Document gDopz7Ex5VMX3QOQjnb99NEGV

INTERROGATORY NO. 26: Is Defendant or any related company, as of the date of answering these interrogatories, still manufacturing, specifying, selling, distributing, applying or installing any asbestos-containing product? If so, give the brand/trade names of such products, type and percentage of asbestos in such product, and the date on which Defendant or any related company first manufactured, specified, sold, _ _ distributed,_appljed or installed said_product_s._____________________________________ ANSWER TO INTERROGATORY NO. 26: Abex objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, compound, vague and ambiguous and calls for speculation. 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 ground that it purports to shift the burden of establishing product identification from plaintiffs to Abex. Abex objects to this interrogatory to the extent it purports to seek information or materials regarding time periods and products that are not at issue m these cases, on the grounds that such information or materials lack relevance 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 lack relevance to the issues arising m these cases and are not calculated to lead to the discovery of admissible evidence. Abex further objects to this interrogatory on the ground that it assumes the truth of matters not established or matters not in evidence. Subject to and without waiving these objections, and insofar as Abex understands this interrogatory, no. -64-