Holdings,
Inc., Takata Seat Belts, Inc., Takata Restraint Systems, Inc., and Takata U.S.A.
Corporation ("Takata Defendants"), the Third Amended Complaint alleges, among other
things, as follows:
12. The safety belts ... Yukon were designed. manufactured. and assembled by the Takata Defendants. GMC
provided specifications to the Takata Defendants. rsiThe Takata Defendants designed and manufactured the safety
belts and buckles. GMC installed ... safety belts and buckles into the Yukon. Both GMC and the Takata Defendants
tested the buckles and safety belts components. GMC caused the Yukon to be marketed. advertised, and represented
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Plaintiffs served written discovery on the Takata Defendants. The Takata Defendants
subsequently provided written responses and documents. On February 16, 2009, plaintiffs
filed ... their Amended Motion to Compel Discovery as to the Takata Defendants. (D.E. r8]
167). On March 3, 2009, the Takata Defendants filed their response in opposition to the
motion ... hearing was held on March 9, 2009, attended by counsel for plaintiffs and the
Takata defendants. With leave of court, on March 16 and 17, 2009, supplemental briefs
were filed
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Plaintiffs served written discovery on the Takata Defendants. The Takata Defendants
subsequently provided written responses and documents. On February 16, 2009, plaintiffs
filed ... their Amended Motion to Compel Discovery as to the Takata Defendants. (D.E. r8]
167). On March 3, 2009, the Takata Defendants filed their response in opposition to the
motion ... hearing was held on March 9, 2009, attended by counsel for plaintiffs and the
Takata defendants. With leave of court, on March 16 and 17, 2009, supplemental briefs
were filed
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01378427.pdf
Request for Production No. 11: The Court finds this inquiry to
be relevant. The Takata Defendants have agreed to determine what, if any, customer
complaint information related to the seat ... documents responsive to this request shall be produced, only to the
extent the Takata Defendants contend that there are differences in safety performance
between the restraint system used by Takata ... Defendants in the 2005 GMC Yukon and
other restraint systems used by Takata Defendants, with the same retractor employed in
the 2005 Yukon, in other SUV-type vehicles. This information
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01379753.pdf
Request for Production No. 11: The Court finds this inquiry to
be relevant. The Takata Defendants have agreed to determine what, if any, customer
complaint information related to the seat ... documents responsive to this request shall be produced, only to the
extent the Takata Defendants contend that there are differences in safety performance
between the restraint system used by Takata ... Defendants in the 2005 GMC Yukon and
other restraint systems used by Takata Defendants, with the same retractor employed in
the 2005 Yukon, in other SUV-type vehicles. This information
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stating that the
response is complete.
Interrogatory No. 9 and Request No. 4: The Takata Defendants already responded in a
verified response that they are not aware of any agreement ... issue in this litigation. See Takata Defs.' Resp. at Interrog. No. 9. The Takata Defendants
are to determine if any general agreements exist which would encompass the design or
testing ... exist, but contain information unrelated to the
seat belt restraint system at issue, the Takata Defendants may approach the court, after
consulting ['13] with plaintiffs, about redacting such non-responsive
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stating that the
response is complete.
Interrogatory No. 9 and Request No. 4: The Takata Defendants already responded in a
verified response that they are not aware of any agreement ... issue in this litigation. See Takata Defs.' Resp. at Interrog. No. 9. The Takata Defendants
are to determine if any general agreements exist which would encompass the design or
testing ... exist, but contain information unrelated to the
seat belt restraint system at issue, the Takata Defendants may approach the court, after
consulting ['13] with plaintiffs, about redacting such non-responsive
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01378428.pdf