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

19. Produce a copy of all standards identified by you in response to Interrogatory No.
19.
RESPONSE:
20. Produce all documents upon which any non-expert witness identified by you in
your Answer to Interrogatory No. 20 expects to rely upon as part of the basis of his or her
testimony you propose to offer at the trial of this case.
RESPONSE:
21. Produce all non-privileged documents regarding, referring, or relating to the
impropriety or incorrectness identified by you in your response to Interrogatory No. 21.
RESPONSE:
22. Produce a copy of all non-privileged documents upon which you rely upon in
formulating your Answer to Interrogatory No. 22.
RESPONSE:
23. Produce all notes, records, memoranda, or other documents regarding, referring,
or relating to conversations between you and KUB concerning the Versalift, the product, or any
matter regarding, referring, or relating to the substance of the accident or this lawsuit.
RESPONSE:
9