Document rxEZ9Jakvm1NbZwZ9YpeQaNxa

. 7'7 CAUSE NO. CV-35116 . Q- ; t r Q r> ..)l3v. . ...fSCIJ JUN 2 7 200E CHRISTOPHER STOECKLER and IN THE DISTRICT COURT AT WENDY STOECKLER, Plaintiffs -7-7 V. ' ..." 7.::. V V,; ANGELINA COUNTY, TEXAS AMERICAN OIL COMPANY, et al., 7 ' , .7 Defendants 7 159TH/217TH JUDICAL DISTRICT DANA CORPORATION'S OBJECTIONS AND ANSWERS TO PLAINTIFFS' FIRST SET OF INTERROGATORIES, AND REQUEST FOR PRODUCTION TO DEFENDANTS PRELIMINARY STATEMENT ' These interrogatories seek information about events that occurred many years ago. These responses are based upon a reasonable investigation into the relevant facts and information currently known to Dana. Because the pending litigation against Defendant appears to involve allegations of exposure to Victor Products Division gaskets, and because of the lack of information regarding allegations of exposure to any other type of asbestos-containing products at issue in these cases, Defendant responds to these interrogatories and requests for production at this time for the Victor Products Division (now the Victor Reinz Division), excluding Reinz Wisconsin Gasket Co., for the period 1967 to date. Investigation into other divisions continues and Dana will supplement as new information is known. If plaintiffs provide information of alleged exposure to specific Dana products not encompassed by these responses, Dana will investigate further and may 1 DANA-0340.950