Document zwM2zdKeK1yOD1RwDMNkQYBB

ANSWER TO INTERROGATORY NO. 33: 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. 34. Has your firm ever been cited or admonished by any government agency (federal, state or local) for dust levels in excess of any threshold limit value (TLV) or other predetermined number respecting all dusts found in work areas where asbestos or asbestos products were manufactured or handled? If so, please state: a. the dust and TLV or number involved (including standard and actual number); b. the date; c. the government agency; d. the means of identifying any document related to such an occurrence; involved. e. any action taken by you and/or the agency ANSWER TO INTERROGATORY NO. 34: Abex objects to this interrogatory on the grounds that it is overly broad, burdensome and, in seeking information concerning the working conditions of Abex employees, lacks relevance to this case and is not reasonably calculated to lead to the discovery of admissible evidence. 35. Have you contributed any funds to research concerning asbestos and its relation to lung, heart, gastro intestinal, and/or larynx disease? If so, please state for each year the amount of money contributed, when and to whom, attaching any report or reports from each individual or organization to whom your funds were distributed. ANSWER TO INTERROGATORY NO. 35: See answer to interrogatory No. 36. -26-