Document jg38595LKBwdYpqaEXoJ8yBg5

RESPONSE TO INTERROGATORY NO. 127: See Abex's response to Interrogatory No. 125, above. INTERROGATORY NO.128: Other than the polices of insurance described in response to Interrogatory No. 126, do there exist any agreements providing for the benefit of Defendant, any predecessor or any related company, complete or partial indemnification for any or all expenses incurred with respect to any or all of these cases, including, but not limited to, judgments, settlements, costs, experts' fees and/or attorneys' fees? RESPONSE TO INTERROGATORY NO. 128: See General Objections. Abex further objects to this request on the grounds that the term "agreement" is undefined rendering this request so vague, ambiguous and potentially misleading that Abex is unable to respond without a substantial risk of inaccuracy. Abex further objects to this request on the grounds that it is compound, vague, ambiguous, overly broad as to time and scope, unduly burdensome, irrelevant to any issue in this action and not reasonably calculated to lead to the discovery of admissible evidence. Without waiver of these objections, upon information and belief, Abex is aware of certain information and/or documents which would be responsive to this request. Pursuant to the Order of the Court issued at a hearing held on April 13, 2000, Abex will produce this information upon receipt of a properly executed protective order securing the confidentiality and limiting the use of this information. ^ INTERROGATORY NO. 129: If your answer to interrogatory No. 128 is "Yes," for each such agreement: (a) Identify all parties to the agreement and state the capacity of each such party (i.e. indemnitor, indemnitee, etc.); -86.