Document ZJaO7z63NknkDbOdeKN2oOn17

IN THE IOWA DISTRICT COURT FOR POLK COUNTY THOMAS C. FLOREN, Administrator of the Estate of Pamela S. Floren, deceased, et al., Plaintiffs, vs. THE B. F. GOODRICH COMPANY, et al., Defendants. LAW NO. CL37-21553 RECEIVED MAR 1 7 1961 REQUEST FOR PRODUCTION OK DOCUMENTS TO THE DEFENDANT CONOCO, INC. COMES NOW the Plaintiffs and through their attorneys and pursuant to the Iowa Rules of Civil Procedure request the above-named Defendant to produce or make available the following documents (at the reasonable expense of Plaintiffs) at the offices of Defendant's attorneys of record upon notice to Plaintiffs' attorneys within the time set forth in the above Rules. 1. Material Safety Data Sheets (MSDS) prepared by this Defendant (or in conjunction with the Chemical Manufacturers Association (CMA) formerly Manufacturing Chemists Association) in the last twenty (20) years the subject of which in whole or in part is: -- Polyvinyl chloride (PVC) -- PVC compounds and resins -- PVC materials and products 2. Safety Guides of the Chemical Manufacturers Association (CMA) formerly Manufacturing Association received by this Defend ant in the last twenty (20) years the subject of which in whole or in part is: -- Polyvinyl chloride (PVC) -- PVC compounds and resins PVC materials and product:*. 3. Cui <Io l i nos for _Ui sk__Kya Knar i_on and Loss Proven t i on_i n publieat ion(s) received by this Defendant in the last twenty (20) year:; the subject of which in whole or in part i OCR 0000019-T5 i -- Polyvinyl chloride (PVC) -- PVC compounds and resins - PVC materials and products 4. Index of Case Histories of Accidents in the Chemical Industry publication(s) received by this Defendant in the last twenty (20) years the subject of which in whole or in part is: -- Polyvinyl chloride (PVC) -- PVC compounds and resins -- PVC materials and products 5. Chemical Safety Data Sheets (CSDS) published by the Chemical Manufacturers Association (CMA) formerly Manufacturing Chemists Association and received by this Defendant in the last twenty (20) years the subject of which in whole or in part is: -- Polyvinyl chloride (PVC) -- PVC compounds and resins -- PVC materials and products 6. Any other technical/scientific publications prepared by this Defendant or in conjunction with the Chemical Manu facturers Association (CMA) formerly Manufacturing Chemists Association in the last twenty (20) years the subject of which in whole or in part is: -- Polyvinyl chloride (PVC) -- PVC compounds and resins -- PVC materials and products 2- - CCR OOOOOl976 WILLIAMS Sc LaMARCA "Georgc^A. LaMarca 700 West Towers 1200 35th Street West Des Moines, Iowa 50265 Telephone: (515) 225-1125 ATTORNEYS AND LEAD COUNSEL FOR THE PLAINTIFFS, FLOREN, CURRAN, STEELE, PARR, PETERSEN, ARMSTRONG, REINERTSON, HEARN and SATROMS DUNCAN, JONES, RILEY & FINLEY Steven K. Scharnberg 404 Equitable Building Pes Moines, Iowa 50309 Telephone: (515) 288-0145 ATTORNEYS FOR PLAINTIFF, YOUNKERS, INC. -3- CCft 000001977