Fill and Sign the Request Production Form

RESPONSES TO DEFENDANT'S FIRST REQUESTFOR PRODUCTION TO PLAINTIFF Comes now _________, Plaintiff in the above styled and numbered cause, and files this his Responses to Defendant's First Request for Production to Plaintiff, and in support thereof would show unto the Court the following, to wit: 1. The federal and state income tax returns of plaintiff for ____-____, together with all schedules and attachments. RESPONSE: Not available at this tine, however, they will be provided at a later date. 2. All documents pertaining to any examinations, treatment or testing of plaintiff's hearing or ears at any tine. Defendant further requests plaintiff to execute the a ttached authorization so that defendant nay obtain such information from tine to time. RESPONSE: Attached are those, which are in my possession at this tine. 3. All documents related to plaintiff's military service. If these records are not available, defendant requests plaintiff to execute the attached authorization so that defendant may obtain these records. RESPONSE: Not available at this time, however, this information will be provided at a later date. 4. All documents relating to medical treatment or examinations of plaintiff. Defendant further requests plaintiff to execute the attached authorization so that defendant may obtain such information from time to time. RESPONSE: Attached are those, which are in my possession at this time. Plaintiff objects to execution of the authorization. 5. All documents relating to testing of noise levels at any location where plai ntiff worked for defendant. RESPONSE: None at this time. 6. All documents published by defendant, the American Association of Railroads or any other group with which defendant is or has been affiliated referring to noise exposure to railroad workers. RESPONSE: None in my possession at this time. 7. All reports of expert witnesses employed by plaintiff or his attorney. RESPONSE: None at this time. 8. All calculations, measurements, or test results of the hearing, or loss thereof, of plaintiff. RESPONSE: Attached are those, which are in my possession at this time. 9. All documents prepared by O.S.H.A. or any other agency or entity relating to noise levels at defendant's place of business. RESPONSE: None. 10. All documents relating to plaintiff's damages. RESPONSE: Attached are those, which are in my possession at this time. 11. All documents received by plaintiff from defendant relating to any aspect of his employment with defendant. RESPONSE: None at this time. 12. All documents from any source warning or informing plaintiff of exposure to noise. RESPONSE: None at this time. 13. All documents relating to the availability of ear protectors to plaintiff. RESPONSE: None. 14. All photographs of facilities or equipment. RESPONSE: None at this 15. All photographs of available to plaintiff. RESPONSE: None at this time. 16. A recent photograph of plaintiff. RESPONSE: To be provided at a later date. 17. All documents relating to defendant. RESPONSE: None. 18. All standards, regulations, guidelines or laws allegedly violated by defendant. RESPONSE: To be provided at a later date.19. All documents relating to noise exposure at any time, defendant's tools, ear protection devices used or defendant' s facilities. RESPONSE: None at this time. 20. All seniority rosters, personnel file materials, work schedules, safety or work rules, or other similar documents relating to your employment with defendant. RESPONSE: None at this time. 21. All documents relating to complaints made about noise levels at defendant's facilities. RESPONSE: None at this time. 22. All written or recorded statements or memoranda of conversations of defendant's supervisory personnel. RESPONSE: None at this time. 23. All written or recorded statements or memoranda of conversations of defendants part on present employees. RESPONSE: None at this time. 24. All written or recorded statements or memoranda of conversations pertaining to this suit. RESPONSE: None. 25. All documents relating to defendant's knowledge of problems posed by noise exposure. RESPONSE: None. 26. If any documents are being withheld because of a claimed privilege please identify each documents with sufficient specificity that the propriety of the clai m of privilege can be evaluated. RESPONSE: None. Respectfully submitted, ______________________ PLAINTIFF CERTIFICATE I certify that I have this date mailed, postage prepaid, a true and correct copy of the above and foregoing Responses to Defendant's First Request for Production to Plaintiff, to Honorable This the _______ day of __________, _____. ____________________________________ ATTORNEY FOR PLAINTIFF