Document mBoozLKyX5BNgvdgnp63omx8Q

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 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 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, insofar as Abex understands this interrogatory, and upon information and belief, the warning labels were affixed to automotive friction product packages. In addition, see Answer to Interrogatory Nos. 36, 63 and 64. -152-