Document jg7K7gkmRYqenmO2K8a0eb6dR

FILE NAME: Abex (ABX) DATE: 0000 DOC#: ABX325 DOCUMENT DESCRIPTION: Legal - Abex Admission to Purchasing SK Wellman in 1963 IN THE SUPERIOR COURT OF THE STATE OF DELAWARE IN AND FOR NEW CASTLE COUNTY Dec 5 2011 1:16PM IN RE: ASBESTOS LITIGATION MICHAEL W. VAUGHAN and SUSAN VAUGHAN, : C.A. No. N 11C-01-263 ASB : Plaintiffs, : vs. : ABP INDUCTION, LLC, successor in interest to : Pillar Induction Company, LLC, ct al., : Defendants. : RESPONSES OF DEFENDANT PNEUMO ABEX LLC, SUCCESSOR IN INTEREST TO ABEX CORPORATION. TO PLAINTIFFS' SUPPLEMENTAL INTERROGATORIES INTRODUCTORY STATEMENT Defendant Pncumo Abcx LLC, successor in interest to Abcx Corporation (hereinafter "Abex"), by and through its attorneys of record, Cooch and Taylor, hereby responds to these interrogatories, as follows: The responses of Abex hereinafter set forth are limited to providing information concerning domestic automotive (hereinafter defined as including but not limited to passenger vehicles, light trucks, heavy duty, off-road and industrial) friction materials manufactured by Abex for the allegedly relevant time period only. Abex never mined or commercially sold raw asbestos. To the best of current and reasonably available information and belief, Abex did not manufacture and sell brakes or brake assemblies. Nor did Abex. ever manufacture, process, distribute, market or sell any asbestos- containing building products. Rather, Abex manufactured and sold friction material, only some of which contained asbestos. To the extent that a friction material contained asbestos, it was Abex purchased The S.K. Wellman Company in 1963. To the best of current and reasonably available information and belief, The S.K. Wellman Company did not manufacture or distribute friction material that contained asbestos prior to Abex's purchase of The S.K. Wellman Company. Further, to the best of current and reasonably available information and belief, following its purchase by Abex, The S.K. Wellman Company business may have sold automotive friction material that contained asbestos. Abex sold The S.K. Wellman Company in 1971. In addition, there may be additional corporate acquisitions involving Abex which are potentially responsive to this interrogatory but due to the passage of time, the change of the nature of its business, and the change in personnel, Abex lacks current knowledge of any such acquisitions. Abex discontinued the manufacture and sale of friction material that contained asbestos in 1987 and no longer operates any facilities. There are no current Abex employees. There is only one Abex officer. Abex does not have any current business operations. 7. List all directors and officers of defendant from 1940 to date and for each state all positions held and the date(s) during which each position was held. RESPONSE: Abex objects to this interrogatory on the grounds that it is overly broad and unduly burdensome. 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 in this case, on the grounds that such information or materials lack relevance and are not reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving its objections, see attached lists. 8. State whether any of defendant's present or former officers or directors ever served (whether before, during or after becoming defendants' officer or director) as an officer or director of any other company, corporation or business which manufactured, sold, distributed, applied and/or installed asbestos or asbestos-containing products and, if so, please: (a) Identify each officer and director of defendant, who served as such other - 6-