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LAW OFFICES OF GROUP ONE State Bar No. 00000000 123 South Secondary Street San Jose, CA 95333 Phone: 408-555-1212 Fax: 408-555-1234 Attorney for PLAINTIFF, ANNE ANDERSON, for herself, and as a Parent and Next Friend of CHARLES ANDERSON, and as Administratrix of the Estate of JAMES ANDERSON ||  ||
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SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF SANTA CLARA

Plaintiff, vs. BEATRICE FOODS INC., A California Corporation, Defendant. || ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) || Case No.: 1234513789 **PLAINTIFF’S FIRST SET OF REQUEST FOR PRODUCION OF DOCUMENTS** ||
 * ANNE ANDERSON, for herself, and as a Parent and Next Friend of CHARLES ANDERSON, and as Administratrix of the Estate of JAMES ANDERSON,

DEMANDING PARTY: PLAINTIFF, ANNE ANDERSON or herself, and as a Parent and Next Friend of CHARLES ANDERSON, and as Administratrix of the Estate of JAMES ANDERSON

RESPONDING PARTY: DEFENDANT, BEATRICE FOODS INC.

SET NUMBER: ONE

Pursuant to Code of Civil Procedure section 2031.010 et seq., PLAINTIFF, ANNE ANDERSON, for herself, and as a Parent and Next Friend of CHARLES ANDERSON, and as Administratrix of the Estate of JAMES ANDERSON., hereby demands that responding party produce for inspection and copying at the Law Office of Group One, 123 South Secondary Street San Jose, California, at the hour of 10:00 a.m. on June 10,1982, all matters and things set forth below in the possession of responding party, his/her/their/its agents or anyone acting on their behalf. ** I. **** INSTRUCTIONS ** A. Unless otherwise noted, this set of requests requires the production of documents or tangible things that were prepared, created, written, sent, dated or received at any time up to the date of service of your response to these requests. B. In producing documents or tangible things pursuant to these requests, please identify the following: i. The paragraphs or subparts of the demand to which each document or tangible thing corresponds; and ii. The location from which the document or tangible thing was produced, including address, file, drawer, or cabinet name and number. C. If you withhold any document or tangible things under a claim of privilege, please furnish with your response to these demands the statement required by California Code of Civil Procedure Section 2031.240(b), identifying each document or tangible thing for which privilege is claimed, including the following information: i. The date, sender, recipient, and subject matter of the document or tangible thing; ii. The relationship between the author of each of said recipients at the time the document or tangible thing was received by the recipient; iii. The basis upon which privilege is claimed; iv. The paragraphs, paragraph or subparts of the demand to which the document of tangible thing corresponds; and v. The general description of the subject matter of the information contained in the document or tangible thing. D. In the event that any requested document and tangible thing can only be obtained from a computer or any other electronic media, such information should be printed out and provided as well as provided on the media on which the information and programs that access it are stored are produced. E. Unless specifically requested, duplicative originals or copies that are absolutely and totally identical to a produced document or tangible thing need not also be produced. However, any duplicate that is in any way different (e.g., contains notes or has missing material) must also be produced. F. In answering these requests, the agency is requested to furnish not only such information as is available to the agency but also such information as is known to any of the agency’s agents, representatives, employees, servants, consultants, contractors, subcontractors, investigators, attorneys, and any other PERSON or entity acting or purporting to act on behalf of the agency. G. DOCUMENTS are to be labeled to indicate the question to which they respond.

