Plaintiff objects that this request seeks information that is not relevant to the subject matter of this lawsuit and is neither admissible evidence nor reasonably calculated to lead to the discovery of admissible evidence.

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However, or whenever a party can obtain such documentation upon reasonable effort from other sources. Proceedings in the courtroom shall not be disrupted. Imerys did so in part in order to avoid OSHA requirements for warning about asbestos. Veritext Court Reporting Services.

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