Document dGe9BRz2YbNgMXzBNpdkxeVG

ANSWER: Defendant objects to Interrogatory No. 39 to the extent It exceeds the scope of Texas Rule of Civil Procedure 166b by asking for a witness list. The interrogatory thereby seeks to invade the attorney work-product, investigative, and third-party communications privileges set forth in Texas Rule of Civil Procedure 166b. The interrogatory is overly broad, general and global and requires Defendant to engage in speculation. Subject to and without waiving the foregoing objections, GM has not yet determined who will be called as witnesses or designated as experts. If GM designates GM employees 8$ experts, and if such experts have prior depositions in their control, copies of the prior depositions will be made available to Plaintiff. 40. Have Defendant or its subsidiaries or predecessors ever acquired through purchase, reorganization, or merger another corporation, company, or business which manufactured, sold, processes, distributed, or contracted or supplied products containing asbestos? If so, for each such entity, state: (a) Full and correct name; (b) Principal place of business; (c) State of incorporation; (d) Date of acquisition by Defendant; (e) Whether or not the business entity was ever authorized to transact business in the State of Texas. ANSWER: Defendant objects to Interrogatory No. 40 to the extent it inquires of "predecessor companies" without identifying or defining such. Moreover, the interrogatory calls for a legal conclusion as to what companies are "predecessors" without setting forth a factual or legal foundation for such an opinion. Further, the interrogatory seeks information which is neither relevant nor material and is not reasonably calculated to lead to the discovery of admissible evidence at the trial of this lawsuit. Subject to and without waiving the foregoing objections, GM acquired the assets of the Bondall Company, 500 Bittner Street, St. Louis, Missouri, in 1939. Bondall designed and manufactured brake linings and clutch facings. 46