Document 2NQjvBjR63xoE0Zqg9m3w45aa
subject matter of the pending action nor reasonably calculated to
lead to the discovery of admissible evidence as it relates to Dana.
4. Defendant objects to each interrogatory and part thereof
to the extent that it seeks information not within the custody and
control of Dana.
5. Defendant objects to each interrogatory and part thereof
to the extent that it seeks to require answers or information, or
require identification of documents, or impose obligations, beyond
those permitted by the applicable rules of Civil Procedure and
local rules of Court.
6. Defendant objects to each interrogatory and part thereof
to the extent that it seeks information in a form different from
that maintained by Dana in the ordinary course of its business.
7. Defendant objects to each interrogatory and part thereof
to the extent that it seeks information concerning or contained in
documents which it objects to producing.
8. Defendant objects to each interrogatory and part thereof
to the extent that it seeks to impose on defendant a discovery
obligation to respond for defendant's businesses and entities not
parties to this litigation.
Defendant responds to these
interrogatories on behalf of itself with information known to it
about Smith & Kanzler Company and that company's product known as
Spraycraft. Defendant does not respond for other companies that
plaintiff may consider to be "subsidiaries" or "affiliates" of
defendant but which are not defendant's. Dana was incorporated
under the name Spicer Manufacturing Corporation. The corporation
changed its name in 1946 to Dana Corporation. There is no
pEFENPANT'S RESPONSES AND. OBJECTIONS TO PLAINTIFFS *
yNTERROQATORIBS AND REQUESTS FOR PRODUCTION f:\asb3\roge.all
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