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Personal Injury Attorneys Dyer, Garofalo, Mann & Schultz

Isotec Class Action Claim

Dear Property Owner:

As you are probably aware, the Montgomery County Court has certified our class action claim for damages resulting from the explosion at Aldrich Chemical Company, doing business as Isotec. Our firm, along with the law firms of Botros, Behnke, Kollin & Schulte and Jones & Washington are representing you in this class action pursuant to the Court's decision.

In the near future, we will be having settlement discussions with the lawyers for Isotec. To help establish the proper level of payment by Isotec, we need some basic information. We need information with regard to the following:

1. How many family members were evacuated?
2. Do you own or lease/rent your home?
3. Did you have any physical damage to your home, personal property or personal injury?

We would appreciate it if you would call the office of class counsel at 1-866-FAIR-PAY to answer the above questions, or you may also complete the form below.

If you prefer to provide us with this information by mail, please complete the enclosed questionnaire and mail it back to our office in the enclosed envelope, or fax it to us at 937-824-8630.

If you should have any questions, please feel free to call us to discuss the same.

Very truly yours,

John A. Smalley, Esq.
DYER, GAROFALO, MANN & SCHULTZ

Richard Schulte, Esq.
Steven Behnke, Esq.
BOTROS, BEHNKE, KOLLIN & SCHULTE

Taylor Jones, Esq.
Cheryl Washington, Esq.
JONES & WASHINGTON

Isotec Interrogatories

Your Name:
E-mail address:
Telephone number:

INTERROGATORY NO. 1: State your name and list your address on September 21, 2003.

a. State your current address if different from above.

INTERROGATORY NO. 2: State whether you are an owner of your home or whether your rent
or lease it. If you are not the sole owner, please list all owners as of September 21, 2003.



a. If you are an owner, state the value of the home and the date you
purchased the home.



INTERROGATORY NO. 3: State your exact location at the time of the September 21, 2003
incident.



II Evacuation Expenses

INTERROGATORY NO. 4: State the location where you stayed on the night of September 21,
2003.



INTERROGATORY NO. 5:
Please identify the type and amount of every out-of-pocket
Evacuation Expenses (not Loss of Use) that you allege to have incurred as a result of the
September 21, 2003 Incident. Please attach any receipts, documentation, or copies of any other
evidence that show the amount of Evacuation Expenses you allege to have incurred.



a. If you identified any Evacuation Expenses in response to Interrogatory Nos. 5(a)
through 5(f), state whether you were reimbursed for any of your Evacuation
Expenses, and if so, identify who reimbursed you in what amount. Attach an
documentation regarding the Evacuation Expenses for which you were reimbursed
and the amount of reimbursement, including copies of any checks paid to you.



INTERROGATORY NO. 6: Identify with a "yes" or "no" answer whether the September 21,
2003 Incident caused you to be absent from your employment.



a. If you answered "yes" to Interrogatory No. 6, then state with a "yes" or "no"
answer whether you lost any wages as a result of your absence from employment.



b. If you answered "yes" to Interrogatory No. 6(a), then identify your place of
employment, the exact amount of wages lost, and the name of any persons at your
place of employment who can testify to your absence. Attach any documentation
from your employer regarding your absence and the amount of wages lost.



III. Loss of Use

INTERROGATORY NO. 7: David B. Fulmer, Chief of the Miami Township Fire Department,
has stated under oath that the evacuation lasted for "a little more than 24 hours (from
approximately mid-morning on Sunday, September 21, 2003, through approximately late
morning on Monday, September 22, 2003)." Identify any period of time for which you allegedly
lost the use of your property as a result of the September 21, 2003 incident.



INTERROGATORY NO. 8: State with a "yes" or "no" answer whether you have a mortgage for
the property listed in response to Interrogatory No. 1.



a. If you answered "yes" to Interrogatory No. 8, state the amount of your monthly
mortgage payment for the payment period that included September 21, 2003.



INTERROGATORY NO. 9: Identify the monthly utility costs for the billing period that included
September 21, 2003, for the following utilities: electricity, natural gas, water, sewage, local
telephone flat-rate (i.e. the fixed monthly charges, not the per-call charges for calls made),
internet service provider (i.e. the fixed monthly services charges, and not any per-call charges to
connect to the internet), and cable or satellite television.



IV. Other Losses

INTERROGATORY NO. 10: Identify with specificity any other losses you incurred as a result
of the September 21, 2003 Incident.



When you have completed the above, please hit 'Submit' once only. The next page may take a little while to load, and you patience is appreciated.

 

  • Submission of this form and the information contained in it is not privileged nor is it intended to create an attorney-client relationship between the sender and Dyer Garofalo Mann & Schultz.
  • Your information will be reviewed during normal business hours, M-F 8:00am - 5:30pm.
  • Alternatively, call1-800-223-8897 for your free consultation! Lines open 24 hours.
  • Let our team of personal injury attorneys fight for your rights. Call the Tiger on 1-800-223-8897 today!
    Dyer, Garofalo, Mann & Schultz, L.P.A are Personal Injury Attorneys in Ohio with offices in
    Dayton (Main Location), Bellefontaine, Huber Heights, Lima, Middletown, Piqua, Springfield, Troy, Xenia, Wilmington, and Richmond, IN.