Grenfell Tower Inquiry... · De Vere Holborn Bars, 138-142 Holborn, London EClN 2NQ 0800 1214282 General enquiries: [email protected] Legal enquiries: [email protected]

Grenfell Tower Inquiry

Cooley (UK) LLP Dashwood 69 Old Broad Street London EC2M 1QS

BY EMAIL ONLY

Your ref: ~cooley.com

Dear Sirs,

WHIRLPOOL CORPORATION REQUEST FOR DOCUMENTS No. 2

Request for Documents

Generally

8 June 2018

This is a second Request for Documents in the control of Whirlpool that are relevant to the issues covered by the Inquiry's Terms of Reference.

You are requested to produce such documents to the Inquiry by 4 p.m. on 22 June 2018 ("the Request").

For the purposes of the Request, a document is in control of Whirlpool if it is in its physical possession, or if it has a right to possession of it, or it has a right to inspect or take copies of it, or customarily has access to it.

De Vere Holborn Bars, 138-142 Holborn, London EClN 2NQ 0800 1214282

General enquiries: [email protected] Legal enquiries: [email protected]

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The Inquiry requests that the documents be provided electronically. The Inquiry is using an online document management review system in order to be able to quickly and efficiently review your documentation. Please can you provide your documents electronically in either their native format, for example Microsoft Word, Microsoft Excel, MSG email files / PST email containers, or please convert any proprietary file formats to Adobe PDF. The Inquiry has a cloud-based system for the uploading of large volumes of documents. If you wish to use such a system, please contact us for further information.

The documents should also be accompanied by an inventory listing them and signed by or under the authority of the person providing them and a statement which explains the steps which have been taken to ensure that (1) all relevant documents have been provided and (2) irrelevant documents have not been provided.

The Inquiry, being a public inquiry, seeks to be as transparent as possible. This means that it expects to disclose material to core participants and may (regardless of disclosure to any person) seek to use such material as part of its body of documentary evidence to which reference may be made by its experts or in its reports and as such may form part of the Inquiry record. Moreover, to ensure that the Inquiry has maximum access to relevant material, it is anticipated that all material in the hands of the Inquiry will be available for the Police to view, should they wish (and vice versa).

The Inquiry will work on the assumption that any material in its possession may be disclosed or used in the manner set out above. Should you seek to object to disclosure or use by the Inquiry, then you should identify your objection in full by reference to specific documents or categories of documents, and support it by legal submission explaining why this course should not be followed in the specific circumstances, in any covering letter accompanying the material.

Basis of the Request

The Request is not made in exercise of statutory powers to compel the production of evidence or documents. The Chairman expects all parties to whom a request of this kind is addressed will co-operate with the Inquiry and provide all relevant material voluntarily without the need for him to exercise those powers. However, the Chairman will consider exercising those powers if the response to this or any later Request is, for example, refused, or incomplete, or not provided by the set deadline.



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Specific Request for Documents and information

1. For Hotpoint Models FF175BP and FF175BG, please provide:

1.1 Installation, Operation, and Maintenance Manual that was in effect on 1 October 2008.

• Operating instructions for FF175B: This has already been provided. Please confirm that these were the relevant instructions as at 1 October 2008;

• Operating instructions for FF175FFP: This has already been provided. Please confirm that these were the relevant instructions as at 1 October 2008;

• Please provide an installation manual for FF175BP and FF175BG as at 1 October 2008;

• Please provide a maintenance manual for FF175BP and FF175BG as at 1 October 2008;

• Please provide Service information as at 1 October 2008;

1.2 Wiring Diagram that was in effect on 1 October 2008.

1.3 Number of Hotpoint Model FF175BP and FF175BG fridge/freezers that were sold worldwide during each ofthe following years: (a) 2005 through 2007 (b) 2008; and (c) 2009 through 2011.

1.4 Whether there have been any recalls (voluntary or otherwise) of the Hotpoint Model FF175BP or FF175BG fridge-freezer manufactured duringthe seven-year period referenced in 1.5 above (2005 through 2011).

1.5 Report(s) describing the nature of the recall(s) and remedy(s) for each recall referenced in 1.4 above.

1.6 Whether there have been any legal suits/claims brought against Whirlpool, Indesit, or its representatives involving a Hotpoint Model FF175BP or FF175BG fridge-freezer manufactured during the seven-year period referenced in 1.3 above (2005 through 2011).

1.11 Description (Case number, jurisdiction, date) of each legal suit/claim referenced in 1.6 above.



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2. For the Run Capacitor in Hotpoint Models FF175BP and FF175BG, please provide: 2.1 The "Change-Order" Document that shows the change from a Class PO Run Capacitor to a Class P2 Run Capacitor and the date that the change to Class P2 occurred. 2.2 The earliest date that Hotpoint Model FF175BP and FF175BG fridge/freezers were manufactured with Class P2 Run Capacitors.

Yours faithfully,

Caroline Featherstone Solicitor to the Inquiry



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