Document jmoaGX2XDQxMeVbYZ5oB4ZV6Q
(e) State what, if any, specific fine, penalty, or sanction was imposed; (f) State the date in which and the manner in which said violation was corrected; (g) Identify any and all officials of Defendant, its predecessor or its related company
having knowledge or notice of said violation and state the date on which said knowledge or notice was received; and (h) Identify any and all documents referring to, relating to or reflecting said violation. SECOND AMENDED ANSWER TO INTERROGATORY NO. 121; See Objections and Answer to Interrogatory No. 120, which are incorporated by reference as though set forth herein in full. INTERROGATORY NO, 122: Has any federal or state government entity, at any time, conducted an inspection, test or survey concerning asbestos or asbestos exposure at any facility where the products listed in response to Interrogatory Nos. 19 and 42 were manufactured, processed, applied, used or removed? SECOND AMENDED ANSWER TO INTERROGATORY NO. 122: Abex objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, compound, vague and ambiguous and calls for speculation. Pursuant to the Court's April 13,2000 Order, Abex's answer to this interrogatory is limited to the years between 1930 and 1980. Abex also objects to this interrogatory to the extent it purports to seek information or materials regarding time periods, products and work sites 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 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
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