Document e7MB3KZ7p4kmJRrkEydn7Zp4G

INTERROGATORY NO. 51: Did your company or its predecessor(s) or subsidiaries ever stamp or place the name of the company, its initials, or any identifying logo on any of its asbestos-containing products? if so, please state the name brand names of such products, a description of such stamp or logo and the dates such were placed on the referred products. ANSWER: See Answer to Interrogatory No. 7. INTERROGATORY NO. 52: Has your company, or your predecessor(s) or subsidiaries, ever devised a research plan to develop, or actually developed or had developed, a product which did not contain asbestos and which could be substituted for one or more of your asbestos-containing products? If so, state the date that such research plan was begun and when such asbestos-free product was first placed on the market. ANSWER: Abex objects to this interrogatory on the grounds- that it is overly broad.and.burdensome. Abex further objects to this interrogatory on the grounds that it lacks relevance to this case and is not reasonably calculated.to lead to the discovery of admissible evidence. Abex objects to this interrogatory to the extent it seeks information on. products which are not. at issue in this case on the grounds that the information sought-is_ not- relevant and not reasonably calculated to lead. to. the discovery of admissible evidence. Abex also objects to this interrogatory to the extent that it seeks confidential, trade secret, or other proprietary information or materials. Subject to and without waiving NY1-86445. 03/31/95 2:34pm -47-