Document Znd8G2BVvv812ZjN1O5Dd05gp

(h) The name and business address of the present custodian records of defendant corporation and any prior custodian of records of defendant corporation. ANSWER: A Eaton Corporation B OBJECTION. Overbroad. Without waiving this objection, Eaton states that from 1923 to 1932 it was known as Eaton Axle & Spring Company; from 1932 to 1966, Eaton Manufacturing Company; and from from 1966 to 1972 Eaton, Yale & Towne, Inc. C OBJECTION. Overbroad, not calculated to lead to the discovery of relevant evidence. Without waiving this objection, Eaton states that it acquired Schuler Manufacturing in 1958 D OBJECTION. Overbroad, not calculated to lead to the discovery of relevant evidence. Without waiving this objection, Eaton states that it manufactures products under the Eaton and Eaton Fuller name. E See Response to subparts B, C and D. F Eaton's principal place of business is in Cleveland, Ohio G All such documents currently in possession ofEaton Corporation have been made available for inspection and copying by Plaintiff's counsel. H OBJECTION. Not reasonably calculated to lead to the discovery of relevant evidence Interrogatory No. 3 State Whether there is any liability insurance which covers, or may cover, you for the instant matter and, if so, discuss: (a) the name and address of the insurance carrier; (b) the policy number, including years for each policy; and (c) the applicable limits of liability. ANSWER: OBJECTION. A summary of insurance will be provided to Plaintiffs counsel.