Document 65bbXzvNZ8bQDdE2XqYJkr19g
Therefore, Dana strictly limits its answers to Dana's brief
relationship with Smith Kanzler Company, which relationship is
described below.
Dana objects to providing the voluminous
information requested in these interrogatories for its automotive,
vehicular and industrial products because they are not the type of
products to which the plaintiff alleges exposure. Questions about
Dana's vehicular products are not relevant and are not calculated
to lead to the discovery of relevant and admissible information.
Further, because Dana merely owned the stock of Smith Kanzler
Company for less than eighteen (18) months, Dana denies that it has
any liability for any products manufactured or sold by Smith
Kanzler Company.
From September, 1967 until February, 1969, Dana owned the
*
stock of a New Jersey corporation known as Smith Kanzler Company,
located in Linden, New Jersey. Smith Kanzler Company produced
certain asbestos containing products that had application in the
building construction industry. Dana did not incorporate Smith
Kanzler Company but came to own its stock as a consequence of the
dissolution of Victor Manufacturing Gasket Company in September,
1967. Victor was at that time the sole shareholder of Smith
Kanzler Company's stock. In February, 1969 less than eighteen (18)
months after acquiring the stock, Dana sold the stock of Smith
Kanzler Company to Philip Carey Corporation. At that time Philip
Carey took possession of Smith Kanzler Company's business records
or those records remained with Smith Kanzler Company. Dana has
located very few of Smith Kanzler Company's records that remained
in its possession after the sale.
DEFENDANT*S RESPONSES AND OBJECTIONS TO PLAINTIFFS' jTNTERRQCATORXES AND REQUESTS FOR PRODUCTION f:\asb3\rogs.all
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