Document jgMbDo3jVvJpxDmo4x51d8eNN
"predecessor** entity to Dana. Further, because Dana is a company
employing thousands of people, it would be practically impossible
to inquire of all Dana's officers, directors, employees, or
partners about their individual knovledge and Dana objects to doing
so.
9. Dana objects to each interrogatory or part thereof as
unreasonable, unduly burdensome or expensive, given the needs and
parameters of this case, to the extent that the interrogatories
relate or may relate to defendant's vehicular products.
10. Defendant objects to each interrogatory and part thereof
to the extent that the interrogatory seeks information about events
that occurred, or may have occurred, prior to the incorporation of
Smith & Kanzler Company in 1964 or after Dana's sale of Smith &
Kanzler Company stock in 1969.
*
11. Defendant objects to each interrogatory or part thereof
that seeks to determine the knovledge, familiarity, or awareness of
Dana.
It is not possible to state precisely if or when a
corporation can be said to have such knowledge; that is a mixed
question of fact and lav. Defendant objects to imputing knovledge,
familiarity or awareness of an employee or employees or agent or
agents of Dana.
12. Dana objects to each interrogatory and part thereof
calling for opinions rather than facts.
13. Dana objects to each interrogatory unless plaintiff's
identify a product injuring them for which Dana is responsible.
The objections stated above are incorporated by reference in
each response herein, as if fully set forth below. No such
pEFENDANT'S RESPONSES AND OBJECTIONS TO PIAIWTIFPS INTERROGATORIES ANP REQUESTS FOR PRODUCTION f:\asb3\rogs.all
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