Document e1yyL12LwYkY2MBz7ggoN4XKq

INTERROGATORY NO. 19: Do you have any records or documents in dicating that any of your products containing asbestos fibers were sold or distributed to the following company for the years 1945 until the present? D & W Distributing Co. of Pekin, Illinois. < (a) Please identify each document. (b) Please identify such products sold or distributed and the dates of such sale or distribution. ANSWER: Defendant Abex objects to this interrogatory as being unduly broad and unlimited, fhis information is available at Defendant's Winchester, Virginia, facility, and can be retrieved only through a manual search of the files, and it would be unduly burdensome to require Defendant to expend a great many man-hours searching its files for each document. Further Defendant states that the information is available only for the last three years due to Defendant's current records retention procedures, and De fendant states that such records would be irrelevant as Plaintiff, by his own testimony, stopped working with asbestos products in 1975. Subscribed and sworn to ojL before me this 0 6 day ofXec^r,f 1982. Janies G. g^flebower Accounts Receivable Supervisor Abex Corporation 1\vvQ ' rr-m: -D OGs) ________________ \NOTARY PUBLIC ^ Ccrr\ ^ W\a^-vUj SWAIN, JOHNSON &`CARD 1900 Savings Center Tower 411 Hamilton Boulevard Peoria, Illinois 61602 (309) 673-0741 7