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
MEDICARE PART A,
CHRYSLER MOTORS CORPORATION, a
Delaware corporation, BECK MOTOR
SALES, INC., a Wisconsin corporation,
PLAINTIFFS' REQUEST FOR PRODUCTION OF DOCUMENTS
TO DEFENDANT CHRYSLER MOTORS CORPORATION
DATED JULY 3, 1990
To: Chrysler Motors Corporation
Plaintiffs, Lester H. Spars and Audrey I. Spars, by their attorneys, hereby
request Defendant, Chrysler Motors Corporation, to produce the documents and
items requested below pursuant to Wisconsin Court Rules within forty-five
(45) days of service at the law offices of Cunningham Lyons & Cabaniss, S.C.,
207 East Michigan Street #400, Milwaukee, Wisconsin 53202, or another mutually
agreed upon location.
DEFINITIONS
1. The term "documents" as used herein 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
communications, reports, memoranda, minutes, bulletins, circulars, instructions,
work assignments, handwritten notes, books, working 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.
3. "Accident Aries" means the 1987 Dodge Aries which was involved in the accident
which is the subject of this lawsuit. (VIN No. 1B3BD26D4HC107681)
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:
Build sheet for the accident Aries.
REQUEST NO. 2:
Owner's manual for the accident Aries.
REQUEST NO. 3:
Service manual for the accident Aries.
REQUEST NO. 4:
All service and/or technical bulletins that relate to the accident Aries.
REQUEST NO. 5:
A copy of your corporate phone books for 1980 through 1987.
REQUEST NO. 6:
Copies of all organizational charts depicting groups or departments at Chrysler
Motors Corporation responsible for the design, development and/or testing
of the transmission and shift components of the accident Aries.
REQUEST NO. 7:
Detail drawings and layout drawings of the following parts:
a) Transmission detent system, including but not limited to spring, rooster
comb, plunger and/or roller, apply rod and cam;
b) Park assembly;
c) Parking pawl;
d) Return spring;
e) Park gear;
f) Gear shift lever;
g) Shift gate;
h) Manual valve;
i) Manual valve body;
j) Drawings of any and all linkage connecting the manual valve to the rooster
comb; and
k) Shift cable.
REQUEST NO. 8:
Copies of pages out of your parts book for the accident Aries which depict
all transmission parts and associated linkage.
REQUEST NO. 9:
All engineering change notices that relate to the transmission or shift
linkage of the Chrysler K car.
REQUEST NO. 10:
All durability test reports for Chrysler K cars.
REQUEST NO. 11:
All documents that detail test procedures for durability testing for Chrysler
K cars.
REQUEST NO. 12:
A copy of your crash test index.
REQUEST NO. 13:
All documents, videotapes, photographs or any other items that detail crash
testing of Chrysler K cars.
REQUEST NO. 14:
All documents, videotapes, photographs or any other items that relate to,
bear upon or concern instrumented testing of the shift system components.
REQUEST NO. 15:
All documents or other items submitted by you or on your behalf to the National
Highway Traffic Safety Administration that relate to, bear upon or concern
the possibility of a Chrysler or any other car experiencing an unintended
gear shift from any point between reverse and park into reverse.
REQUEST NO. 16:
All documents or other items submitted by you or on your behalf to the National
Highway Traffic Safety Administration in response to its investigation of
the park to reverse allegations involving Ford Motor Company products.
REQUEST NO. 17:
The transmission of the accident Aries is identified as PK#4377921 9149
9451, what does this alpha numeric designation mean?
REQUEST NO. 18:
All documents, memorandum, videotapes, photographs or any other items that
relate to, bear upon or concern your evaluation or monitoring of the National
Highway Traffic Safety Administration's investigation into the park to reverse
phenomena with Ford Motor Company products.
REQUEST NO. 19:
All test reports, memorandum or other documents or items that relate to,
bear upon or concern any studies undertaken by you or on your behalf to
evaluate the ability of persons to properly perceive whether or not a transmission
has been fully engaged in park or is at some point in between reverse and
park.
REQUEST NO. 20:
All documents that relate to, bear upon or concern any allegations that
a Chrysler motor vehicle experienced an unintended shift from any point
between reverse and park into reverse.
REQUEST NO. 21:
All documents or other items that relate to any allegations that a Chrysler
transmission and/or shift system is defective in any respect.
REQUEST NO. 22:
Any and all surveys conducted to assess the rate of incidence of unintended
gear shifts from any point between reverse and park into reverse.
REQUEST NO. 23:
All policies of insurance, whether excess or primary, which provide coverage
for the claims in this case.
REQUEST NO. 24:
All print ads for the Chrysler K car.
REQUEST NO. 25:
All film ads for the Chrysler K car.
REQUEST NO. 26:
All correspondence, memorandum or any other items exchanged with the vendor
or vendors of the transmission, shift system or its components.
REQUEST NO. 27:
All Board of Director meeting minutes that relate to, bear upon or concern
the unintended shift of any transmission from any point between reverse
and park into reverse.
REQUEST NO. 28:
All committee, subcommittee meeting minutes that relate to, bear upon or
concern the unintended shift from any point between reverse and park in
the transmission into reverse.
Dated this 3rd day of July, 1990.
CUNNINGHAM LYONS & CABANISS, S.C.
Attorneys for Plaintiffs,
Lester H. Spars and Audrey I. Spars
By: John C. Cabaniss |
Law Office of John C. Cabaniss
250 East Wisconsin Avenue Suite
750 Milwaukee, WI 53202
Telephone 414-278-6066
Facsimile 414-278-1229
cabaniss@cabanisslaw.com
cabaniss@cabanisslaw.com
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