Document o9LNEbbLLxBZ8zvyOLrvjVmM7

INTERROGATORY NO. 16: State the first and last dates on which any asbestoscontaining product was manufactured by. (a) Defendant; (b) each and every predecessor; and (c) each and every related company ANSWER TO INTERROGATORY NO. 16: 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 product identification from plaintiffs to Abex i 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 grounds 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 m 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 assumes the truth of matters not established or matters not m evidence. Subject to and without waiving these objections, and insofar as Abex understands this interrogatory, see Answer to Interrogatory No. 19 -40-