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Fill and Sign the Offered Trial Form

Fill and Sign the Offered Trial Form

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Open the document and fill out all its fields.
Apply your legally-binding eSignature.
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___________________ ___________________ ___________________ Dear ____________: Pursuant to the Court's Pre-Trial Order, the following is a listing of the exhibits that Plaintiff may offer into evidence: 1. ____________ Corporation Safety Sign Kit No. 1 for V-Type Printer-Slotter (Depo. of Lawrence Taylor) 2. Letter from ____________ Company to mead containers Division dated 4/2/71, RE: Safety Information - Solid (Non-Split) Printer-Slotters (Depo. of ____________). 3. Letter from ____________ Company to Mead Container Division dated 4/2/71, RE: Safety Information - Solid (Non-Split) Printer-Slotter (Depo. of ____________). 4. Wash-up procedure for ____________ "V" type printer-slotter (Without Baldwin Press Washer) (Depo. of ____________). 5. Information on Safety Kits offered by ____________ (Depo. of ____________). 6. Illustration of ____________ Type "VI" (Depo. of ____________). 7. Drawing of Type "YZ" Printer-Slotter (Depo. of ____________). 8. Drawing of Type " VZ" Printer-Slotter (Depo. of ____________). 9. Drawing of Mounting Area (Depo. of ____________). 10. Floor Plan Type "VP" Special Printer-Slotter Drawing No. 6557-11 (Depo. of ____________). 11. Data Sheet from National Safety Council on "Management Safety Policies" (Depo. of Lawrence Taylor). 12. Data Sheet from National Safety Council on "Printer-Slotters" (Depo. of ____________). - 1 - 13. Photograph (Depo. of ____________). 14. Photograph (Depo. of ____________). 15. Photograph (Depo. of ____________). 16. Photograph (Depo. of ____________). 17. Photograph (Depo. of ____________). 18. Photograph (Depo. of ____________). 19. Photograph (Depo. of ____________). 20. Photograph (Depo. of ____________). 21. Photograph (Depo. of ____________). 22. Photograph (Depo. of ____________). 23. Photograph (Depo. of ____________). 24. Photograph (Depo. of ____________). 25. Vol. 19, No. 2, ____________ Leader, Sept. 1973 (Depo. of ____________). 26. Fountain Configuration (Depo. of ____________). 27. Printer-Slotter Data drawing (Depo. of ____________). 28. Printer-Slotter file (Depo. of ____________). 28.A *(Number reserved for document to be supplied) Additional documents with Printer-Slotter file (Depo. of ____________). 29. ______________ Liability Claim (Depo. of ____________). 30. __________ Liability Claim (Depo. of ____________). 31. ________________ Liability Claim (Depo. of ____________). 32. Position Description (Depo. of ____________). 33. Memo 3/30/93 (Depo. of ____________). 34. Trouble Shooting Guide (Depo. of ____________). - 2 - 35. V2 Printer-Slotter 7051 (Depo. of ____________) 36. Maintenance Bulletin #5 (Depo. of ____________) 37. Printer-Slotter Data (Depo. of ____________) 38. Telephone Data Information Sheet 6/15/93 (Depo. of ____________) 39. Drawing VSX (Depo. of ____________) 40. Drawing 2/27/46 (Depo. of ____________) 41. Invoice (Depo. of ____________) 42. Copy of Business card (Depo. of ____________) 43. * (Number reserved for document to be supplied) A letter stating change of procedure for routing inquiries to Custom Engineering without unilaterally supplying instruction manuals and parts manuals. (Depo. of ____________) 44. * (Number reserved for document to be supplied)Survey that shows known entries on the V style or V type printer-slotters (Depo. of ____________) 45. ____________ corporate history (Depo. of __________________) 46. Amended Notice of Deposition (Depo. of __________________) 47. Saturn IV ____________ Flexo Folder Gluer - Operator's Procedure Manual (Technical Literature) 48. Zero Energy State (ZES) for fishing machinery - ____________ Saturn IV Flexo, folder gluer, counter injector 49. Medical illustration 50. Medical illustration 51. Medical illustration 52. Medical illustration - 3 - 53. Mortality table 54 Summary of medical bills with bills attached Dr. ___________ will have additional exhibits that you can review at his deposition and we will number there. Please let me know by tomorrow if you want me to have those exhibits ready now for you. As you can expect, there will be many governmental standards or industry standards or regulations that would be applicable and/or which form the basis of Dr. _______________’s opinions which have been provided. These will be numbered separately and will be in addition to those, which have been enumerated above. My recollection is that I have identified for you Dr. ______________ and provided you a summary of his opinions as well as _________________, a vocational expert. You did mention to me you wanted to take Dr. _________________'s deposition. Do you want to take _________________'s deposition? The doctors that did the operation on _______________ are all out of state. Two are in _________________ and one is in _______________. Let me know if you have any objection to taking videotape depositions of those doctors. There are two in _______________, _____________ and we can do those on the same date (hopefully). With respect to lost wages and lost future wages, that evidence will be based, in part, on _______________'s opinion with respect to Mr. ______________'s earning capacity and/or anticipated future earnings. As you know, Mr. _______________ has lost considerable wages from the time of his injury and will lose wages in the future because of the severity of his injury. If you would like my calculation, please advise. These exhibits are available for your inspection at our office. The mortality tables cover the Acts of ______________. We have photographs of the medical illustrations which can be - 4 - sent to you and if you would like a copy of the summary of medical bills and/or bills, please advise. This may save you a trip downtown. Sincerely, __________________ - 5 -

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