Document xddOm75KjNJorxVwZxO3K52J0

"can testify" with regard to various topics, however, Abex cannot determine from this question which person or persons it should identify. 52. Did or does defendant maintain a medical library' If yes, state: (a) Date established; (b) Location; (c) Names and addresses cf librarians; (a) Title, author, and publisher of all journals and books bought or subscribed tc during the period 1930 through 1978, (e) To whom journals m the area of asbestos, ' industrial hygiene, medicine safety or engineering were distributed. ANSWER: Abex objects to this interrogatory on the grounds that it is overly broad, burdensome, lacks relevance to this case and is not reasonably calculated to lead to the discovery of admissible evidence. Clayton H. Thomas, Jr. Attorney for Defendant Abex Corporation -41