Document 6Ragd2DvoDYODmxx4dKDvXgkE

IN THE CIRCUIT COURT FOR DADE COUNTY, FLORIDA 11TH CIRCUIT IN RE CONSOLIDATED ASBESTOS CASES ) ) ) ) ) `) CASE NO. 91-80,000(42) Amended Answers of Dana CORPROATION TO PLAINTIFFS* MASTER Preliminary Interrogatories and Requests for Production PRELIMINARY STATEMENT Dana Corporation (Dana) is a multinational corporation with thousands of employees at hundreds of plants and facilities across the country and around the world. Dana manufactures a variety of industrial and vehicular products for original equipmentmanufacturers and for the aftermarket. In view of Dana's size, it would be practically impossible to inquire at every Dana plant and facility to answer these interrogatories. Necessarily, Dana must narrow the scope of its inquiry based upon the allegations of the complaints and the product that appears to be at issue. To the e'"tent Dana can determine from the Complaints, it is appsrently contended that the plaintiffs were exposed to asbestoscontaining products allegedly manufactured by the Victor Product- 1