This is my discovery request. I am trying to find the evidence I need to prove my case and to prove a pattern of practice. As a pro se litigant, I appreciate any advice. If you're an expert who can help me request the right things in discovery, please reach out: supertech007@gmail.com

My Request For Discovery 

SUPPLEMENTAL DISCOVERY – SAFETY POLICIES & INJURY MISCLASSIFICATION

1. Identify all safety training materials, including videos, presentations, and written policies, in effect at the Edgerton, Kansas facility during the relevant time period that address standing on concrete floors, use or provision of anti-fatigue mats, and prevention of foot or lower-extremity injuries.

2. Identify all individuals responsible for approving, implementing, and enforcing the safety policies and training materials addressing standing on concrete floors and anti-fatigue mats, including job titles and dates of responsibility.

3. Produce all safety training videos, presentations, manuals, and written policies used at the Edgerton facility that address employee safety while standing on concrete floors or the provision of anti-fatigue mats.

4. Produce documents sufficient to show when the safety materials were last updated and whether management acknowledged responsibility for providing the safety equipment referenced in those materials.

5. Identify all individuals involved in the preparation, review, approval, or submission of Plaintiff’s injury report(s), including any OSHA-related documentation.

6. State the basis for classifying Plaintiff’s injury as “not work related,” including the identity of all persons who made, reviewed, or approved that determination.

7. Produce Plaintiff’s complete injury file, including drafts, internal notes, communications, and OSHA-related documentation, whether or not previously provided to Plaintiff.

8. Produce all communications referencing Plaintiff’s injury, its classification, or its relationship to workplace conditions, including communications between management, HR, safety personnel, and outside entities.

9. Identify the individual(s) with final authority to approve injury classifications and OSHA determinations at the Edgerton facility during the relevant time period.

10. Produce documents sufficient to show who signed off on Plaintiff’s injury classification and whether that sign-off complied with Defendant’s own safety policies and training materials.