Document v1KkzYrrYGR5G1N66p5JE13gZ

litigation on the grounds that such requests are overly broad, unduly burdensome, and not reasonably calculated to lead to the discovery of admissible evidence. Subject to its objections. Union Carbide responds as follows: See Union Carbide's Response to Interrogatory No. 16. INTERROGATORY NO. 18: State the last date on which Defendant or any related company specified, sold, distributed, applied and/or installed any asbestos-containing product outside the United States and identify by brand or trade name the products so specified, sold, distributed, applied and/or installed. RESPONSE: See General Objections Nos. 1-8. Union Carbide further objects to this Interrogatory on the ground that it is overly broad. Union Carbide further objects to this Interrogatory to the extent that it calls for information about Union Carbide employees or premises, or policies pertaining to Union Carbide employees or premises that are unrelated to the claims in this litigation on the grounds that such requests are overly broad, unduly burdensome, and not reasonably calculated to lead to the discovery of admissible evidence. Union Carbide further objects to this Interrogatory on the grounds that absent an allegation that the Plaintiff was exposed to a Union Carbide product abroad, the information sought by this Interrogatory is irrelevant. Subject to its objections, Union Carbide responds as follows: See Union Carbide's Response to Interrogatory No. 16. INTERROGATORY NO. 19: Identify by full and complete trade name, any and all asbestos-containing products as defined above, which this Defendant, any related company, or any predecessor(s) has, at any time: (a) Designed; 00 Manufactured; (c) Processed; (d) Sold; (e) Distributed; (f) Applied; (g) Installed; (h) Patented; (i) Specified; or O') Re-labeled. RESPONSE: See General Objections Nos. 1-8. Union Carbide further objects to this Interrogatory on DOCSNY1-.1012018.1 13