Document ppgGgJ5eB1poM486mpvLqXLnB

INTERROGATORY NO. 131: From 1940 to present, state whether Defendant and/or predecessor or related company ever provided workers' compensation health, accident and disability and/or life insurance coverage for its employees, and if so. (a) Withdrawn by plaintiff or stricken by the Court; (b) State whether such insurance earners) ever conducted any dust counts or studies, mdustnal hygiene surveys or other tests relating to any asbestos-containing products that Defendant's employees may have been working with or around; and, (c) If you response to subpart (b) hereof is in the affirmative, please mdicate the date of each such count, study, survey or other test and identify all documents relatmg thereto. ANSWER TO INTERROGATORY NO. 131: Abex objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, compound, vague and ambiguous and calls for speculation. Pursuant to the Court's April 13, 2000 Order, Abex's answer to this interrogatory is limited to the years between 1930 and 1980 Abex also objects to this interrogatory on the ground that it purports to shift the burden of establishing product identification 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 grounds that such information or materials lack relevance and are not reasonably calculated to lead to the discovery of admissible evidence. To the extent it purports to seek information or materials regarding the working conditions of Abex employees, this interrogatory is objected to on the grounds that such information or materials lack relevance to the issues arising in these cases and are not reasonably calculated to lead to the discovery of admissible evidence. -293-