Document 2R4j5nepJnaeMVxNBBekve9op

K8895 MXYrslm & -/-S q3 IN THE CIRCUIT COURT THIRD JUDICIAL CIRCUIT MADISON COUNTY, ILLINOIS t^ IN RE: ALL ASBESTOS LITIGATION FILED BY THE SIMMONS FIRM, LLC, Plaintiffs, vs. A.W. CHESTERTON, et ah. Defendants. ) ) DANA CORPORATION'S RESPONSES ) TO PLAINTIFFS' STANDARD ) INTERROGATORIES REGARDING ) SPICER AXLE PRODUCT DIVISIONS ) PURSUANT TO ORDER DATED ) OCTOBER 20.2003 ) ) ) PRELIMINARY STATEMENT Pursuant to the consent order dated October 20, 2003, Dana Corporation ("Defendant") hereby submits these Responses To Plaintiffs' Standard Interrogatories with respect to the Spicer Axle Product Divisions. This preliminary statement applies to and is incorporated into each i response. In addition, in order to avoid confusion. Defendant has incorporated below the changes to the interrogatories ordered by the Court on April 14, 2000, and provides responses to the interrogatories as so modified. Defendant responds to these interrogatories after reasonable investigation with the best available information presently known to it about the Spicer axle product line. In some cases, Defendant is not aware ofany individuals with personal knowledge ofrelevant information covering early years ofaxle manufacturing. Moreover, the documents available to Defendant do not provide all of the information sought. Accordingly, Defendant will respond only to the extent that there is ROYSTER ELKER~ LILEN information currently available and reviewed that it believes is sufficient to respond, in whole or in part, to the interrogatory. Unless otherwise requested in the interrogator, these responses are Salte 100 ;TwaIa Plaza H tf vqdalla Street /7 125-0467 , -/W0 14)656-4646 limited to U.S.A. manufacturing and sales. To the extent Defendant manufactured or sold products that were not part of the Spicer Axle historical product lines, those products will be addressed separately as otherwise required by the October 20,2003 order. SCF-ALLF-10936