Document 6wVEYJpBmDznNm5GZeajOdpgg
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IN THE CIRCUIT COURT THIRD JUDICIAL CIRCUIT MADISON COUNTY, ILLINOIS
IN RE: ALL ASBESTOS LITIGATION FILED BY THE SIMMONS FIRM, LLC
Plaintiffs,
vs.
A.W. CHESTERTON, et al.. Defendants.
DEFEND ANT DANA CORPORATION'S INITIAL RESPONSES TO PLAINTIFFS' STANDARD REOUEST FOR PRODUCTION OF DOCUMENTS REGARDING FORMER SPICER ) CLUTCH DIVISION
PRELIMINARY STATEMENT
Pursuant to the consent order dated October 20, 2003, Dana Corporation ("Defendant")
submits these responses to Plaintiffs' Standard Request for Production of Documents, addressing
documents that relate to the former Spicer Clutch Division. This preliminary statement applies to,
and is hereby incorporated into, each response below.
Paragraph 9 of the consent order provides that, although interrogatory responses are to be
provided by December 15, 2003, "Plaintiffs understand and agree that production and copying of
documents may take longer than stipulated in this agreement." Defendant has expended enormous
resources in order to timely respond to Plaintiffs' interrogatories. In addition, Defendant has been
diligentlybeen searching for and gathering documents concerning the former Spicer Clutch Division
that may be responsive to Plaintiffs' Standard Request for Production of Documents. However,
given the large number of divisions or other entities for which Defendant has been compiling
information and documents, as well as the historical nature of the issues and the documents
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themselves, that process of searching for and gathering documents necessarily is taking longer than as was stipulated in the agreement.
. >ll 100 (. vain Plaza II 10* /`andaUa Street
r.O. Box 467 'dwardsvltk, 1L 6201S-0467
Fax (618) 656-7940 . (618)656-4646
Accordingly, Defendant will produce during the week of December 15, 2003 certain documents that are responsive to Plaintiffs' Standard Request for Production ofDocuments and that Defendant has been able to locate, assemble, copy, and produce at this time. Defendant continues
diligently to search for and assemble additional responsive documents, anticipates that it will