**II.** **DEFINITIONS**

A. “PLAINTIFF” and “COMPLAINANT” means and refers to ANNE ANDERSON and includes any of her current or former agents, representatives and attorneys. B. “DEFENDANT” means and refers to BEATRICE FOODS, INC. and includes any of its current or former agents, representatives and attorneys. C. “CORPORATION,” “COMPANY,” “YOU,” “YOUR,” or “YOURSELF,” means BEATRICE FOODS, INC., the named corporation in this case, and any and all of its agents, representatives, employees, servants, consultants, contractors, subcontractors, investigators, attorneys, and any other PERSONS or entities acting or purporting to act on behalf of the agency. D. “PERSON”, “PERSONS,” “PEOPLE”, and “INDIVIDUAL” means any natural PERSON, together with all federal, state, county, municipal and other government units, agencies or public bodies, as well as firms, companies, corporations, partnerships, proprietorships, joint ventures, organizations, groups of natural persons or other associations or entities separately identifiable whether or not such associations or entities have a separate legal existence in their own right. E. “DOCUMENT,” “DOCUMENTS,” and “WRITING” means all records, papers, and books, transcriptions, pictures, drawings or diagrams or every nature, whether transcribed by hand or by some mechanical, electronic, photographic or other means, as well as sound reproductions of oral statements or conversations by whatever means made, whether in YOUR actual or constructive possession or under YOUR control or not, relating to or pertaining to or in any way to the subject matters in connection which it is used and includes originals, all file copies, all other copies, no matter how prepared and all drafts prepared in connection with such writing, whether used or not, including by way of illustration and not by way of limitation, the following; books; records; reports; contracts; agreements; expense accounts; canceled checks; catalogues; price lists; video, audio and other electronic recordings; memoranda (including written memoranda of telephone conversations, other conversations, discussions, agreements, acts and activities); minutes; diaries; calendars; desk pads; scrapbooks; notes; notebooks; correspondence; drafts; bulletins; electronic mail; facsimiles; circulars; forms; pamphlets; notice; statements; journals; postcards; letters; telegrams; publications; inter- and intra- office COMMUNICATIONS; photostats; photographs; microfilm; maps; drawings; diagrams; sketches; analyses; electromagnetic records; transcripts; and any other documents within DEFENDANT’S possession, custody or control from which information can be obtained or translated, if necessary, by detection devices into reasonably usable form, i.e. typed in English prose. F. “TCE” means and refers to the chemical trichloroethylene. G. “PERC” means and refers to the chemical tetrachloroethylene. H. The connectives “and” and “or” shall be construed either disjunctively or conjunctively as necessary to bring within the scope of the discovery request all responses that might otherwise be construed to be outside of its scope. I. “COMMUNICATION” or “COMMUNICATIONS” means any and all inquiries, discussions, conferences, conversations, negotiations, agreements, meetings, interviews, telephone conversations, letters correspondence, notes telegrams, facsimiles, electronic mail, memoranda, or other forms of COMMUNICATIONS, including but not limited to both oral and written COMMUNICATIONS. J. “SURROUNDING AREA” means the area located within a one (1) mile radius of THE TANNERY. K. “ESI” means electronically stored information or in hard copy format. L. “THE TANNERY” shall mean YOUR tannery located in Woburn, CA. M. “WRITING” as used in this request for identification and production is a broadly inclusive term referring to any and all written or other graphic material, however produced or reproduced, of every kind and description and to everything upon which sounds, words, symbols or pictures are recorded or depicted by magnetic or electrical impulse, photography, or otherwise. The term "writing" includes, by way of example and not limitation, the following and anything similar to any of the following: i. Letters, telegrams, telexes, cables, TXWs, memoranda, interoffice correspondence and other forms of correspondence and written communication; ii. Agreements, contracts, policies, handbooks, practice guidelines, reports, studies, records, books, journals, papers, statements, pamphlets, circulars, publications, stenographic notebooks, files and their contents, file folders, file covers, file jackets, and notes; iii. Summaries, abstracts, indexes, tabulations, graphs, charts, lists and inventories; iv. Calendars, desk calendars, appointment books, schedules, logs, telephone messages, diaries, time sheets, minutes of meetings, and transcripts; v. Financial statements, checks, invoices and accounting records and books; vi. Pleadings, deposition transcripts, trial transcripts, interrogatories, answers to interrogatories, affidavits, declarations, papers filed or lodged with courts, and papers filed with or sent to administrative agencies. vii. Tape recordings, sound reproductions, objects, photographs, motion pictures, microfilm, computer data stored on magnetic tape, computer printouts, data processing cards or tapes, and computer disks or diskettes. (Evid.Code,§250)

** III. **** ITEMS TO PRODUCE **

**REQUEST NO. 1:** Produce all agreements, documents, ESI, and reports relating to the corporate organization of BEATRICE FOODS, INC.

