Product Liability Airbag Case Request For Production Of Documents

COMES NOW the Plaintiff, by and through his undersigned counsel, and files this her first Request for Production of Documents as follows:

In all items listed below, it shall be understood that the crash test data requested refers to vehicles of the class representative of the crash test performance of the subject vehicle. If there are variances or modifications in vehicle structures making them different from the subject vehicle, these must be identified.

If variances or modifications in vehicle structures making them different from the subject vehicle are identified, performance a list of these and identify where an assessment of the crash-response performance is made so as to deem data from these non-similar vehicles useful in characterizing the subject vehicle class.

1. Produce all acceleration/displacement/kinematics/electrical-performance charts recorded for vehicles and/or manikins in passive-restraints-verification crash tests involving frontal full-barrier collisions (complete barrier), for SRS/air bag deploy/non deploy verification. Data to include, but is not limited to:
   1. Location and direction of impact to be stated with engineering measurement precision, i.e., lateral location of central intrusion vector (inches or mm) and angle of PDOF (degrees)

 

1. Time line from front bumper impact through vehicle rebound and stop, showing frame velocity, G forces at front of vehicle, G forces at driver position, G forces at sensor positions

 

1. Time line from front bumper impact to arming/safing and crash/discriminating sensor closures

 

1. Time line from front bumper impact to driver air bag squib fire electrical pulse, including magnitude and duration of the electrical fire pulse

 

1. Time line from front bumper impact to passenger air bag squib fire electrical pulse, including magnitude and duration of the electrical fire pulse

 

1. Manikin and/or passenger motion vs. time after impact, wearing seat belt

 

1. Manikin and/or passenger motion vs. time after impact, not wearing seat belt

 

1. All recordations of manikin and/or passenger motion vs. time after impact in crash or sled tests, including videotape, computer data acquisition, charts, etc.

 

1. All recordations of air bag envelope deployment after impact in crash or sled tests, including videotape, computer data acquisition, charts, etc.

 

1. All recordations of SRS ECU and/or squib circuit electrical performance, including analog electrical data and crash-record EEPROM download data. This to include all data whether the on-vehicle SRS ECU is used as a primary SRS deploy controller, or the SRS ECU is serving only in a ride-along capacity.

 

1. All video and photographic recordations of static and dynamic body crush, including any grid overlays for dimensional analysis

 

1. Identify whether air bags were manually fired or fired by the production-level-in-vehicle system including its production-level sensors

 

1. Produce all acceleration/displacement/kinematics/electrical-performance charts recorded for vehicles and/or manikins in passive-restraints-verification crash tests involving vehicle-vehicle impact collisions, for SRS/air bag deploy/non deploy verification. This data to include any bullet vehicle underriding target truck/trailer/other-vehicle crash tests. Data to include, but is not limited to:

 

1. location and direction of impact to be stated with engineering measurement precision, i.e., lateral location of central intrusion vector (inches or mm) and angle of PDOF (degrees)

 

1. time line from front bumper impact through vehicle rebound and stop, showing frame velocity, Gforces at front of vehicle, G forces at driver position, G forces at sensor positions

 

1. time line from front bumper impact to arming/safing and crash/discriminating sensor closures

 

1. time line from front bumper impact to driver air bag squib fire electrical pulse, including magnitude and duration of the electrical fire pulse

 

1. time line from front bumper impact to passenger air bag squib fire electrical pulse, including magnitude and duration of the electrical fire pulse

 

1. manikin and/or passenger motion vs. time after impact, wearing seat belt

 

1. manikin and/or passenger motion vs. time after impact, not wearing seat belt

 

1. all recordations of manikin and/or passenger motion vs. time after impact in crash or sled tests, including videotape, computer data acquisition, charts, etc.

 

1. all recordations of air bag envelope deployment after impact in crash or sled tests, including videotape, computer data acquisition, charts, etc.

 

1. all recordations of SRS ECU and/or squib circuit electrical performance, including analog electrical data and crash-record EEPROM download data. This to include all data whether the on-vehicle SRS ECU is used as a primary SRS deploy controller, or the SRS ECU is serving only in a ride-along capacity.

 

1. all video and photographic recordations of static and dynamic body crush, including any grid overlays for dimensional analysis

 

1. identify whether air bags were manually fired or fired by the production-level in-vehicle system including its production-level sensors

 

1. Produce all functional crash-performance requirements specifications given to passive-restraint sensor/ECU suppliers. If such functional crash-performance requirements specifications contain sub-parts, or multiple-condition deployment criteria, include all such specification sub-parts in the specification supplied.

 

1. If such specifications include must-fire/must-not-fire metrics, produce these.

 

1. If such specifications include example crash test data, provide the list of such crash-test data and provide documentation for the vehicle used as the subject of the crash test.

 

1. If such specifications include energy reserve performance criteria [deployment and/or diagnostics] in the event of primary power supply malfunction, include such criteria.

 

1. If such document originals are larger than letter size, produce a original-size copy of such documents.

 

1. Provide a list of all structural/mechanical changes incorporated in the subject vehicle that were not incorporated in the [each] crash test vehicle.

 

1. Produce all supplier algorithm-simulation response-to-test-crash acceleration signatures/profiles for vehicle-manufacturer-provided functional crash-performance requirements specifications.

 

1. If such functional crash-performance simulation summaries contain sub-parts, or multiple-condition deployment criteria, include all such summary sub-parts in the specification supplied.

 

1. If such documents are color coded, produce the color versions of such documents

 

1. If such document originals are larger than letter size, produce a original-size copy of such documents.

 

Respectfully submitted