Document v6X1rEZ2ErR8z385mRrYzwOKb

arising in these cases and are not reasonably calculated to lead to the discovery of admissible evidence. Abex also objects to this interrogatory on the ground that it assumes the truth of matters not estabhshed or matters not in evidence Subject to and without waiving these objections, insofar as Abex understands this interrogatory, and based upon information and belief, E H. Feierabend served on the Asbestos Study Committee of the Friction Materials Standards Institute, Inc. from 1972 to at least 1975. Further, Abex discontinued the manufacture and sale of asbestos-containing friction products in 1987 and no longer operates any friction product manufacturing facilities. There are no current Abex employees, officers who worked for Abex, or directors who sat on its Board during the period Abex manufactured and sold friction products with personal knowledge of the information contained m all the records and documents that might be responsive to this interrogatory The available information, from which Abex would prepare a response to this ( interrogatory, is contamed m files and records maintained by Abex. To prepare a response to this interrogatory would necessitate the preparation or the making of a compilation, abstract, audit, or summary of or from these files and records No such compilation, abstract, audit, or summary presently exists. The burden and expense of preparing or making such a compilation, abstract, audit, or summary would be substantially the same for plaintiffs as for Abex -224-