Document Z8kgKq0Kq3JGDw9MJxww5b5nO
from disclosure because of a privilege claimed for any reason? If yes, please list each document
being claimed as protected from disclosure in a privilege log providing the date of the document,
the identity of the author, what individual or entity the document was addressed to, the identity
of any individuals or entities provided copies of the document, a brief description of the nature of
the document, arid the particular privilege claimed as shielding the document from disclosure.
ANSWER: At this time, Kelsey-Hayes has not asserted a privilege with respect to any documents. However, if at a later time plaintiff narrows objectionably vague and overbroad interrogatories, Kelsey-Hayes reserves the right to assert any and all privileges with respect to documents that might be included within the requested information.
Dated: November___ , 2002
Respectfully submitted, GREENSFELDER, HEMKER & GALE, P.C.
By t'
Cl.
___
Edward S. Bott Jr., #03126866
Andrew M. Voss, #06257487
Andrew R. Margrabe, #06276646
10 South Broadway, Suite 2000
St. Louis, Missouri 63102
Telephone: (314)241-9090
Facsimile: (314)241-8624
Attorneys for Kelsey Hayes
CERTIFICATE OF SERVICE
I hereby certify that a copy of the foregoing was mailed this
day of November, 2002
to John Simmons, Esq., and Ted. N. Gianaris, Attorneys for Plaintiff, 301 Evans Avenue, Suite
300, Wood River, IL 62095 and to the Central Records Depository at 203 W. High Street,
Edwardsville, IL 62025 by regular U.S. Mail with postage prepaid.
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