Document emGxvkyvK7EXrb86LX8LGJZR9

INTERROGATORY NO. 95: Identify any and all persons attending, on behalf of Defendant, any predecessor or any related company, any meetings, seminars or symposiums held by the trade organizations, associations, or other entities identified in response to Interrogatory No. 94. -ANSWER TO INTERROGATORY NO. 95: Abex objects to this interrogatory on the grounds that it is over broad, unduly burdensome, compound, vague and ambiguous and calls for speculation 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 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 grounds that the information or materials it purports to seek lack relevance to the issues arising m these cases and are not calculated to lead to the discovery of admissible evidence To the extent 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 ground that it assumes the truth of matters not established or matters not m evidence Subject to and without waiving these objections, and insofar as Abex understands this interrogatory, see Answer to Interrogatory No. 98 -222-