**REQUEST NO. 2:** Produce all agreements, documents, ESI, and reports that relate to supplier contracts, proposed supplier contracts, draft supplier contracts, contemplated supplier contracts, or supplier offers of contracts of which product Trichloroethylene is mentioned between 1950 and present.

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**REQUEST NO. 3:** Produce all agreements, documents, ESI, and reports that relate to supplier contracts, proposed supplier contracts, draft supplier contracts, contemplated supplier contracts, or supplier offers of contracts of which product Perchloroethylene is mentioned between 1950 and present.

**REQUEST NO. 4:** Produce all agreements, documents, ESI, and reports that BEATRICE FOODS, INC. relied upon for employee safety training from 1950 to present.

**REQUEST NO. 5:** Produce all agreements, documents, ESI, and reports that constitute compliance with all Federal Environmental Regulations between 1950 to the present.

**REQUEST NO. 6:** Produce all agreements, documents, ESI, and reports that constitute any environmental testing conducted between 1950 to the present.

**REQUEST NO. 7:** Produce all documents which describe the responsibilities of management and employees working at THE TANNERY.

**REQUEST NO. 8:** Produce all documents which in any way relate or pertain to the safety of the employees, working at THE TANNERY.

**REQUEST NO. 9:** Produce all documents where the Environmental Protection Agency references any testing conducted at THE TANNERY.

**REQUEST NO. 10:** Produce all documents which in any way relate, refer or pertain to any use of TCE at THE TANNERY. **REQUEST NO. 11:** Produce all documents which in any way relate, refer or pertain to THE TANNERY’S disposal of TCE.

**REQUEST NO. 12:** Produce all documents which in any way relate, refer or pertain to any use of PERC at THE TANNERY.

**REQUEST NO. 13:** Produce all documents which in any way relate, refer or pertain to the storage of PERC at THE TANNERY. **REQUEST NO. 14:** Produce all documents which in any way relate, refer or pertain to THE TANNERY’S disposal of PERC.

**REQUEST NO. 15:** Produce all documents which in any way relate, refer or pertain to the handling of THE TANNERY chemicals.

**REQUEST NO. 16:** Produce all documents which in any way relate, refer or pertain to the supervisory structure of THE TANNERY.

**REQUEST NO. 17:** Produce any documents, which in any way relate, refer, or pertain to any hydrologic or soil testing done on the 15-acre lot abutting THE TANNERY.

**REQUEST NO. 18:** Produce all formula books which identify the chemicals used during the manufacturing process at THE TANNERY.

**REQUEST NO. 19:** Produce all documents which in any way relate, refer or pertain to the July 12, 1956 report by A.C. Bolde, a sanitary engineer at the state public health department, which demanded you clean up THE TANNERY waste.

**REQUEST NO. 20:** Produce all documents which in any way relate, refer or pertain to complaints made by neighbors about the smell of THE TANNERY.

**REQUEST NO. 21:** Produce all documents which in any way relate, refer or pertain to tests made on the 15-acre lot abutting THE TANNERY.

**REQUEST NO. 22:** Produce all documents which in any way relate, refer or pertain to the manufacture of leather at THE TANNERY from 1960 to 1969.

**REQUEST NO. 23:** Produce all documents reflecting any communications from residents of Woburn, CA and/or employees of THE TANNERY regarding any concerns relating to the water supply in Woburn, CA from 1950 to present.

**REQUEST NO. 24:** Produce all written reports of each person whom YOU expect to call as an expert witness at trial. **REQUEST NO. 25:** Produce all documents that any expert witness YOU intend to call at trial relied to form an opinion.

**REQUEST NO. 26:** Produce t he most recent resume or curriculum vitae of each expert whom YOU expect to call as an expert witness at trial.

