at any time since 1940: (a) been a member of a medical and/or scientific library or library association? (b) been a member of any organization or association which maintained a medical and/or scientific library? (c) been a member of any organization or association through which members obtained the use of, or access to, a medical and/or scientific library? ANSWER TO INTERROGATORY NO. 52: Abex objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, compound, vague and ambiguous. 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 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 ground that such information or materials lack relevance and are not reasonably calculated to lead to the discovery of admissible evidence To the extent to which it purports to seek information or materials regarding the working conditions of Abex employees, this interrogatory is objected to on the grounds that such information or materials 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 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. -125-