Document rxdL03kDz08gYyG1Z4Ky18gn0

KJDB:sg04/14/86 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OHIO WESTERN DIVISION ETTA WALLACE, personal representative of the Estate of Fred A. Wallace, et al.. Plaintiffs, -vs- C-HRYStER PLASTIC PRODUCTS CORPORATION, et al.. Defendants. REQUESTS FOR PRODUCTION OF DOCUMENTS DIRECTED TO ALL DfFEKPANT PVC MANUFACTURERS Case No.': C84-7864 . Judge Nicholas J. Walinski -0O0- Pursuant to Ohio Rule of Civil Procedure 34, plaintiffs request that the following documents be produced for Inspection and copying at the offices of Hurray & Murray Co., L.P.A., 300 Central Avenue, Sandusky, Ohio, within 30 days after service of the following requests for production of documents. 1. All records of sales, direct or Indirect, of Polyvinyl Chloride (PVC) resin from you to Chrysler Plastic Products Corporation (Chrysler) between January 1, 1967 and December 31, 1980. 2. All documents indicating the extent to which PVC resin sales to Chrysler during the time period indicated above, represented sales of PVC resin manufactured in the: (a) suspension; (b) emulsion; (c) bulk; or, (d) solution process. 3. All documents indicating the extent to which PVC resin sales to Chrysler during the time period specified In request number 1, were ia.LHmopolyroer;iurray K Murray ^ cP1y,neri or <c) terpolymer. a ico4i, *orist>OH*k moetaTtoN *TTO*(T| at k*W wif awtkfw* HWUk taNCUHV. OHIO MWQ UCC 082498 4. All written documents Indicating, with respect to PVC resin sold to Chrysler during the time period specified above, the size (in microns) of the resin sold. 5. All written documents Indicating the results of any tests done on any PVC resin by you or any other entity to determine the concentration (in parts per million) of residual vinyl chloride monomer in PVC resin of the type sold to Chrysler during the time period specified in request number 1. 6. ATI Material Safety Data Sheets published by you prior to * January 1, 1986, relating to any PVC resin manufactured by you. 7. All documents in your possession Indicating the dates of manufacture and the dates of shipment of PVC resin sold to Chrysler. 8. All written results of any testing done on the PVC resin identified In the prior request to determine the concentration of residual vinyl chloride monomer. 9. All documents sent by you to the Occupational Safety & Health Administration, relating, In any way, to PVC. 10. All documents reporting or summarizing efforts taken by you, at any time since January 1, 1967 to reduce the percentage of residual vinyl chloride monomer in PVC resin manufactured by you. Murray S Murray co..l..a. mw el****!. Rwemic UMOUlItT, 0MM I HTQ -2- UCC 082499 11. Each and every document sent to Chrysler, informing Chrysler of any known or potential human health hazards relating to exposure or over exposure to vinyl chloride monomer. MURRAY & MURRAY CO., L.P.A. 300 Central Avenue Sandusky, Ohio 44870 Phone: (419) 627-9700 Attorneys for Plaintiffs Iurray 5 Murray a * **ort**jQ**L AmaoeifttfO* ATTON|T| at caw MMMY ANeUfkY. Ohio 4WTO UCC 082500 -3-