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9. Produce all documents available to you regarding, referring or relating to any and<br />

all testing activities performed by persons or laboratories identified in your response to<br />

Interrogatory No. 11.<br />

RESPONSE:<br />

10. Produce all documents regarding, referring or relating to any and all lawsuits<br />

identified in your response to Interrogatory No. 12.<br />

RESPONSE:<br />

11. Produce all documents regarding, referring or relating to any incident, event or<br />

occurrence identified in your response to Interrogatory No. 13.<br />

RESPONSE:<br />

12. Produce all documents regarding, referring, or relating to any complaints by<br />

operators, maintenance personnel, supervisors, or any other persons about the Versalift as they<br />

relate to the operation, maintenance, repair and service of the Versalift.<br />

RESPONSE:<br />

13. Produce a copy of all articles and documents identified in your Answer to<br />

Interrogatory No. 14.<br />

RESPONSE:<br />

7

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