Document dnN5NgG4RvwNdvvQdkRjLbwvQ

IN THE CIRCUIT COURT OF THE FOURTH JUDICIAL CIRCUIT IN AND FOR DUVAL, FLORIDA ALLEN GEORGE FULLER and MARY ANN FULLER, his wife. CASE NO: 97-03539 CA DIVISION: Plaintiffs, vs. RAYMARK INDUSTRIES, INC., a Connecticut corporation et al.. Defendants. / DANA CORPORATION'S ANSWERS TO PLAINTIFFS' FIRST SET OFJNTERROGAXQBIES INXRQJUCXIQN Dana Corporation ("Dana") objects to plaintiffs' characterization of it as the successor by merger with Victor Manufacturing & Gasket Company. The relationship between these entities is described in the following Preliminary Statement. PRELIMINARY STATEMENT Dana is a multinational corporation with thousands of employees at numerous plants and facilities across (he country and aroundTheworld. Dana-manufactures-a .variety .ofindustrial .and vehicular products for original equipment manufacturers and for the aftermarket. In view of Dana's size, it would be overly burdensome to inquire at every Dana plant and facility to respond to these interrogatories. Necessarily, Dana must narrow the scope of its inquiry based upon the allegations ofthe complaint and plaintiffAllen Fuller's deposition testimony. In this case, plaintiffs have named as a defendant Dana Corporation as successor by merger with Victor Manufacturing & Gasket Company. In the 1960's Victor Manufacturing & Gasket Company was dissolved pursuant to and in conformity with relevant provisions of the Illinois Business Corporation Act of 1933, contained at 111. Rev. Stat Ch. 32 74-81 (1967). The Act was in effect in Illinois at the time of the voluntary dissolution of Victor Manufacturing & Gasket Company. Other provisions of the Act governed merger and consolidation. See 111. Rev. Stat. Ch. f DANA-340.080