Document dM214Y9kN1rqgawYz8Jjbmd0

INTERROGATORY NO. 98: Identify any and all documents which Defendant, its predecessor(s) or any related company submitted to, or received from, the organizations listed in response to Interrogatory Nos. 94 and/or 97: (a) which refer to, relate to or reflect the subject of asbestos; (b) which refer to, relate to or reflect a relationship between asbestos exposure and any disease; and/or (c) which refer to, relate to or reflect the placement or providing of warnings with respect to hazardous products. ANSWER TO INTERROGATORY NO. 98: Pursuant to the Court's April 13, 2000 Order, Abex's answer to this interrogatory is limited to the years between 1930 and 1980. Abex discontinued the manufacture and sale of asbestos-containing friction products in 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 during the period Abex manufactured and sold friction products with personal knowledge of the information contained in all the records and documents that might be responsive to this interrogatory. The available information, from which Abex would prepare a response to this interrogatory, is contained in files and records maintained by Abex. To prepare a response to this interrogatory would necessitate the preparation or the making of a compilation, abstract, audit, or summary of or from these files and records. No such compilation, abstract, audit, or summary presently exists. The burden and expense ofpreparing or making such a compilation, abstract, audit, or summary would be substantially the same for plaintiffs as for Abex. -228-