Document wz4DK9x781mLe2qoLkd5zKR3

(b) each and every predecessor; and (c) each and every related company. SECOND AMENDED ANSWER TO INTERROGATORY NO. 16: 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 on the ground that it purports to shift the burden of establishing product identification from plaintiffs to Abex. Abex further 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 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 of admissible evidence. Subject to and without waiving these objections, and to the best of current and reasonably available information and belief, Abex ceased selling clutch facings in approximately 1971. Abex ceased manufacturing and selling its asbestos-containing railroad friction products in 1977. Abex ceased manufacturing and selling its asbestos-containing automotive friction products in 1987. INTERROGATORY NO. 17: State the first and last dates on which any asbestos-containing product was specified, sold, distributed, applied and/or installed within the United States by: (a) Defendant; (b) each and every predecessor; and (c) each and every related company. 38