Document zQbovzR0XYL3BGn7j1gpM47w6
IN THE CIRCUIT COURT THIRD JUDICIAL CIRCUIT MADISON COUNTY, ILLINOIS
IN RE: ALL ASBESTOS LITIGATION FILED BY THE SIMMONS FIRM, LLC,
Plaintiffs, vs.
A.W. CHESTERTON, et al., Defendants.
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FORD MOTOR COMPANY'S ANSWERS TO PLAINTIFFS' INTERROGATORIES
Defendant Ford Motor Company ("Ford") herein submits its Answers to Plaintiffs'
Interrogatories to Ford Motor Company as follows.
PRELIMINARY STATEMENT AND GENERAL OBJECTIONS
Ford's answers to plaintiffs' interrogatories have been prepared in accordance with the
Illinois Rules of Civil Procedure, pursuant to a reasonable and duly diligent investigation and
search for the documents and information requested. Ford has not completed its investigation of
the facts relating to this litigation. Consequently, Ford's answers to plaintiffs' interrogatories
reflect all of the responsive information identified by Ford pursyant to a reasonable and duly
diligent search in those areas where such information is expected to be found in the United
States. To the extent these interrogatories purport to require more. Ford objects because (a) they
seek to compel Ford to conduct a search beyond the scope of permissible discovery contemplated
by the applicable rules of evidence and procedure, and (b) compliance with the interrogatories
would impose an undue burden and expense on Ford. The following answers are given without
prejudice to Ford's right to produce evidence of any subsequently discovered facts. Ford also