Document qaYxzddp5DLe1mjjj20XX0X9j

Abex further objects to this request on the ground that it purports to shift the burden of establishing product identification from plaintiffs to Abex. Abex further objects to this request to the extent to which it seeks information regarding time periods and products that are not at issue in this case on the ground that such information lacks relevance, and is not reasonably calculated to lead to the discovery of admissible evidence. Abex further objects to this request on the ground that the information it seeks otherwise lacks relevance to the issues arising in this case, and is not reasonably calculated to lead to the discovery of admissible evidence. Abex further objects to this request on the grounds that it is overly broad, oppressive, harassing and otherwise unduly burdensome, and calls for speculation to the extent to which it requests knowledge, information or materials which are not within the personal possession or control of Abex, its employees or agents, or which may be ascertained or derived, if at all, only from a page-by-page review of the existing voluminous business records and documents of Abex. Subject to and without waiving these objections, see objections and response to Request For Production No. 1, above. REQUEST FOR PRODUCTION NO. 40: Please produce a true and correct copy of all documents pertaining to the acquisition, purchase or sale by Defendant of any asbestos-containing product manufacturing facility or asbestos-containing product or product line. RESPONSE TO REQUEST FOR PRODUCTION NO. 40: See General Objections. Subject to and without waiving these objections, see objections and response to Request For Production No. 1, above. -42-