Form 6H:32 Defendant's RFP - Jones Act
REQUEST FOR PRODUCTION
{INSERT APPLICABLE STANDARD REQUESTS - FORM 6H:3}
REQUEST 10: Produce all materials showing that {plaintiff/decedent} is a seaman under the Jones Act, 46 U.S.C. §§30104-30105.
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REQUEST 11: Produce all materials showing that {plaintiff/decedent} was acting in the course and scope of {his/her} employment at the time of the accident.
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REQUEST 12: Produce all correspondence, memoranda, and other materials between {plaintiff/decedent} and any other person, partnership, corporation, firm, or entity relating to the subject matter of this suit.
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REQUEST 13: Produce all medical records relating to the following:
a. {Plaintiff/Decedent}'s personal injuries that are the subject of this suit.
b. Any previous personal injuries or preexisting conditions of {plaintiff/decedent}.
c. Any personal injuries sustained after those that are the basis of this suit.
d. {Plaintiff/Decedent}'s mental or emotional condition for the last ten years.
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REQUEST 14: Produce all materials showing that {plaintiff/decedent} missed work as a result of {his/her} injuries.
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REQUEST 15: Produce all materials showing that a defect or malfunction in the ship or its equipment contributed to the cause of the accident.
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REQUEST 16: Produce all materials given to {plaintiff/decedent} by defendant in connection with {plaintiff/decedent}'s employment.
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REQUEST 17: Produce all materials, including those given by {plaintiff/decedent}'s fellow employees and prepared in the ordinary course of business, that are in plaintiff's possession, custody, or control concerning the accident that is the basis of this lawsuit.
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REQUEST 18: Produce all preemployment physical reports for {plaintiff/decedent}.
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REQUEST 19: Produce all materials that plaintiff contends show defendant was negligent in any manner.
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REQUEST 20: Produce all materials that plaintiff contends show defendant violated applicable rules, regulations, or statutes.
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REQUEST 21: Produce all materials that plaintiff contends show the vessel {name of vessel} was unseaworthy.
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REQUEST 22: Produce all notes, calendars, diaries, or other materials providing a record of events relating to the accident or complaints raised by plaintiff in the lawsuit.
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REQUEST 23: Produce all materials showing all amounts of money paid to {plaintiff/decedent} by defendant in the five years before the accident.
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REQUEST 24: Produce all rules, regulations, management or operating guidelines, or other materials that plaintiff contends were in effect at the time of the accident and were not followed by defendant.
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REQUEST 25: Produce all surveillance footage, videotapes, tape recordings, photographs, sketches, or drawings that have been made of defendant, {his/her/its} equipment or property, or the scene of the accident.
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REQUEST 26: Produce all rules, regulations, ordinances, statutes, or laws that plaintiff contends were violated by defendant causing the accident that is the basis of this lawsuit.
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REQUEST 27: Produce all materials that plaintiff contends show the {name of vessel} was in navigation at the time of the accident that is the basis of this lawsuit.
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REQUEST 28: Produce all materials showing that defendant received notice about any matter that plaintiff contends was not properly addressed by defendant and that contributed to the accident that is the basis of this lawsuit.
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REQUEST 29: Produce all job applications, résumés, correspondence, or other materials {plaintiff/decedent} submitted to any person or entity in an attempt to obtain employment in the last ten years.
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REQUEST 30: Produce all applications for life insurance, health insurance, or disability insurance that {plaintiff/decedent} filed with any company in the last ten years.
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REQUEST 31: Produce all materials plaintiff sent to or received from any other employee of defendant that mentioned the accident or injuries involved in this lawsuit.
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REQUEST 32: Produce all tax returns filed within the last ten years.
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REQUEST 33: Produce all materials that plaintiff contends show defendant did not fully pay {plaintiff/decedent} maintenance and cure payments.
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