Document v1gDVVLaR9NkOxrEm9j9BaYJ8

REQUEST FOR PRODUCTION NO. 26: Please produce a true and correct copy of all documents memorializing or referring, relating or pertaining to communications or correspondence among and/or between your officers, director, agents, representatives, employees or consultants and any employer, purchaser or user of your asbestos-containing products, its officers, directors, agents, representatives, employees or consultants which in any way relates, refers or pertains to asbestos, asbestos-containing products, pneumoconiosis, asbestos-related illness, injury or disease, dust or workplace health or safety. RESPONSE TO REQUEST FOR PRODUCTION NO^dT See General Objections. Abex further objects to this request on the grounds that it is over broad, oppressive, harassing, otherwise unduly burdensome, compound, vague, ambiguous and speculative. Objection is also made to this request on the ground that the terms "user," "asbestos," "pneumoconiosis," "asbestos-containing products," "asbestos-related illness," "asbestos-related . . . injury," "asbestos-related . . . disease," "dust," "workplace," "health" and "safety" are undefined, and call for speculation. Abex further objects to this request on the ground that it purports to shift the burden of establishing causation from plaintiffs to Abex. Abex further objects to this request to the extent to which it seeks information regarding time periods, products and work sites 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. To the extent to which it seeks information regarding the working conditions of Abex employees, this request is objected to on the ground that such information 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 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. -28-