1. Identify the specific provision(s) of each governmental or industry regulation, standard, guideline, recommendation, accepted practice, or custom that you contend was applicable to the design, manufacture, performance, testing, certification, or safety of the component(s) at issue at the time The Product left the manufacturer's control. (Standard Product Liability Interrogatory No. 1.)

2. State whether The Product underwent any change in its condition between the time it left the manufacturer's control and the time of the occurrence and, if so, describe each change in condition. (Standard Product Liability Interrogatory No. 2.)

3. State whether The Product underwent any change in its condition between the time of the occurrence and the present and, if so, describe each change in condition. (Standard Product Liability Interrogatory No. 3.)

4. State whether, at any time after the occurrence, you or any person on your behalf examined The Product or any of its components and, if so, describe the nature and results of each examination, identify the person who performed it, and identify each document that refers to it. (Standard Product Liability Interrogatory No. 4.)

5. State whether, at any time, you or any person on your behalf conducted any test, study, or other analysis concerning possible safety or health hazards of The Product [or of any substantially similar product] and, if so, describe the nature and results of each test, study, or analysis, state when it was performed, identify each person who performed it, and identify each document that refers to it. (Standard Product Liability Interrogatory No. 5.)

6. If you intend to use at trial a simulation (computer or actual), experiment, test, or analysis, describe each simulation, experiment, test, or analysis, identify the person who created or performed it or who intends to perform it, and identify each document that refers to it. (Standard Product Liability Interrogatory No. 6.)

7. Identify each document that depicts or purports to depict the occurrence or scene of the occurrence. (Standard Product Liability Interrogatory No. 7.)

8. Identify each document that depicts or purports to depict the condition of The Product or any of its components at the time of or after the occurrence. (Standard Product Liability Interrogatory No. 8.)

9. State the date, place, and circumstances under which you first became aware that exposure to or use of The Product [or any substantially similar product] may be harmful or hazardous, identify each source of information leading to your awareness, and identify the harm or hazards of which you became aware. (Standard Product Liability Interrogatory No. 9.)

10. Identify each person (other than your attorney or an expert retained in anticipation of litigation or preparation for trial who is not expected to be called as a witness at trial) who has made any written or oral report, memorandum, or statement to you or anyone acting on your behalf regarding the cause of the occurrence, and identify each document that constitutes or refers to each such report, memorandum, or statement. (Standard Product Liability Interrogatory No. 10.)

31. If you contend that any product information was or should have been provided with The Product at the time of its sale or distribution to the end user, state the subject matter of the product information, identify the person responsible for providing the product information, and identify each document that constitutes or refers to the product information. (Standard Product Liability Interrogatory No. 31.)

32. Identify and describe each study, experiment, test, or analysis, performed by you or on your behalf, that mentions any adverse effects of the use of The Product [or any substantially similar product]. (Standard Product Liability Interrogatory No. 32.)

33. State whether any product information concerning [insert a description of the particular use or risk at issue in the case] was changed in any way with respect to The Product [or any substantially similar product] during the period [date] through [date]. (Standard Product Liability Interrogatory No. 33.)

34. Identify each safety-related product information, sign, display, or other document furnished by you to sellers for display in their sales facilities from [date] through [date] that concerned The Product [or any substantially similar product]. (Standard Product Liability Interrogatory No. 34.)

35. Describe each change that was made to each item identified in your answer to the preceding Interrogatory, state whether the change was furnished by you to sellers of The Product or their customers, and state when the change was furnished to the sellers or their customers. (Standard Product Liability Interrogatory No. 35.)

36. If at any time before the occurrence you or anyone on your behalf made any statement regarding the safety of The Product [or any substantially similar product]:

37. If you contend that the plaintiff was given any written or oral product information concerning The Product at any time before the occurrence, as to each product information:

38. If you or anyone on your behalf provided to the plaintiff any technical literature, product brochure, or promotional literature concerning The Product at any time before the occurrence:

39. If you are aware of any lawsuit or other claim based upon an allegation that a defect in a component substantially similar to the component(s) at issue was a cause of any personal injury, death, or property damage, as to each:

40. If there has been any federal or state governmental or industry investigation of the safety of The Product or [any substantially similar product or] the component(s) at issue [or any component substantially similar to the component(s) at issue]:

41. If you or any agent or employee of yours expressly warranted or guaranteed The Product, state the exact words of each warranty or guarantee, and when, where, and by what means the warranty or guarantee was given. (Standard Product Liability Interrogatory No. 41.)

42. If you contend that you or any agent or employee of yours disclaimed any warranty or guarantee of The Product, state the exact words of each disclaimer, whether you contend that the person harmed by The Product was or should have been aware of the disclaimer, and when, where, and by what means the disclaimer was made. (Standard Product Liability Interrogatory No. 42.)

43. Explain the meaning of each code word, code number, or other symbol appearing on The Product, including any that identifies the place of manufacture, the date of manufacture, the lot or batch of which The Product was a part, or any test or examination of The Product. (Standard Product Liability Interrogatory No. 43.)

