Document wq3qbZje6bKMNnMJdj2V285wQ

such product identified: (a) Describe each and every name, initials or identifying logo appearing on said product, at any time, by stating the wording, lettering, symbols, size, color and manner in which it was stamped, placed or axed to said product; (b) State the date(s) during which each such name, initials, or identifying logo appeared on said product; and / (c) Identify any and all documents referring to, relating to or reflecting the stamping, placing or affixing of names, initials or logos to said product, including, but not limited to, any pictures, photographs or like representations of such names, initials or logos. SECOND AMENDED ANSWER TO INTERROGATORY NO. 30; See Objections and Answer to Interrogatory No. 29, which are incorporated by reference as though set forth herein in full. INTERROGATORY NO. 31: Was each of the asbestos-containing products listed in response to Interrogatory No. 19 generally expected to reach, or was each packaged to reach, the consumer or user, without substantial change in the condition in which it was sold? SECOND AMENDED ANSWER TO INTERROGATORY NO. 31: Abex objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, compound, vague and ambiguous and calls for speculation. Abex also objects to this interrogatory to the extent it purports to seek information or materials regarding time periods and products that are not at issue in these cases, on the grounds that such information or materials lack relevance and are not reasonably calculated to lead to the discovery of admissible evidence. Abex further objects to this interrogatory on the grounds that the information or materials it purports to seek otherwise lack relevance to the issues arising in these cases and are not reasonably calculated to lead to the discovery ofadmissible evidence. Subject to and without waiving these objections, Abex's asbestos-containing automotive 59