**REQUEST NO. 27:** Produce all documents, notes, correspondence, bills, invoices, diagrams, photographs, or other documents prepared or reviewed by each person whom you expect to call as an expert witness at trial.

**REQUEST NO. 28:** Produce all **YOUR** financial records, including but not limited to **YOUR** pay stubs, pay checks, bank statements, and investment statements for the period from 1950 to present.

**REQUEST NO. 29:** Produce all documents that contain or otherwise relate to the facts or information that YOU contend refute, in any way, the allegations contained in the Complaint in this action.

**REQUEST NO. 30:** Produce all documents for each interrogatory set forth in PLAINTIFFS' First Interrogatories, produce all documents which YOU referred to, relied upon, consulted or used in any way in answering such interrogatory. //** If any document is withheld from production under a claim of privilege or other exemption from discovery, state the title and nature of the document, and furnish a list signed by the attorney of record giving the following information with respect to each document withheld: **// // (i) the name and title of the author and/or sender and the name and title of the recipient; // // (ii) (ii) the date of the document's origination; //

**REQUEST NO. 31:** Produce all documents that identify procurement receipts of any and all chemicals used in cleaning equipment at THE TANNERY from 1950-present. **REQUEST NO. 32:**

Produce all documents that identify receipts of disposal of waste from the barrels use at THE TANNERY.

**REQUEST NO. 33:** Produce all documents that identify the names of suppliers used to purchase storage containers used at THE TANNERY from 1950-present.

**REQUEST NO. 34:** Produce all documents that identify the safety management and Human Resources personnel at THE TANNERY from 1950-present.

**REQUEST NO. 35:** Produce all documents of receipts from chemical storage facilities in the Town of Woburn, CA and **SURROUNDING AREAS** from 1950-present.

**REQUEST NO. 36:** Produce all documents that identify all management responsibilities at the TANNERY from 1950-present.

**REQUEST NO. 37:** Produce all documents that identify all standards of operating procedures in handling of any chemical at the TANNERY.

**REQUEST NO. 38:** Produce all documents that identify detailed employment records of individuals who worked at THE TANNERY from 1950-present.

**REQUEST NO. 39:** Produce all documents that identify all conduct by the Board of Directors of BEATRICE FOODS INC.

**REQUEST NO. 40:** Produce all documents upon which YOU rely in support of your contention that there is no custodian of records for the organizational chart of BEATRICE FOODS INC.

**REQUEST NO. 41:** Produce all documents that identify the names of individuals responsible for facilities management at THE TANNERY from 1978-present.

**REQUEST NO. 42:** Produce all documents provided to THE TANNERY from the EPA or any safety inspections.

**REQUEST NO. 43:** Produce all documents, agreements and records that relate to THE TANNERY employees who have inadequately disposed of TCE.

**REQUEST NO. 44:** Produce all documents, agreements and records that relate to THE TANNERY employees who have inadequately disposed on PERC. **REQUEST NO. 45:** Produce all documents, agreements and records that relate to any persons or TANNERY employees disposing waste containing TCE on YOUR 15-acre lot in Woburn, CA between 1950 to date of production.

**REQUEST NO. 46:** Produce all documents, agreements and records that relate to any persons or TANNERY employees disposing waste containing PERC on YOUR 15-acre lot in Woburn, CA between 1950 to date of production.

**REQUEST NO. 47:** Produce all documents, agreements and records that relate to how often any persons or TANNERY employees disposed waste containing TCE on YOUR 15-acre lot in Woburn, CA between 1950 to date of production.

**REQUEST NO. 48:** Produce all documents, agreements and records that relate to the amount of TCE waste in gallons that was disposed of each year between 1950 to date of production at THE TANNERY.

**REQUEST NO. 49:** Produce all documents, agreements and records that relate to how often any persons or TANNERY employees disposed waste containing PERC on YOUR 15-acre lot in Woburn, CA between 1950 to date of production.

**REQUEST NO. 50:** Produce all documents, agreements and records that relate to the amount of PERC waste in gallons that was disposed of each year between 1950 to date of production at THE TANNERY.

