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BSIS-Roberson01798

HWCPI0001671

HWCPI0001711

HWCPI0001739

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11572-1000 MXY/dal ANSWER: See Answers to Interrogatory Nos. 56 and 63, which are incorporated herein as if fully rewritten.

will not make such documents available to plaintiffs Abex further objects to this interrogatory to the extent it purports to seek medical records or privileged personnel information Abex will not provide such information absent an appropnate waiver of the applicable privilege Abex has no comprehensive list or log of the documents with respect to which it claims privilege In the past, when Abex has had cause to review some boxes of documents, it has segregated and/or tagged certain documents with respect to which it claims privilege.

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'?

INTERROGATORY NO. 37: With respect to each product listed in response to Interrogatory No 19, state.

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