Document E45pE7LzyMq8rkw09godB4yj

K8895DIA058 Warner." The automatic transmission clutch plates and brake bands were packaged and shipped in bulk within brown cardboard boxes. These boxes may have contained shipping labels and packaging tape, which referenced Borg-Warner. Most of Borg-Warner's clutch products were sold to original equipment manufacturers (OEMs) with packaging generally composed of various strengths and sizes of die-cut corrugated cardboard. Various types of boxes were used, based on the specifications of the various OEMs. With regard to aftermarket or service parts, clutch products manufactured by Borg-Warner may have been sold by the OEMs in their own packaging. Those clutch parts sold by Borg-Warner to the aftermarket were packaged in blue and gold boxes prior to 1967 and after 1967 a black, red and white box was used displaying the logo and the words "Borg-Warner." INTERROGATORY NO. 28: For each subpart below, state whether or not, to Defendant's knowledge, any items as described therein presently exist and, if so, identify any and all such existing items and state the present location of each: (a) any product listed in response to Interrogatory No. 19, including, but not limited to, any sample, part or piece thereof; (b) any package of the type in which any or all of the products listed in response to Interrogatory No. 19 were or would have been sold, including, but not limited to, any partial package; (c) any catalogue, brochure, sales literature or like item referring to, relating to or reflecting any or all of the products listed in response to Interrogatory No. 19; (d) any picture, drawing, photograph or like representation of the items described in subparts (a), (b) and/or (c) of this Interrogatory. ANSWER TO INTERROGATORY NO. 28 Borg-Wamer answers that exemplars of some of its products and packaging are available for viewing at the BorgWamer Inc. Law Department, by appointment through Borg-Wamer's counsel. INTERROGATORY NO. 29: Did Defendant, any related company or any predecessor ever stamp or otherwise place (including affixing tags or labels) a company name, initials, or any identifying logo on any of the products listed in response to Interrogatory No. 19? ANSWER TO INTERROGATORY NO. 29 Borg-Wamer answers that its products were stamped with the identifying marks of the division that manufactured the product.