Document one5xMDmjmR1pQB4L239NY47

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; ______ (h)____ 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. ANSWER TO INTERROGATORY NO. 69: 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 causation from plaintiffs to Abex. Abex farther 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. I -159-