Document X7BovyBkNe2VKGN31BewEzNg4

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OHIO WESTERN DIVISION MARY A. DENDINGER, et al., and ETTA W. WALLACE, et al., Plaintiffs, ) ) ) ) ) ) vs. ) CHRYSLER PLASTIC PRODUCTS CORPORATION, et al., Defendants. ) ) ) ) ) )---------------------------------------------------------------------------------------------------------------------------------------------------------------- CASE NO.: C87-7117 Hon. Nicholas J. Walinski REQUEST FOR PRODUCTION OF DOCUMENTS DIRECTED TO DEFENDANTS Now come plaintiffs, b} lt attorneys, pursuant to Federal Rule of Civil Procedure j<, .d request that defendants produce the following documents for inspection and copying at the offices of Murray & Murray Co., L.P.A., 300 * Central Avenue, Sandusky, Ohio, 44870, on or before the 10th day of November, 1988, at 10:00 a.m. The time for inspection will continue until plaintiff's counsel has had an opportunity to carefully examine and inspect all documents. Plaintiffs' counsel will identify those documents he wishes either to have released to his custody for copying or to have copied by defendants jrray & Murray VUMDAL p Al uwmtj AT law (t. IUMDUIHV. OHIO 4TO ROUTS. /"/ 062462 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OHIO WESTERN DIVISION MARY A. DENDINGER, et al., and ETTA W. WALLACE, et al., Plaintiffs VS CHRYSLER PLASTIC PRODUCTS CORPORATION, et al., Defendants. CASE NO.: C87-7117 Hon. Nicholas J. Walinski REQUEST FOR PRODUCTION OF DOCUMENTS DIRECTED TO DEFENDANTS -0O0- Now come plaintiffs, by and through their attorneys, pursuant to Federal Rule of Civil Procedure 34, and request that defendants produce the following documents for inspection and copying at the offices of Murray & Murray Co., L.P.A., 300 Central Avenue, Sandusky, Ohio, 44870, on or before the 10th day of November, 1988, at 10:00 a.m. The time for inspection will continue until plaintiff's counsel has had an opportunity to carefully examine and inspect all documents. Plaintiffs' counsel will identify those documents he wishes either to have released to his custody for copying or to have copied by defendants Murray & Murray ucc 062463 pursuant to a court order designating a reasonable charge for copying. ^ 101. All correspondence and documents sent to or received from the Manufacturing Chemists Association or any committee thereof, prior to 1975, pertaining to vinyl chloride or polyvinyl .chloride. ^102. All correspondence and documents sent to or received * from any other polyvinyl manufacturer, or any employee thereof, prior to 1975, regarding vinyl chloride or polyvinyl chloride. '103. All internal (within your company) communications, bulletins and memoranda, authored prior to 1975, concerning the actual or potential chronic health effects, including cancer, in animals or humans, of exposure to vinyl chloride. ^*104. All documents in your possession relating to the tentative, preliminary and final results of any studies, surveys, reports, articles, tests or analyses pertaining to the actual or potential chronic health affects, including cancer, in animals or humans, of exposure to vinyl chloride which have not appeared in published medical or scientific journals. 105. All documents in your possession inconsistent with or refuting the sworn deposition testimony in this case of your designated representative(s) regarding RVCM concentrations in your resins. N 106. All documents pertaining to the RVCM concentrations in your resins prior to 1980, which you have not previously produced. 107. Each and every document you intend or expect to introduce into evidence at the trial of this action. 108. Each and every document reviewed or examined by any of your witnesses in the course of preparing for trial testimony. 109. Each and every document which will be used by any of your witnesses in the course of giving trial testimony. ray & Murray PmO^EIIiOHAI. association attounct* AT law MVtHT >O0 ClKTHA JWfMUC fcAMDWft*V. OHIO 4470 2 q'$&4 ??Ch ,and every docuinent upon which any of your witnesses will rely or base his or her trial testimony. Dennis E. Murray, Esq. Kirk J. Delli Bovi, Esq. MURRAY & MURRAY CO., L.P.A. Attorneys at Law 300 Central Avenue Sandusky, OH 44870 Telephone: (419) 627-9700 Attorneys for Plaintiff Murray a Murray * *-*** *Q*,C**to**i' a*toeunOR ATTOUWCV# at LAW huwmy mmn IMOgiKV. OHIO 4*?0 CERTIFICATION This is to certify that a copy of the foregoing was served upon all counsel of record by mailing said copy, postage prepaid, addressed as follows: Robert A. Bunda, Esq. FULLER & HENRY One SeaGate, 17th Floor P. 0. Box 2088 Toledo, Ohio 43603 Attorneys for Defendants this bfL^ day of October, 1988. Kirk J. Delli Bovi Murray & Murray a WlMHim. AAlOClATtOM ATTQNtYy AT LAW SAMOUSKV, O*0 44*70 062466