Document k99YG4wYmp5b11GNb5kpZLVmn

INTERROGATORY NO. 66: With respect to each product identified in response to Interrogatory No. 65 as having been accompanied by a warning, state whether, subsequent to the first warning described, above, any different warning was ever placed upon said product. Any alteration, change or modification in the language, working, capitalization, punctuation, style of type or printing, size, color, or location on the package or container, of the warning constitutes a different warning__________________ ANSWER TO INTERROGATORY NO. 66: Abex objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, compound, vague and ambiguous and calls for speculation. Abex also objects to this interrogatory on the ground that it purports to shift the burden of establishing causation from plaintiffs to Abex Abex further objects to this interrogatory to the extent it purports to seek information or matenals regarding time penods and products that are not at issue in these cases, on the ground that such information or matenals lack relevance 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 matenals it purports to seek otherwise lack relevance to the issues ansing in these cases and are not reasonably calculated to lead to the discovery of admissible evidence. Abex also objects to this mtenogatory on the grounds that it assumes the truth of matters not established or matters not in evidence. Abex further objects to this interrogatory on the ground that it seeks to impose upon Abex a legal duty or obligation to which it was not subject. Subject to and without waiving these objections, and insofar as Abex understands this interrogatory, no. -153-