Free Statement - District Court of Arizona - Arizona

IN THE UNDITED STATES DISTRICT COURT
g RECEIVED WLT
FOR THE DISTRICT OF ARIZONA
APR 0 7 2005
sTEvE scHRUM, ) I ACTION Sm? Mttaw
) 9
Pramarri ) """"”
)
v. . ) Court No.: 04 CV 619
BURLINGTON NORTHERN )
SANTA FE RAILWAY COMPANY, )
)
Defendant. )
PLAINTIFF’S ANSWERS TO DEFENDANT’S INTERROGATORIES
NOW COMES the Plaintiff, STEVE SCHRUM, by and through his attorneys,
George T. Brugess and HOEY & FARINA, P.C., and for his Answers to Defendant, V
BURLINGTON NORTHERN SANTA FE RAILWAY COMPANY’S Interrogatories
states as follows:
l. Please state what precautions, if any, Plaintiff took to prevent Plaintift’ s
claimed injuries.
ANSWER: Reported conditions of air quality to supervisors, Mark Brown,
Jared Wooten, Steve Marino, Kevin McMynorlds, Larry Craiger,
Requested Nelson Lime Plant to Water down work areas tried
using paper respirators, reported condition to Terry Wittie contact
at lime plant shipping and receiving. Checked with local
communications Company on Price and Availability of respirators
with microphone hookups compatible with radios used by BNSF.
Requested written permission from supervisors to use respirators
for myself and crew that l would purchase at my own expense.
2. Provide the substance of all conversation, communications or statements
made by or between Plaintiff and any BNSF employee regarding air quality at the lime
plant or the need for respirators at Plaintiff s job site.
. Received
j§;;§¥ · Elliii
Case 2:04-cv—00619-RCB Document 79-3 Filed O2/16/2006 Page 1 of 3 A _,,
, _ Charles D. {final;

6. Describe in detail all injuries, complaints and symptoms, whether
physical, mental or emotional, which Plaintiff claims has been caused, aggravated or
otherwise contributed to by the conditions about which Plaintiff complains in his
Complaint.
AN SWER: Chronic Asthma, Chronic bronchitis, shoulder separation,
aggravation, wheezing, coughing, sleep deprivation, vertigo,
depression, severe mood swings, sexual dysfunction, constantly
scratching head causing sores, lack of energy, change in appetite,
feeling worthless and hopeless, suicide thoughts, lack of
concentration, obsessive compulsive disorder (must have new soap _
each bath; no one can touch or look at his food; must use clean
glass for each drink; does not like people near him because they
contaminate his air), yelling and fighting, nothing seems right, and
he will disappear for hours for no reason.
7. For all injuries mentioned in the preceding Interrogatory, please identify
those which you consider or have been told are, permanent.
AN SWER: All.
8. List each respiratory condition from which you have suffered during the
past twenty years. With respect to each condition, please state:
(a). The date on which you first began experiencing symptoms;
(b). The diagnosis made by your healthcare provider;
(c). The date on which the diagnosis was made;
(d). The name and address of the healthcare provider who made the
A diagnosis. p ‘
ANSWER: See medical records attached; investigation continues.
Case 2:04-cv—OO619-RCB Document 79-3 Filed O2/16/2006 Page 2 of 3

PROOF OF SERVICE
George T. Brugess, an attorney, certifies that he served a copy of the foregoing
Answers to lnterrogatories upon the attorney listed below by placing a copy thereof in the
United States Mail box located at 542 S. Dearborn, Chicago, Hlinois addressed as below,
with proper postage affixed at or before 5:00 on ‘·\- Qs ’ O °:' .
FENNEMORE CRAIG I
A Professional Corporation
William L. Thorpe
Sal J. Rivera .
Melissa W. Rawlinson
3003 North Central Avenue
Suite 2600
Pheonix, Arizona 85012-2913
Charles D. Onoiry
3101 N. Central Avenue, Suite 600 .
Phoenix, Arizona 85012
7 I I 7 Q

A
George T. Brugess
HOEY & FARINA, P.C. I
542 S. Dearborn V
Suite 200
Chicago, Illinois 60605
(312) 939-1212
Case 2:04-cv—OO619-RCB Document 79-3 Filed O2/16/2006 Page 3 of 3

Case 2:04-cv-00619-RCB

Document 79-3

Filed 02/16/2006

Page 1 of 3

Case 2:04-cv-00619-RCB

Document 79-3

Filed 02/16/2006

Page 2 of 3

Case 2:04-cv-00619-RCB

Document 79-3

Filed 02/16/2006

Page 3 of 3