IN THE UNITES STATES DISTRICT COURT FOR THE EASTERN ...

2. Business address and business telephone number(s);
3. Principal occupation;
4. Connection or relationship to any of the parties, issues or facts of this
case.
Where the subject is other than a natural person, give:
a. Its full name;
b. The address of its principal office and its principal place of
business;
c. The nature of its principal business, profession, function or
purpose; and
d. Its connection or relationship to the parties, issues or facts of this
case.
F. The word “statement” as used in these Interrogatories and Requests for
Production means any written document, recording of an oral conversation or monologue by a
person, as defined herein, by electronic or any other means, or any other archival of words
issued, uttered, spoken, or adopted by such person, made for the purpose of recording factual
information or opinions concerning an event, occurrence, incident, or other happening.
G. The phrase “the accident” or “this accident” refers to the accident alleged in the
Complaint from which Plaintiff suffered the injuries complained of in this case.
H. The term “the product” or “bucket truck” means the Ford F-800 identified by
V.I.N. 1FDYF80E9WVA20329, including the VO42-MHI Versalift identified by Serial No.
AY9709, which is the product at issue in this lawsuit.
I. The term “Versalift” means the boom arm model VO42-MHI, identified as Serial
No. AY9709, as well as any component parts making up the arm, including but not limited to the
4