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

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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
otation bearing, pedestal, and any critical fasteners, which is part of the product at issue in this lawsuit. J. The term “KUB” means the Knoxville Utilities Board. K. The term “rotation bearing” means the bearing identified in Defendant Gear Products’ initial disclosures, identified by Plaintiffs as model number 449-05106-L, serial number 97B02214-04, which Plaintiffs have alleged was incorporated into the design of the Versalift. REQUESTS <strong>FOR</strong> PRODUCTION 1. Produce for inspection any parts of the Versalift, including any bolts , critical fasteners, or other parts obtained by you in preparation of this lawsuit or as part of any investigation of or inquiry into this accident. RESPONSE: 2. Produce for inspection and copying all maintenance records regarding, referring or relating to the Versalift for any work performed from the date of manufacturing to present, specifically including but not limited to those documents referring, regarding or relating to the pedestal, critical fasteners, or the rotation bearing. RESPONSE: 3. Produce an exact color copy of all pictures taken by you of the Versalift. RESPONSE: 5
Page 1 and 2: IN THE UNITES STATES DISTRICT COURT
Page 3: B. The word "document" includes any
Page 7 and 8: 9. Produce all documents available
Page 9 and 10: 19. Produce a copy of all standards
Page 11: CERTIFICATE OF SERVICE The undersig

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

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