General Motors Corporation-Rear Lap Belt-No Shoulder Belt:
Document Requests


STATE OF WISCONSIN-CIRCUIT COURT-DANE COUNTY

ELIZABETH D. WOLF and RICHARD
A. WOLF, wife and husband,
and KATE E. WOLF, a minor child,
and PHYSICIAN'S PLUS INSURANCE
CORPORATION, a Wisconsin corporation,

Case No. 92-CV-3140
Products Liability-30100
v.




GENERAL MOTORS CORPORATION,
a Delaware corporation, and
AHRENS OLDSMOBILE-CADILLAC,
INC., a Wisconsin corporation,

PLAINTIFFS' REQUEST FOR PRODUCTION OF DOCUENTS
DATED MARCH 18, 1993
GENERAL MOTORS CORPORATION
c/o Michael J. Gonring, Esq.
Quarles & Brady
411 East Wisconsin Avenue
Milwaukee, WI 53202

Barry E. Fields, Esq.
Kirkland & Ellis
200 East Randolph Drive
Chicago, IL 60601
TO:
















Plaintiffs, by their attorneys, hereby request that the defendants, pursuant to S 804.09, Wis. Stats., produce within thirty (30) days the following documents and things for inspection and copying at the offices of Cunningham Lyons & Cabaniss, S.C., 207 East Michigan Street, Suite 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" and/or "General Motors" means the General Motors Corporation, its officers, directors, employees and/or wholly owned subsidiaries.

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:

REOUESTS
 1. All documents, films, photographs or other items produced by General Motors in the case captioned Wendv Kummer. et al. V. General Motors Corporation, Milwaukee County Circuit Court.

2. All documents, films and other items that relate to the car-to-car crash tests series conducted in 1966.

3. All documents, reports, photographs or other items created in connection with all accident investigations conducted by or on behalf of Mr. Wil Nelson that involved an injury to an occupant wearing a lap belt only.

4. All worker's compensation records, investigative reports or documents that relate to, bear upon or concern injuries received by any employee of General Motors that were received when that employee was involved in an accident wearing a lap belt only.

5. The design content book for the 1988 Oldsmobile Ciera.

6. All deposition transcripts of any current or former General Motors employee from any case where it was alleged a General Motors vehicle was defective for not having rear lap\shoulder belts.


P.O. ADDRESS:

CUNNINGHAM LYONS & CABANISS, S.C.
207 East Michigan Street, Suite 400
Milwaukee, WI 53202
Phone: (414) 271-4655
Back to Article