Chrysler Dodge Aries - Park to Reverse: Document Requests
STATE OF WISCONSIN - CIRCUIT COURT - MILWAUKEE COUNTY
LESTER H. SPARS, AUDREY I. SPARS,
and WISCONSIN PHYSICIANS SERVICE
MEDICATE PART A,
V.
CHRYSLER MOTOR CORPORATION,
BECK MOTOR SALES,
PLAINTIFF' S SECOND REQUEST FOR PRODUCTION OF DOCUMENTS
TO DEFENDANT CHRYSLER MOTOR CORPORATION
TO: CHRYSLER MOTOR CORPORATION
Plaintiffs Lester H. Spars and Audrey I. Spars, by their
attorneys, hereby request Defendant Chrysler Motor Corporation
produce the documents and items requested below pursuant to Wisconsin
Court Rules within thirty (30) days of service at the Law Offices of
Cunningham Lyons & Cabaniss, S.C., 207 E. Michigan St., Suite 400,
Milwaukee, WI 53202, or another inutually agreed upon location.
DEFINITIONS
1. The term "documents" is used in a comprehensive sense and
includes without limitation and without limiting the generality of
its meaning, purchase orders, vouchers, work orders, invoices,
letters, telegrams, intracorporate coittirtunications, reports,
memoranda, minutes, bulletins, circulars, instructions, work
assignments, handwritten notes, books, workinq assignment paper,
formal and informal sketches, design drawings, production drawings,
manufacturing drawings, service drawings, assembly drawings and any
other drawings, however designated, specifications, blueprints, full-
size engineering and design layouts, full-size installation and assembly
layouts, tracings and microfilm thereof, photographs, shorts, drafts,
worksheets, advertisements, catalogs, periodicals, proving ground records,
consultations, communications, experiments, videotape, movie film, studies
and other writings and physical objects of whatever nature, including
copies of mechanical and photocopy reproductions of any or all of the
foregoing items.
2. "You", "your" and "yours" means Chrysler Motors
Corporation, its officers, directors, managing agents, employees and
all acting on all persons, including attorneys that act on behalf of
each entity individually and/or collectively.
INSTRUCTIONS
If, in response to this request for production of documents, you
withhold production of any document on the ground of a privilege,
please state with respect to each said document:
(a) The type of document involved and a general description of
the contents of the document;
(b) The names, business and residence addresses, and telephone
numbers, and position of the individual(s) from whom
the documents emanated;
(c) The names, business and written addresses and telephone
numbers and position of each individual(s) to whom the
document or copy of document was sent;
(d) The date of each document;
(e) The privilege upon which said Defendant relies on in
withholding the document;
(f) The facts upon which the Defendant relies on in support of
its claim that it is privileged to withhold such document;
(g) The names, business and resident addresses and telephone
numbers, and positions or occupations of
individual(s) known or believed by Defendant to have
knowledge concerning the factual basis for Defendant's
assertion of privileged work product with regard to the
document.
REQUESTS
REQUEST NO. 1:
Copies of the Minutes of the Vehicle Regulation Committee
wherein the topic of the NHTSA Peer Review Inquiry regarding the Ford
"Park-to-Reverse" situation, and/or Chrysler Motors response thereto
was discussed, mentioned, or otherwise brought before the Committee.
REQUEST NO. 2:
Copies of the Minutes of the Vehicle Regulation Committee
wherein the NHTSA Inquiry regarding the Center for Auto Safety
petition requesting investigation of an alleged failure of the
automatic transmission to engage or hold in the Park position in
certain Chrysler Motors vehicles, and/or Chrysler Motors response
thereto was discussed, mentioned, or otherwise brought before the
Committee.
REQUEST NO. 3:
Copies of any other Minutes of the Vehicle Regulation Committee
wherein the issue of a failure to engage or hold in a Park position
or a "Park-to-Reverse" situation was mentioned, discussed or
otherwise brought before the Committee.
REQUEST NO. 4:
Copies of each complaint filed against Chrysler prior to October
10, 1988, wherein it was alleged that a Chrysler K-platform,
minivan, or either Chrysler vehicle with the same or similar
transaxle assembly as the subject 1987 Dodge Aries, failed to hold
or engage in the park position or otherwise shifted unintentionally
from the park to reverse position.
REQUEST NO. 5:
Copies of each deposition transcript of the plaintiff in each
lawsuit filed against Chrysler prior to October 10, 1988, wherein it
was alleged that a Chrysler K- platform, minivan, or either Chrysler
vehicle with the same or similar transaxle assembly as the subject
1987 Dodge Aries, failed to hold or engage in the park position or
otherwise shifted unintentionally from the park to reverse position.
REQUEST NO. 6:
Copies of the accident report from each accident which was the
subject of each lawsuit filed against Chrysler prior to October 10,
1988, wherein it was alleged that a Chrysler K- platform, minivan, or
either Chrysler vehicle with the same or similar transaxle assembly
as the subject 1987 Dodge Aries, failed to hold or engage in the park
position or otherwise shifted unintentionally from the park to
reverse position.
DATED: March 26, 1991.
CUNNINGHAM LYONS & CABANISS
Attorneys for the Plaintiffs
By
John C. Cabaniss
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