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

4. Produce for inspection and copying all service, operation, and other manuals in
your possession regarding, referring or relating to the Versalift, concerning the manufacture,
assembly, testing, marketing, maintenance, repair, safety, or operation of the Versalift.
RESPONSE:
5. Produce a copy of any documents in your possession at any time referring,
regarding, or relating to any investigation of the accident on March 11, 1998 wherein Plaintiff
Jimmy Claiborne was injured, including but not limited to any drawings, sketches, notes,
photographs, models, videotape, computer generated materials, computer files, e-mail, recorded
statements, or any other documents in your possession at any time from March 11, 1998 to
present.
RESPONSE:
6. Produce all documents identified by you in response to Interrogatory No. 5.
RESPONSE:
7. Produce all documents regarding, referring or relating to any and all testing
identified in your response to Interrogatory No. 6.
RESPONSE:
8. Produce all documents identified by you in response to Interrogatory No. 8.
RESPONSE:
6