Document zdKzb8JwmQZ7qERbvY7Lv8mwg

PLAINTIFF'S EXHIBIT MWD/17410-0001 \ SRS-23 Atty. No. 3027 IN THE CIRCUIT COURT FOR THE SEVENTEENTH JUDICIAL CIRCUIT WINNEBAGO COUNTY, ILLINOIS RUSSELL BREMER and BARBARA BREMER Plaintiffs, vs. METROPOLITAN LIFE INSURANCE CO., et al., Defendants. ) ) ) ) ) ) ) ) ) ) Case No: 01 L133 DEFENDANT SEARS, ROEBUCK and CO.'s SUPPLEMENTAL RESPONSES TO PLAINTIFFS' INTERROGATORIES NOW COMES Defendant, SEARS, ROEBUCK and CO. (hereinafter "Sears") and supplements its responses to Plaintiffs' Interrogatories 1, 4(b) and 4(g) as follows: 1. Defendant objects to this interrogatory as it is overly broad, unduly burdensome, irrelevant and not reasonably calculated to lead to the discovery of admissible evidence. However, without waiver, Defendant states that it has conducted an investigation of the products at issue in this matter, namely Joint Cement for Dry Wall, Ready Mixed Joint Cement, Patching Plaster and Spackling Paste and has determined that these products did not contain asbestos. 4(b). See Sears Chemical Specialty Information sheets for Joint Cement, Ready Mixed Joint Cement, Patching Plaster and Spackling Paste, dated December 6, 1967. These documents set forth the formulas for these products. These products did not contain asbestos. 4(g). Not applicable. Respectfully submitted, FREEBORN & PETERS Michael W. Drumke, one of the attorneys for Defendant SEARS, ROEBUCK and CO. Michael W. Drumke Kenn Brotman Freeborn & Peters 311 South Wacker Drive, Suite 3000 Chicago, IL 60606-6677 (312) 360-6000 #427425 / 2 OCT. 17.2001 11 ' 34AM nu. l-'.d-'cil STATE OP ILLINOIS COUNTY Sf COOK SS 2 Kenneth L. Vermilion, being duly sworn, states that he is an Assistant Secretary and an authorized agent for the purpose of executing this document on behalf of Sears, Roebuck and Co.; that while he does not have personal knowledge of all of the facts recited in the foregoing document, the statements and information made herein have been collected and made available to him by counsel and employees of Sears, Roebuck and Co.; that the information contained herein is true and correct to the best of his knowledge and belief and the document is, therefore/ verified on behalf of Sears, Roebuck and Co. SUBSCRIBED AND,SWORN TO B L, Vermilion on this day of _ certify which witness my hand and~ me by the sBaaLJiLdUyAyTKVCenneth L___., 220oQ2LI, to office. Notary Public in and for the State of Illinois