Document oDKpJDDVdnvxaz60GKzEn9xxg

burdensome. To the extent this interrogatory seeks information concerning the working conditions of Abex employees., it is objected to on the grounds that such information lacks relevance to this case and is not reasonably calculated to lead to the discovery of admissible evidence. > 57. As to any threshold limit values published by the American Conference of Governmental Industrial Hygienists, state whether you have brought such information to the attention pf those using your products. If you have not done so, state the reasons why you have not done so. ANSWER TO INTERROGATORY NO. 57: Abex objects to this interrogatory on the grounds that it is overly broad, burdensome and lacks particularity as to what information is being requested. There are various threshold limit values for various types of substances. Abex cannot respond to this interrogatory without more specific information. 58. Have you been: (a) a member of or (b) affiliated in any manner with or (c) received reports or (d) subscribed for reports or publication to the Industrial Hygiene Foundation of Pittsburgh? ANSWER TO INTERROGATORY NO. 58: Abex objects to this interrogatory on the grounds that it is burdensome and overly broad as to time and scope. Subject to and without waiving these objections, Abex was a member of the following trade associations: Asbestos Information Association of North America (1975 to 1980) and The Brake Lining Manufacturing Association (from an unknown period to 1949). Furthermore, Abex was a member of the Friction Materials Standards Institute (1949 to present); The American Industrial Hygiene Association ("AIHA") ; The Air Pollution Control Association; the Manufacturers Alliance for NTl-136110. 01/23/03 2:14am -45-