Document kGYajodvLeQp0k8gn3Rzbg8y

establishing causation from plaintiffs to Abex. Abex further 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 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. Abex objects to this interrogatory on the grounds that the information or materials it purports to seek otherwise lack relevance to the issues arising in these cases and are not reasonably calculated to lead to the discovery of admissible evidence. Abex also 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 to the best of current and reasonably available information and belief, in the mid-1970s, and perhaps earlier, Abex commenced the placement of warning labels on its asbestos-containing automotive friction products. Any discussion of warning labels for friction materials at a Friction Materials Standard Institute, Inc. meeting may have taken place after Abex commenced placement of warning labels on its asbestos-containing products. INTERROGATORY NO. 69: If you answer to Interrogatory No. 68 is "Yes," with respect to each such suggestion, recommendation, counseling, advice or other indication: (a) Identify the person(s) and/or entity(ies) giving the same; (b) State the date(s) on which the same was given; (c) Identify any and all persons receiving notice of the same; (d) Describe what, if any, action Defendant took in response to or upon the same; and, (e) Identify any and all documents referring to, relating to or reflecting the same, or any action taken thereon or in response thereto. 109