Document zoan6wmD8dxmm48DX6eE0Ep7B

IN THE CIRCUIT COURT THIRD JUDICIAL CIRCUIT MADISON COUNTY, ILLINOIS IN RE: ALL MADISON COUNTY ASBESTOS LITIGATION FILED BY THE O'BRIEN LAW FIRM BORG-WARNER CORPORATION BY ITS SUCCESSOR IN INTEREST RESPONSES TO PLAINTIFF'S SECOND REQUEST FOR PRODUCTION OF DOCUMENTS Borg-Wamer Corporation (hereinafter referred to as "Borg-Warner") does not currently exist, nor is its successor engaged in the manufacture or sale of asbestos-containing automotive products. A good faith effort has been made to responsively address plaintiffs' discovery to which objections have not otherwise been filed. For this reason, BorgWamer Inc., an entity familiar with the prior automotive operations of Borg-Wamer Corporation, has assisted in the preparation of responses to this discovery on behalf of the Defendant, relying upon information collected from various sources, including information recently identified. Defendant's exploration of its prior operations is continuing and these responses amend and supersede any previously filed responses to discovery in this and any other jurisdiction. Defendant does not purport to have adopted or applied any definitions set forth at the outset of or at other places in plaintiffs' discovery nor has it assumed the improper, unproved and hypothetical facts or accepted the terminology or substance of plaintiffs' claims incorporated in, implied or alluded to within this discovery. In an effort to expand its previous responses to discovery of Borg-Wamer's United States automotive operations these answers address the manufacture and sale of Borg-Wamer clutch materials for automatic transmissions. General Objections 1. Borg-Wamer objects to Plaintiffs' Discovery on the grounds that it is overly broad, unduly burdensome, seeks information which is not relevant to Plaintiffs' cause of action, and seeks information which is not reasonably calculated to lead to the discovery of admissible evidence. Without waiving this objection, and subject to any additional objections herein, BorgWamer provides its Answers herein. 1