44. If there was a change after the date of manufacture of The Product in the design of the component(s) at issue [or component substantially similar to the component(s) at issue]:

45. If there was a change after the date of manufacture of The Product in the manufacturing process of the component(s) at issue [or component substantially similar to the component(s) at issue]:

46. Identify all persons who (a) were directly responsible for the design, testing, certification, or safety of the component(s) at issue, (b) are most knowledgeable about the design, testing, certification, or safety of the component(s) at issue, (c) manufactured the component(s) at issue, or (d) assembled the component(s) at issue into The Product. As to each person, state the area of that person's responsibility or knowledge (e.g., design, testing, certification, or safety). (Standard Product Liability Interrogatory No. 46.)

61. Name each component at issue and:

62. With respect to each component at issue for which you contend there was a defect in design, state the particulars of each alternative design that you contend could and should have been employed and state the cost of the alternative design. (Standard Product Liability Interrogatory No. 62.)

63. With respect to each component at issue for which you contend there was a defect in manufacture, identify the applicable manufacturing specifications for the component at issue and state how you contend it failed to meet the prescribed manufacturing specifications. (Standard Product Liability Interrogatory No. 63.)

64. If you contend that this defendant failed to provide adequate product information for The Product, state how the product information was inadequate and how you contend the defendant could and should have made it adequate. (Standard Product Liability Interrogatory No. 64.)

65. State the facts that support your contention that The Product was defective and unreasonably dangerous, state how long the alleged defective or unreasonably dangerous condition existed before the occurrence, and identify each person and document having or containing information that supports your contentions. (Standard Product Liability Interrogatory No. 65.)

66. Identify each person who you contend is responsible for causing the alleged defective or unreasonably dangerous condition of The Product, and identify each person and document having or containing information that supports your contention. (Standard Product Liability Interrogatory No. 66.)

67. State the facts that support your contention that The Product reached you without substantial change in the condition in which it was manufactured, and identify each person and document having or containing information that supports your contention. (Standard Product Liability Interrogatory No. 67.)

68. State the facts that support your contention that the alleged defect in The Product was a proximate cause of the harm alleged in this action. (Standard Product Liability Interrogatory No. 68.)

69. If you contend that The Product was not properly installed before the occurrence, state the facts that support your contention and identify each person and document having or containing information that supports your contention. (Standard Product Liability Interrogatory No. 69.)

70. If you contend that this defendant before the occurrence had notice of any defect or unreasonably dangerous condition of The Product, state the facts that support your contention and identify each person and document having or containing information that supports your contention. (Standard Product Liability Interrogatory No. 70.)

71. Describe each complaint about The Product, if any, made at any time by you or any other person to this defendant, and identify each person and document having or containing information about the complaint. (Standard Product Liability Interrogatory No. 71.)

72. Describe the negligent acts or omissions for which you contend that this defendant is responsible with respect to The Product, state the facts that support your contention, state how each negligent act or omission could and should have been avoided, and identify each person and document having or containing information that supports your contention. (Standard Product Liability Interrogatory No. 72.)

73. If you contend that this defendant violated any statute, regulation, ordinance, standard, or guideline with respect to the manufacture or design of The Product or with respect its product information, for each statute, regulation, ordinance, standard, or guideline provide:

74. If you contend that the violation of any statute, regulation, ordinance, standard, or guideline set forth in your answer to the preceding Interrogatory proximately caused any harm alleged in this action, state the facts that support your contention. (Standard Product Liability Interrogatory No. 74.)

75. If you contend that this defendant had a duty to test but failed to test The Product, state the facts that support your contention and identify each person and document having or containing information that supports your contention. (Standard Product Liability Interrogatory No. 75.)

76. Identify the person who sold The Product to the person who owned The Product at the time of the occurrence, and state the sales price, the date of sale, and whether The Product was sold in a “new” or “used” condition. If The Product was sold in a “used” condition, identify each person who owned The Product at any time from the date of its manufacture to the present and state when the person owned it. (Standard Product Liability Interrogatory No. 76.)

77. Identify each person who has or had custody of The Product or any component at issue from the date of the occurrence to the present. For each person identified, state the time during which that person had custody and the exact location, including any street address, at which The Product or component at issue was kept. (Standard Product Liability Interrogatory No. 77.)

78. If you have knowledge of any maintenance or repair that was contemplated, recommended, or conducted, or should have been conducted, on The Product before the occurrence, state the knowledge you have concerning any such maintenance or repair and identify each person and document having or containing any information concerning the maintenance or repair. (Standard Product Liability Interrogatory No. 78.)

79. If you have knowledge of any photograph, video, motion picture, drawing, model, or other image made of The Product or any component at issue at any time, describe the medium on which the image is recorded, identify each person who participated in that process, state the date when the image was made, and identify the person who has present custody of the image. (Standard Product Liability Interrogatory No. 79.)