Document mbrgd6y9z6aVz4xnZ1jyjN65k

litigation; real estate and business transactions; labor and employment issues, claims and litigation; anti-trust issues, claims and litigation; legal issues related to corporate governance or management; as well as other legal issues, transactions and claims. When a plaintiff avails himself or herself of the offer to inspect the documents, Abex will remove any documents with respect to which it claims privilege, on a box-by-box basis, and will prepare and serve a privilege log on plaintiff within sixty (60) days after the last date upon which the documents were inspected. Any dispute as to the propriety ofany objection can thereafter be resolved by the Court. INTERROGATORY NO. 1(0: If your answer to Interrogatory No. 102 is "Yes": (a) Identify any and all documents received by Defendant, its predecessors), or a related company referring to, relating to or reflecting any findings or results of those studies or tests, and state the date upon which each was first received; (b) Identify any and all communications (oral or written), between Defendant, its predecessors) or a related company and Saranac personnel, including but not limited to Gerrit W.H. Schepers, M.D.; (c) Identify any and all documents referring to, relating to or reflecting the Saranac studies received or submitted by Defendant, its predecessors) or a related company either directly, through related or predecessor companies, through other companies, or through any trade associations, organizations or other entities; and (d) Identify any and all documents referring to, relating to or reflecting recommendations or findings of such studies relating to: (i) Adequacy or inadequacy of threshold limit values; (ii) Substitution of materials other than asbestos to be used in the insulation process. SECOND AMENDED ANSWER TO INTERROGATORY NO. 103: See Objections and Answer to Interrogatory No. 102, which are incorporated by reference as though set forth herein in full. 185