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CONFIDENTIAL

Jun. 8, 2002

Personal Injury (Non-Vehicular)
Product Liability
Defective Design

Confidential

Settlement –  $1,000,000

Judge

Elizabeth A. White

Court

L.A. Superior Long Beach


Attorneys

Plaintiff

Edward Steinbrecher


Defendant

Stephen E. Ronk
(Gordon & Rees LLP)


Experts

Plaintiff

Ann T. Vasile
(medical)

Thomas A. Curtis
(medical)

Paul F. Youngdahl
(technical)

James K. Watson
(medical)

Defendant

Mehrdad Haghi
(technical)

Facts

The defendant designed, manufactured and installed two conveyor systems at X Inc., the
plaintiffÆs employer. The conveyor systems utilized chains and sprockets. Employees worked on
both sides of the conveyor belt. The plaintiff, a 56-year-old female, was positioned to work near
the end of the conveyor used for moving boxes of fish products from the conveyor onto a table.
She was doing her job when her right forearm got caught in a 2 1/2-inch gap between the
conveyor frame and the sprocket guard. Her right arm then wrapped around the axle connected
to the sprocket. The plaintiff was trapped in the conveyor system for approximately one hour,
and suffered serious injuries which resulted in the amputation of her right arm below the elbow.

Settlement Discussions

The plaintiff demanded, and the defendant agreed, $1 million being the policy limits.

Specials in Evidence

$500,000 $12,000 Unknown Unknown

Injuries

Amputation of the right arm below the elbow. The plaintiff had sustained multiple fractures to her right arm, as well as a serious infection. Following several surgeries, the right arm could not be saved.

Other Information

<M>A mediation was held before Judge Enrique Romero.</M>


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