Document rxnbJnQ6JOgD1p0ZDbB8j0RJa

CAUSE HO. 93-03625-1 0Cr 7995 &AROi\i & HELEN GAMBRELL, Individually S and as the Special S Administratrix of the Estate of ROBERT GAMBRELL, Deceased S S vs. S s THE ABER COMPANY, ET AL S IN THE DISTRICT COVRT?iJU& DALLAS COUNTY, TEXAS 162ND JUDICIAL DISTRICT DEFENDANT EMERSON ELECTRIC CO.'fi FIRST SUPPLEMENTAL ANSWER TO PLAINTIFFS' MASTER SET OF INTERROGATORIES TO: Helen Gambrell, by and through her attorney of record, Mr. Russell W. 6udd, BARON & BUDD, The Centrum, 3102 Oak Lawn Avenue, Suite 1100, Dallas, Texas 75219. COMES NOW, Defendant Emerson Electric Co. and makes and files this its First Supplemental Answer to Plaintiffs' Master Set of Interrogatories as to Interrogatory No. 62, and would show unto the Court as follows: GENERAL OBJECTIONS Emerson Electric Co. has a number of divisions and subdivisions. The only division identified in this litigation is Wiegand Division. The only subdivision is Appleton Electric Co. which has separately responded to these Master Interrogatories and Request for Production. Emerson Electric Co. objects to these interrogatories and Request for Production to the extent this discovery requests information concerning any other division or subsidiary as such requests are overbroad, unduly burdensome, assumes facts not in evidence, seek information that is not relevant nor reasonably calculated to lead to the discovery of admissible evidence and constitutes a fishing expedition on behalf PEFPNDAWT EMERSON ELECTRIC CO.'S FIRST SUPPLEMENTAL ANSWER TO PLAINTIFFS' MASTER SET OF INTERROGATORIES PAGE 1 F:\EDW\053008UPJNT SC-ELEC-11180 of the Plaintiff. The answers to the discovery requests are made subject to such objection and are only on behalf of the Wiegand Division of Emerson Electric Co. No other division of Emerson Electric has been identified by Plaintiff. INTERROGATORIES INTERROGATORY NO. 62* Please identify documents which will be used at time of trial, (Exhibit List, Deposition List), which are relevant to each of Defendant's enumerated defenses in Defendant's last filed Answer. RESPONSE* Emerson Electric Co. adopts and incorporates the general objection in its response to this interrogatory as though set out verbatim. However, subject to said objections and without waiving same, see attached Defendant's Exhibit List, marked Exhibit MAM. Respectfully submitted, DeHay & Elliston, L.L.P. 1500 Maxus Energy Tower 717 North Harwood Street Dallas, Texas 75201-6508 Telephone (214) 953-5454 Telecopier (214) 953-5455 (i, A (*xaUjjfitA. GARY D. ELLISTON State Bar No. 06584700 ERIC D. WEWERS State Bar No. 21236650 DCTKMDMTT EMERSON ymftTRTg CO.'S FIRST SUPPLEMENTAL ANSWER TO PIAIKTIFTS' MASTER SET OF INTERROGATORIES PAGE 2 F:\EDW\0i300SUPJNT CERTIFICATE OP SERVICE I HEREBY CERTIFY that a true and correct copy of the above and foregoing document has been forwarded to counsel for Plaintiff, Hr. Russell W. Budd, BARON & BUDD, The Centrum, 3102 Oak Lawn Avenue, Suite 1100, Dallas, Texas 75219 by certified mail, return receipt requested and to all other counsel of record by U. S. Hail, postage prepaid, on this the 3rd day of October, 1995. DEFSNPJUtT EMERSON fT.Wirrpyc CO.'S FIRST SUPPLEMENTAL ANSWER TO PIAXWTIFFS' MUSTER SET Or INTERROGATORIES PAGE 3 P:\EDW\0S3ODSUPJNT