Document RJw3bK5d4DrdRyawg0jRvLGNB

SUPREME COURT OF THE STATE OF NEW YORK EIGHTH JUDICIAL DISTRICT In. Re: Eighth Judicial District Asbestos Litigation EIGHTH JUDICIAL DISTRICT ASBESTOS LITIGATION This Document Applies to: SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ERIE MICHAEL JOSEPH KOLASINSKI vs. Plaintiff, ACME LIQUIDATING CORP., successor in interest to LIFE AUTOMATION CORP. tfk/a LIPE-ROLLWAY TECHNOLOGY, INC., et al. Defendants. EATON CORPORATION RESPONSES TO PLAINTIFFS' INTERROGATORIES Index No. 2008-405 EATON'S RESPONSES TO PLAINTIFFS' INTERROGATORIES Comes now Defendant, Eaton Corporation, on behalf of its current and former business operations known as Truck Components Operations and on behalf of no other entity, and provides the following Objections and Responses to Plaintiffs Interrogatories and Requests for Production ofDocuments: 1. Overly Broad. Undue Burden - Scope and Time. Eaton objects to the definitions, instructions and individual requests seeking information concerning products other than those to which Plaintiff alleges exposure. Eaton objects to providing information concerning divisions or business units other than those involved with the product or products to which Plaintiff alleges exposure. Requests seeking such information are overly broad and unduly burdensome, oppressive, and not reasonably limited to scope or time. Eaton states that it has manufactured a wide array of highly engineered products for nearly a century. As such, attempting to determine every activity engaged in by every such business would be extraordinarily and unreasonably difficult. For these reasons, Eaton will only incur the burden and expense of obtaining information which pertains to products manufactured by Eaton's current and former business 1