Bells Account Bonner Law INTAKE FORM My Account Registration Rpd Response – 11-22-Nikcole & Catherine RPD Rpd Response – 12-3-Millard RPD RPD RESPONSE-MG set FACTSHEET#Name First Last REQUEST FOR PRODUCTION NO. 1: All DOCUMENTS RELATING TO TETRA TECH RELATED ENTITIES.RESPONSE NO. 1:REQUEST FOR PRODUCTION NO. 2: All DOCUMENTS RELATING TO all SYMPTOMS and/or DIAGNOSES YOU identified in YOUR ORIGINAL RESPONSE to PFS1 Questions 8(a) and 9(a).RESPONSE NO. 2:REQUEST FOR PRODUCTION NO. 3: ALL DOCUMENTS RELATING TO any COMMUNICATION between YOU and TETRA TECH RELATED ENTITIES.RESPONSE NO. 3:REQUEST FOR PRODUCTION NO. 4: All DOCUMENTS RELATING TO any COMMUNICATION between YOU and any federal, state, or local government agency RELATED TO BAYVIEW, including but not limited to the NAVY, CCSF, or CDPH.RESPONSE NO. 4:REQUEST FOR PRODUCTION NO. 5: All DOCUMENTS RELATING TO YOUR allegation that YOUR “fear . . . began back in 2004” RELATED TO TETRA TECH RELATED ENTITIES’ “digging and construction” as referred to in Paragraph 155 of YOUR COMPLAINT.RESPONSE NO. 5:REQUEST FOR PRODUCTION NO. 6: All DOCUMENTS RELATING TO any COMMUNICATION between YOU and any DEVELOPER ENTITY.RESPONSE NO. 6:REQUEST FOR PRODUCTION NO. 7: All DOCUMENTS RELATING TO any COMMUNICATION between YOU on the one hand, and Dr. Ahimsa Porter Sumchai, Dr. James Dahlgren, Dr. Raymond Tompkins, Dr. Mark Alexander, and/or Christopher Busby on the other hand.RESPONSE NO. 7:REQUEST FOR PRODUCTION NO. 8: All DOCUMENTS that form the basis of YOUR claim for damages for WRONGFUL DEATH caused by TETRA TECH RELATED ENTITIES.RESPONSE NO. 8:REQUEST FOR PRODUCTION NO. 9: If YOUR ORIGINAL RESPONSE to PFS1 Question 7(a) is Yes, all DOCUMENTS that form the basis of YOUR claim for damages for PHYSICAL INJURIES caused by TETRA TECH RELATED ENTITIES.RESPONSE NO. 9:REQUEST FOR PRODUCTION NO. 10: If YOUR ORIGINAL RESPONSE to PFS1 Question 10(a)(i) is Yes, all DOCUMENTS that form the basis of YOUR claim for damages for EMOTIONAL DISTRESS caused by TETRA TECH RELATED ENTITIES.RESPONSE NO. 10:REQUEST FOR PRODUCTION NO. 11: All COMMUNICATIONS concerning YOUR PFS1.RESPONSE NO. 11:REQUEST FOR PRODUCTION NO. 12: All COMMUNICATIONS with any experts retained in this ACTION.RESPONSE NO. 12:REQUEST FOR PRODUCTION NO. 13: All COMMUNICATIONS concerning this ACTION.RESPONSE NO. 13:REQUEST FOR PRODUCTION NO. 14: If YOUR ORIGINAL RESPONSE to PFS1 Question 11(a) is Yes, all DOCUMENTS and/or COMMUNICATIONS RELATED TO medical monitoring YOU have received or that YOU have been advised to obtain RELATED TO YOUR possible exposure to toxic substances at or from HUNTERS POINT.RESPONSE NO. 14:REQUEST FOR PRODUCTION NO. 15: If YOUR ORIGINAL RESPONSE to PFS1 Question 12(a) is Yes, all DOCUMENTS and/or COMMUNICATIONS RELATED TO YOUR claim that YOU have a genetic predisposition for cancer or other chronic illness.RESPONSE NO. 15:REQUEST FOR PRODUCTION NO. 16: If YOUR ORIGINAL RESPONSE to PFS1 Questions 12(b) and/or 12(c) is Yes, all DOCUMENTS RELATED TO the results of any biomonitoring, environmental monitoring, or other testing conducted on YOU and/or YOUR PROPERTY for the presence of toxins or other substances.RESPONSE NO. 16:REQUEST FOR PRODUCTION NO. 17: If YOUR ORIGINAL RESPONSE to PFS1 Question 13 is Yes, all DOCUMENTS that form the basis of YOUR claim for REAL PROPERTY DAMAGES caused by TETRA TECH RELATED ENTITIES.RESPONSE NO. 17:Date MM slash DD slash YYYY LAW OFFICES OF BONNER & BONNER/s/ A. Cabral BonnerA. CABRAL BONNERAttorney for PlaintiffsEmail
