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

STATE OF WISCONSIN - CIRCUIT COURT - DANE COUNTY
CIVIL DIVISION

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
ARRENS OLDSMOBILE-CADILLAC,
INC., a Wisconsin corporation,

PLAINTIFFS' REQUESTS FOR ADMISSION To
GENERAL MOTORS CORPORATION DATED JULY 9, 1993

To: GENERAL MOTORS CORPORATION
CIO Barry E. Fields, Esq.
Kirkland & Ellis
200 East Randolph Drive
Chicago, IL 60601

Michael J. Gonring, Esq.
Quarles & Brady
411 East Wisconsin Avenue
Milwaukee, WI 53202


Plaintiffs, by their attorneys, Cunningham Lyons & Cabaniss, S.C., request that the defendant General Motors Corporation admit or deny in writing, within thirty (30) days, pursuant to S 804.19 Wis. Stats., the following facts, and if they can not truthfully admit or deny such facts, defendant shall set forth in detail the reasons why such admissions or denials cannot be made:

DEFINITIONS
1. The term "subject vehicle" refers to the 1988 Oldsmobile Cutlass Ciera which is the subject of this litigation.

ADMISSIONS

1. That General Motors designed its restraint systems so as to prevent the transfer of slack from the chest section to the lap section under impact loading for 1988 model year cars.

2. That the meeting minutes of the Automotive Safety Technical Committee dated September 7, 1965 include the notation that the "restraint system must be designed so as to prevent the transfer of slack from the chest section to the lap section under impact loading".

3. That it has been a restraint system design goal of General Motors since 1965 to design its car restraint systems so as to prevent the transfer of slack from the chest section to the lap section under impact loading.

4. That since May 5, 1982, General Motors has maintained a design manual entitled, "Belt Restraint Systems Design Procedures and Performance Considerations".

5. That the manual entitled, "Belt Restraint Systems Design Procedures and Performance Considerations" has been used in connection with the design of automobile restraint systems at General Motors since 1982.

6. That the manual entitled, "Belt Restraint Systems Design Procedures and Performance Considerations" provides that slack in the lap belt can increase the possibility of submarining.

7. That the manual entitled, "Belt Restraint Systems Design Procedures and Performance Considerations" provides that slack in the lap belt can increase lap belt peak load and the time to require achieve significant loading of the lap belt.

8. That the manual entitled, "Belt Restraint Systems Design Procedures and Performance Considerations" provides that slack in the lap belt can increase total hip travel.

9. That the manual entitled, "Belt Restraint Systems Design Procedures and Performance Considerations" provides that slack in the lap belt can increase the potential for higher femur loads (depending on vehicle configuration).

10. That the manual entitled, "Belt Restraint Systems Design Procedures and Performance Considerations" provides that slack in the lap belt can induce head travel.

11. That the manual entitled, "Belt Restraint Systems Design Procedures and Performance Considerations" provides that slack in the lap belt can be minimized in order to reduce HIC.

12. That the manual entitled, "Belt Restraint Systems Design Procedures and Performance Considerations" provides that slack in the shoulder belt has more influence on HIC and head travel than slack in the lap belt.

13. That the manual entitled, "Belt Restraint Systems Design Procedures and Performance Considerations" provides it is usually beneficial to minimize slack in the lap belt.




P.O. ADDRESS: 207 East Michigan Street
Suite 400
Milwaukee, WI 53202
(414) 271-4655


CO-COUNSEL: Anthony C. Anegon, Esq.
Aherin & Rice, P.A.
1212 Idaho Street
P.O. Drawer 698
Lewiston, ID 83501-0698



I certify that on 7/9/93, I
mailed the within papers on all
counsel of record pursuant to
S 801.14(2) Wis. Stats.




John C. Cabaniss

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