General Motors Corporation-Rear Lap Belts-No Shoulder Belts:
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
AHRENS OLDSMOBILE-CADILLAC,
INC., a Wisconsin corporation,

PLAINTIFFS' REQUESTS FOR PRODUCTION OF DOCUMENTS
DATED JULY 12, 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 . 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: