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Personal Inj. Prod. Liability | New York Northern
Memorandum of Law
MEMORANDUM OF LAW re 27 Motion for Miscellaneous/Other Relief,, w/ Cert. of Service filed by Crystal Elwell, Lucas Elwell. (Attachments: # 1 Declaration of Seth A. Dymond in Opposition to Crown's Motion to Preclude Camerota, P.E., # 2 Exhibit(s) A - Crystal Dep., # 3 Exhibit(s) B - Accident Report, # 4 Exhibit(s) C - Training Guide, # 5 Exhibit(s) D - Operator Manual excerpt, # 6 Exhibit(s) E - Lucas Dep. excerpt, # 7 Exhibit(s) F - Manzel Dep. excerpt, # 8 Exhibit(s) G - 1991 Kmart letter, # 9 Exhibit(s) H - 1996 letter, # 10 Exhibit(s) I - special door orders and related correspondences, # 11 Exhibit(s) J - door use survey responses, # 12 Exhibit(s) K - 1987 RC - Door Notes, # 13 Exhibit(s) L - current webpage - doors, # 14 Exhibit(s) M - breakdown of foot accidents, # 15 Exhibit(s) N - various foot accident reports, # 16 Exhibit(s) O - Romauldi report excerpt, # 17 Exhibit(s) P - 1985 Sevart letter, # 18 Exhibit(s) Q - 1993 Ballot vote, # 19 Exhibit(s) R - 1991 Dunlap letter, # 20 Exhibit(s) S - Camerota Dep. excerpts, # 21 Exhibit(s) T - Grisez Dep. excerpts, # 22 Exhibit(s) U - Warning sticker mock-up)(Dymond, Seth)
MEMORANDUM OF LAW re 28 Motion for Summary Judgment,, w/ Cert. of Service filed by Crystal Elwell, Lucas Elwell. (Attachments: # 1 Declaration of Seth A. Dymond in Opposition to Crown's Motion for Summary Judgment, # 2 Exhibit(s) A - Crystal Dep., # 3 Exhibit(s) B - Accident Report, # 4 Exhibit(s) C - Training Guide, # 5 Exhibit(s) D - Operator Manual excerpt, # 6 Exhibit(s) E - Lucas Dep. excerpt, # 7 Exhibit(s) F - Manzel Dep. excerpt, # 8 Exhibit(s) G - 1991 Kmart letter, # 9 Exhibit(s) H - 1996 letter, # 10 Exhibit(s) I - special door orders and related correspondences, # 11 Exhibit(s) J - door use survey responses, # 12 Exhibit(s) K - 1987 RC - Door Notes, # 13 Exhibit(s) L - current webpage - doors, # 14 Exhibit(s) M - breakdown of foot accidents, # 15 Exhibit(s) N - various foot accident reports, # 16 Exhibit(s) O - Romauldi report excerpt, # 17 Exhibit(s) P - 1985 Sevart letter, # 18 Exhibit(s) Q - 1993 Ballot vote, # 19 Exhibit(s) R - 1991 Dunlap letter, # 20 Exhibit(s) S - Camerota Dep. excerpts, # 21 Exhibit(s) T - Grisez Dep. excerpts, # 22 Exhibit(s) U - Warning sticker mock-up, # 23 Exhibit(s) V - 1987 ASME B56.1 meeting minutes excerpt, # 24 Statement of Material Facts Plaintiffs' Response to Crown's SOF and Statement of Additional Material Facts in Dispute)(Dymond, Seth)
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