Document ykOZXBRVK4nJ0RBqOz4eBdXDn

^y<TE OF NORTH DAKOTA COUNTY OF BURLEIGH Ruben Biech Kristi Kresge Oscar Kroll Luverne Wedwick IN DISTRICT COURT SOUTH CENTRAL JUDICIAL DISTRICT Civil No. 95-C-2162 95-C-2325 9S-C-21 66 95-C-2327 DEFENDANT 8QRG-WARNER CORPORATION'S ANSWERS TO PLAINTIFFS' INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO DEFENDANT (SET 11 % TO: ABOVE-NAMED PLAINTIFFS AND THEIR ATTORNEY, JEANETTE T. BOECHLER, ONE N. 2ND STREET, STE 314, PO BOX 1932, FARGO, ND 58107 Though Borg-Warner Corporation has made every good faith effort to respond to those Interrogatories to which it has not objected, in making such response, Borg-Warner Corporation does not purport to have adopted or applied any definitions set forth at the outset of or at other places in Plaintiff's Interrogatories nor has Borg-Warner assumed the improper, unproved and hypothetical facts set forth, implied or alluded to in Plaintiff's Interrogatories or accepted those allegations of Plaintiff's claims or argumentative terminology or alluded to in those Interrogatories. Defendant, Borg-Warner, objects to Plaintiff's definition of "asbestos products" as being overly broad, ambiguous, misleading and unlimited in scope. Therefore, without waiving this objection, BorgWarner has responded to Plaintiff's Interrogatories only with regard to automotive or motor products to which Plaintiff is claiming exposure, i.e. brake and clutch products, only with regard to the Borg-Warner divisions which have manufactured or sold them and only with regard to U.S. operations. The responses made herein are made without in any way' waiving or intending to waive, but on the contrary intending to reserve and reserving: (1) the right to object on the grounds of competency, privilege, relevancy SCF-ALLF-00075 S-DC-004.13