1. 1
STATE OF INDIANA ) IN THE MARION SUPERIOR COURT
)SS:
COUNTY OF MARION ) CAUSE NO. 49D12-1302-CT-000052
CARL CLIENT )
Plaintiffs )
)
VS )
)
INDIANA SKYDIVING )
CENTER, LLC d/b/a )
SKYDIVE INDIANAPOLIS )
Defendants )
CARL CLIENT’S REQUEST FOR
PRODUCTION OF DOCUMENTS AND
THINGS TO DEFENDANTS
Pursuant to Ind. Trial Rule 34, the Plaintiff, Carl Client (Client) requests that the
Defendant respond to the following requests for production of documents in writing within thirty
(30) days and that you produce and permit the Petitioner and its representatives to inspect and
copy all of the following described documents and tangible things which are in the possession,
custody or control of you, your attorneys and/or other representatives, and that the documents
and tangible things be organized and labeled to correspond with the categories in this request.
Production is to occur at the law offices of Dewey, Cheatum & Howe, LLC, 123 Gotcha Blvd.,
Indianapolis, IN 46250.
I.
GENERAL INSTRUCTIONS
The following instructions apply to each of the interrogatories propounded herein:

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A. Unless otherwise indicated, these requests for production of documents relate to the
time, place, circumstances and matters reflected in the Petitions to Review.
B. If an objection is interposed to any request consisting of multiple parts, the objection
should specify to which part or parts of the request the objection is directed.
C. Unless otherwise specified, documents produced or identified in compliance with a
request should include all documents relating to the time period specified for the request
regardless of whether prepared before, during or after the period.
D. In the event any document requested to be identified is unavailable, explain the reason
in detail.
E. In producing documents called for by a request, designate for each document the
request or requests to which the document responds.
F. If you object to or otherwise decline to comply with any portion of a request, provide
all information or documents requested by that portion of the request to which you do not object
or with which you do not otherwise decline to comply. If you object to a request on the ground
that it is too broad, provide all information and documents or portions of documents that you
concede are relevant or reasonably calculated to lead to the discovery of admissible evidence. If
you object to a request on the ground that to provide the requested discovery would constitute an
undue burden, provide all requested discovery that can be supplied without undertaking what you
claim to be an undue burden.

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G. You are to supplement your answers to the following requests in accordance with
Trial Rule 26(e) of the Indiana Rules of Procedure.
II. DOCUMENT REQUESTS
1. Any and all documents, records, memoranda, field notes, photographs, videotapes,
recordings, including any and all drafts, regarding the usual course of inspection of parachute
deployment devices by any employee or certified staff who were present during the time in
which Carl Client sustained his injury.
RESPONSE:
2. Any and all correspondence between Robert “Bob” Dougherty and trained personnel,
employees, manufacturer of parachute and parachute deployment devices, and any form letters
and contracts used in the course of business.
RESPONSE:

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3. All other reports, test results, photographs, videotapes, drawings or any other recorded
matter made by or on behalf of the defendant or any employee, officer, contractor or
subcontractor thereof, with regard to Indiana Skydiving Center, its condition or any attribute
thereof either before or after construction of Indiana Skydiving Center.
RESPONSE:

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STATE OF INDIANA ) IN THE MARION SUPERIOR COURT
)SS:
COUNTY OF MARION ) CAUSE NO. 49D12-1302-CT-000052
CARL CLIENT )
Plaintiffs )
)
VS )
)
INDIANA SKYDIVING )
CENTER, LLC d/b/a )
SKYDIVE INDIANAPOLIS )
Defendants )
CARL CLIENT’S REQUEST FOR
INTERROGATORIES TO DEFENDANT
Pursuant to Ind. Trial Rule 33, the Plaintiff, Carl Client (Client) requests that the
Defendant respond to the following interrogatories in writing and under oath within thirty (30)
days.
I. GENERAL ISTRUCTIONS
The following instructions apply to each Interrogatory propounded herein:
A. Unless otherwise indicated, these Interrogatories relate to the time, place,
circumstances and matters reflected in the pleadings.
B. If an objection is interposed to any Interrogatory consisting of multiple parts, the
objection should specify to which part or parts of the Request or Interrogatory the objection is
directed.
C. If you object to any Interrogatory or any subpart thereof on the grounds that it calls for
disclosure of information which you claim is privileged, then answer such Interrogatory or

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subpart as follows: (1) furnish all information and facts called for by such Interrogatory or
subpart which you do not claim is privileged, and (b) for each communication, recommendation,
fact or advice which you claim is privileged, state the basis for your claim of privilege.
D. If you object to or otherwise decline to comply with any portion of an Interrogatory,
provide all information or documents requested by that portion of the Request or Interrogatory to
which you do not object or with which you do not otherwise decline to comply. If you object to
an Interrogatory on the ground that the time period requested is too broad, provide all documents
from the previous five (5) years.
E. You are to supplement your answers to the following Interrogatories in accordance
with Rule 26(E) of the Indiana Rules of Trial Procedure.
II. INTERROGATORIES
1. Identify by name, position, and address, all persons employed by or retained by or on
behalf of Indiana Skydive Center, either directly or as an agent or representative or independent
contractor, who either worked or else had a sanctioned role in the preparation or safety training
of Carl Client on February 1, 2013 (HEREAFTER, “That day”). For each person so identified,
state the type of work and service performed with Indiana Skydive Center.
ANSWER:
2. Identify by name and position, all persons employed by or on behalf of Indiana
Skydive Center, either directly or as an agent or representative or independent contractor, who

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investigated, inspected or examined Carl Client’s parachute in response to this claim or report of
actual or potential design or deployment defects. For each person so identified, state the date of
employment or representational start date and end date, if applicable and their position or
positions that day.
ANSWER:
3. Identify by name and address, all persons or entities who installed the parachute used
by Carl Client on that day. For each person so identified state the duration of time which they
were retained for the purposes of furnishing parachutes, and the reason for choosing that or those
particular company or companies over others.
ANSWER:

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STATE OF INDIANA ) IN THE MARION SUPERIOR COURT
)SS:
COUNTY OF MARION ) CAUSE NO. 49D12-1302-CT-000052
CARL CLIENT )
Plaintiffs )
)
VS )
)
INDIANA SKYDIVING )
CENTER, LLC d/b/a )
SKYDIVE INDIANAPOLIS )
Defendants )
CARL CLIENT’S REQUEST FOR
ADMISSION TO ROBERT DOUGHERTY
Pursuant to Trial Rule 36, Plaintiff, by counsel, respectfully submit the following Request
for Admission to be answered by Robert Dougherty on behalf of himself and all others similarly
situated in writing, under oath, without evasion, within thirty (30) days after the receipt thereof.
REQUEST TO ADMIT NO. 1: Admit that aircrafts occasionally deploy without having
as a passenger a direct employee of Indiana Skydive Center,
RESPONSE:
REQUEST TO ADMIT NO. 2: Admit that Indiana Skydive Center is registered as more
than one entity with the Indiana Secretary of State.
RESPONSE:
REQUEST TO ADMIT NO. 3: Admit that there is no expectation that the trainer
whom shows jumpers the instruction video may not be the one who accompanies clients on jums.
RESPONSE: