Document gEgE1mBOnZLKVjmq1aYM1qa3Q

INTERROGATORY NO. SO: Did Defendant, any predecessor or any related company, or any medical department or industrial hygiene division thereof, maintain a medical and/or scientific library at any time from 1940 to the present? If so: (a) State the dates such library existed; (b) State the number of volumes maintained therein; (c) State die number of employees, part-time or full-time, assigned to the maintenance of said library; and (d) - Identify the person(s) within the corporate structure to whom said library employees reported throughout the existence ofthe library. SECOND AMENDED ANSWER TO INTERROGATORY NO. SO: Abex objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, compound, vague and ambiguous. Abex also objects to this interrogatory to the extent it purports to seek information or materials regarding time periods and products that are not at issue in these cases, on the ground that such information or materials lack relevance and are not reasonably calculated to lead to the discovery of admissible evidence. To the extent to which it purports to seek information or materials regarding the working conditions of Abex employees, this interrogatory is further 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 objects to this interrogatory on the grounds that the information or materials it purports to seek otherwise lack relevance to the issues arising in these cases and are not reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving these objections, Abex did not maintain an official medical library, although its medical department did have various books and publications 86