Document jBmjx85XGnnxaxp0zeaywk6dQ

Westinghouse's portfolio ofbusinesses and products changes almost continually. Changes occur when Westinghouse develops new products, discontinues old products, acquires other companies or their product lines, or divests itself of subsidiaries or product lines. Changes also occur when Westinghouse adds suppliers to, and deletes suppliers from, its product lines. Westinghouse has not and does not generally maintain its business records according to product content, asbestos or otherwise. Therefore, it is not reasonably possible for Westinghouse to fully answer form interrogatories because of the overly broad, categorical manner in which they are framed. These discovery requests are not limited in any fashion to the product(s) reasonably believed by plaintiffs to have been sold, distributed or manufactured by Westinghouse and to which they reasonably believe they were exposed. Without this basic information from plaintiffs about product type and location, it would be unduly burdensome for Westinghouse to attempt to respond because to do so would require review of documents from thousands of files relating to many different products and issues having nothing to do with this litigation. Normally, once the specific location is identified, Westinghouse, from public and internal documents, is able to verify the sale of a marine or land-based turbine. As to other products, Westinghouse cannot reasonably respond to those Interrogatories which seek confirmation of all specific sales to specific customers or geographic regions. Westinghouse does not maintain its records according to product content, whether asbestos or otherwise. Documents generated by various Westinghouse divisions and subsequently stored by Westinghouse are not maintained by customer name or purchaser name. These documents are generally stored according to their 3