**REQUEST NO. 51:** Produce all documents, agreements and records that relate to other agents that were allowed by YOUR COMPANY to dump waste containing TCE at THE TANNERY between 1950 to date of production.

**REQUEST NO. 52:** Produce all documents, agreements and records that relate to other agents that were allowed by YOUR COMPANY to dump waste containing PERC at THE TANNERY between 1950 to date of production.

**REQUEST NO. 53:** Produce all documents, agreements and records that relate to the amount of TCE waste in gallons that was disposed of by other agents each year between 1950 to date of production.

**REQUEST NO. 54:** Produce any and all documents (ESI or in hard copy format) pertaining to any safety complaint by any employee at THE TANNERY from 1950 to the present. **REQUEST NO. 55:** Produce any and all documents (ESI or in hard copy format) pertaining to any notice, notification, memoranda or letter prepared by any employee at THE TANNERY relating to the chemical PERC from 1950 to the present.

**REQUEST NO. 56:** Produce any and all documents (ESI or in hard copy format) pertaining to any notice, notification, memoranda or letter prepared by any employee at THE TANNERY relating to the chemical TCE from 1950 to the present.

**REQUEST NO. 57:** Produce any and all documents (ESI or in hard copy format) pertaining to any notice, notification, memoranda or letter prepared by YOU or other PERSONS to any Woburn, CA resident relating to the chemical TCE from 1950 to the present.

**REQUEST NO. 58:** Produce any and all documents (ESI or in hard copy format) pertaining to any notice, notification, memoranda or letter prepared by YOU or other PERSONS to any Woburn, CA resident relating to the chemical PERC from 1950 to the present.

**REQUEST NO. 59:** Produce any and all documents (ESI or in hard copy format) pertaining to any physical illness complained of by any employee at THE TANNERY from 1950 to the present.

Dated: __May 10, 1982__ __ AMANDA HALL Attorney for PLAINTIFF ANNE ANDERSON, for herself, and as a Parent and Next Friend of CHARLES ANDERSON, and as Administratrix of the Estate of JAMES ANDERSON

**PROOF OF SERVICE** I am employed in the City of San Jose, County of Santa Clara, California. I am over the age of 18 and not a party to the within action. My business address is LAW OFFICES OF GROUP ONE, 123 South Secondary Street, San Jose, CA 95333. On May 10, 1982, I served a copy of the below-listed document(s) described as: **PLAINTIFF’S FIRST SET OF SPECIAL INTERROGATORIES TO DEFENDANT BEATRICE FOODS INC.**

** ¨ ** **BY U.S. MAIL:** I enclosed the document(s) listed above in a sealed envelope or package, addressed to the person(s) at the address(es) set forth above and placed the envelope or package for collection and mailing, following this firm’s ordinary business practices. I am readily familiar with this firm’s practice for collecting and processing of documents for mailing. Under that practice, on the same day that document(s) is/are placed for collection and mailing, it/they is/are deposited in the ordinary course of business with the U.S. Postal Service, in a sealed envelope or package with postage fully prepaid. ** ¨ ** **BY FAX TRANSMISSION:** I faxed the document(s) to the persons at the fax numbers listed above. No error was reported by the fax machine that I used. A copy of the record of the fax transmission containing the time, date, and sending fax machine telephone number, which I printed out, is available upon request. ** ¨ ** **BY HAND-DELIVERY:** I served the document(s) by placing it/them in an envelope or package addressed to the persons at the addresses listed above and providing them to a professional messenger service for service. A copy of the professional messenger’s proof of delivery is available upon request. ** þ ** **BY E-MAIL:** I caused the document(s) to be served electronically on the persons at the electronic notification addresses listed below. ** ¨ ** **BY OVERNIGHT DELIVERY:** I enclosed the documents in an envelope or package provided by an overnight delivery carrier and addressed to the person(s) at the address(es) listed above. I placed the envelope or package for collection and overnight delivery at an office or a regularly utilized drop box of the overnight delivery carrier.

I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed on May 10, 1982, at San Jose, California.
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Amanda Hall