Document rpYJw22omXoKmNMYb6X0Xyby7
IN THE CIRCUIT COURT THIRD JUDICIAL CIRCUIT MADISON COUNTY, ILLINOIS
IN RE: ASBESTOS LITIGATION
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FILED BY THE SIMMONS FIRM. L L.C.)
Plaintiffs.
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vs. )
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A.P. GREEN REFRACTORIES. eL al.. )
Defendants.
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SUPPLEMENTAL ANSWERS OF PNEUMO ABEX CORPORATION, AS SUCCESSOR-IN-INTEREST
TO ABEX CORPORATION. TO PLAINTIFFS' INTERROGATORIES
Preliminary Statement and General Objections
Pursuant to the Qlinois Rules ofCivil Procedure and the Illinois Supreme Court
Rules, defendant Pneurao Abex Corporation, as successor-in-interest to Abex Corporation
("Abex"), hereby objects to Plaintiffs' Interrogatories, as follows*
Abex objects to these interrogatories on the grounds that they are premature and
purport to shift the burden of establishing product identification from plaintiffs to Abex
Abex also objects to these interrogatories on the grounds that they are compound,
contain numerous terms that are vague and ambiguous and that they call for speculation.
Abex further objects to these interrogatories to the extent they purport to seek
information or materials unrelated to Abex's alleged liability in these actions and are not
reasonably calculated to lead to the discovery ofadmissible evidence.
Abex objects to these interrogatories on the grounds that they assumethe truth of
matters not established or matters not in evidence.
PLAINTIFF'S 1 ECAXMHIIDBIT
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