Sample 30(B)(6) Deposition - List of Documents to be Produced by Defendant

Below are sample request for production of documents sought by the 30(b)(6) deponent.  It is amazing how asking for the same documents the second time sometimes produces different results.  

LIST OF DOCUMENTS TO BE PRODUCED BY DEFENDANT JONES SUPPLY COMPANY, LP CORPORATE REPRESENTATIVE

  1. Please produce a copy of each publication, manual, piece of literature, guideline, or other written material provided by Defendant Jones Supply to Defendant Rolfes (or any of its' drivers) at any time prior to the date of the subject collision.
  2. Please produce each and every document provided by Jones Supply to Rolfes, including, but not limited to, each and every document referring to hauling, delivery, safety, truck specifications, insurance, maintenance, driver evaluations, driver conduct, driver dress, advertising, the Jones Supply logo, compensation, bonuses, and discounts.
  3. Please produce all documents reflecting the policies or procedures of Rolfes regarding safety, motor vehicle safety, travel policy, sleep and rest requirements, vehicle inspection, driver standards and hiring requirements that were in effect at the time of the incident, including, but not limited to driver safety manuals, driver safety operating procedures, driver safety training manuals/procedures/guidelines.
  4. Please produce all documents reflecting the policies or procedures provided by Jones Supply to Rolfes regarding safety, motor vehicle safety, travel policy, sleep and rest requirements, vehicle inspection, driver standards and hiring requirements that were in effect at the time of the incident, including, but not limited to driver safety manuals, driver safety operating procedures, driver safety training manuals/procedures/guidelines.
  5. Please produce any employee handbook for Defendant Rolfes that was in effect at the time of the incident.
  6. Please produce a copy of the driver manual, company handbook, or their equivalent issued to Defendant Rolfes and Dughly by Jones Supply.
  7. Please produce a copy of the company safety rules or its equivalent issued to Defendant Rolfes and Dughly by Jones Supply that were in effect on August 27, 2013, and for 1 year prior.
  8. Please produce a copy of the company safety rules or its equivalent for Defendant Rolfes that were in effect on August 27, 2013, and for 1 year prior.
  9. Please produce all documents, books, reports, manuals, policies and memoranda setting forth Jones Supply's safety rules and regulations with respect to the loading, securing the load, or operation of tractors or trailers on behalf of Jones Supply. This includes any documents provided to so-called "independent contractors."
  10. Please produce all documents, books, reports, manuals, policies, and memoranda setting forth Rolfes's safety rules and regulations with respect to the loading, securing the load, or operation of tractors or trailer.
  11. Please produce all memoranda, policies, procedures or correspondence given or sent to Defendant Rolfes about the falsification of records during their engagements with Jones Supply.
  12. Please produce all policies or procedures of Defendant Jones Supply relating to accident or injury investigation or reporting that were in effect on the date of the incident, and include blank copies of any documents that are required to be completed after an accident or injury.
  13. Please produce the accident register maintained as required in 49 CFR 390.15(b) to include the motor vehicle incident with Plaintiff and all accidents three (3) years prior to the date of the incident.
  14. All documents constituting, commemorating to relating to any hours of service violations by any driver employed by Defendant Rolfes from three (3) years prior to the incident to present.
  15. All documents constituting, commemorating, or relating to any incidences of overweight citations or warnings issued for any tractor and/or trailer owned, leased or otherwise in the service of Defendant Rolfes.
  16. A copy of each out of service report or violation concerning the tractor and trailer involved in this incident for the 5 years prior to this incident to the present, to include copies of any supplements, responses, or amendments to the same.
  17. Please produce all pertinent documents in Defendant Jones Supply's possession reflecting Defendant Rolfes's compliance with 49 C.F.R. § 385, entitled "Safety Fitness Procedures," including without limitation:
    1. All documentation defining Rolfes's "safety rating";
    2. All documentation Rolfes received in the course of any onsite examination of motor carrier operations, including Defendant Rolfes's operations. This is to include all documentation relative to a compliance review and/or safety review;
    3. In the absence of a safety rating, please produce a copy of the Motor Carrier Identification Report, form MCS-150, filed in accordance with 49 C.F.R. § 385.21 with the FHWA Office of Motor Carrier Information management and Analysis, Washington, D.C.
  18. All documents reflecting the repair history for the truck and trailer involved in the occurrence.
  19. Any and all DOT audits of your operation, and exit reports to you, in the five years before the collision and any since the collision.
  20. A copy of all National Transportation Safety Board investigate reports for five (5) years prior to the collision and one (1) year after the collision.
  21. Any and all documents setting forth any policies, procedures, guidelines, recommendations or directives regarding driver conduct, driver safety, driver hiring, subcontractor hiring, commercial carrier hiring, discipline or firing prepared or used by Defendant Rolfes during the five (5) year period prior to the subject incident and through the present date, together with all amendments, revisions or supplements thereto.
  22. All training or instructional videotapes, CDs or DVDs used by any defendant in its training any of its drivers at any time during the five years before the occurrence.
  23. All pay stubs, federal W-2 forms, expense reimbursement, commissions, bonuses and any other documents or tangible evidence reflecting payment of money or benefits for any reason from you to Defendant Dughly for the 5 year period preceding the collision in question.
  24. All Safety Ratings issued to Defendant Rolfes by any federal government agency for the five years preceding the incident.
  25. A copy of all leases, understandings, memoranda and other documents relating to the use and/or possession of the tractor-trailer in question. This would include any subcontractor agreements, commercial carrier agreements, broker agreements, and any agreements for Jones Supply to affix its logo to a Rolfes truck, including, but not limited to, the truck involved in the incident.
  26. All documents constituting, commemorating, or relating to any written instructions, orders, or advice given to Defendant Rolfes and/or Dughly in reference to cargo transported, routes to travel, locations to purchase fuel, cargo pickup or delivery times issued by Jones Supply, shippers, receivers, or any other persons or organization from five (5) years prior to and including date of loss.
  27. Copies of the organizational charts and lists identifying the divisions and management structure for your company, its subsidiaries, parents, or affiliates of the year of the collision and four years prior.
  28. Produce any and all documents that indicate your company is a common carrier, a contract carrier, or a private carrier.
  29. Copies of any and all DOT and State agency reviews of your company for the period commencing 10 years prior to this collision, to the present time.
  30. All correspondence writings and/or documents sent by your company to Defendant Jones Supply regarding disciplinary action or suspension or termination of contracts. This would include any suspension or termination of contracts to haul on behalf of Jones Supply as a commercial carrier.
  31. Please produce the entire qualification file of Defendant Rolfes and Dughly (regardless of subject, form, purpose, originator, receiver, title or description) maintained pursuant to 49 CFR 391.51 and preserved pursuant to 49 CFR 379.
  32. Please produce any job, driver, independent contractor, and/or employment application filled out or signed by Defendant Dughly.
  33. Please produce the entire driver investigation history file or its equivalent for Defendant Dughly maintained pursuant to 49 CFR 391.53 and preserved pursuant to 49 CFR 379 (including Appendix A, Note A).
  34. Please produce any and all documents reflecting any background check performed on Defendant Dughly with regard to their employment history or job references, including letters of reference.
  35. Please produce any and all documents reflecting any background check performed on Defendant Dughly with regard to his driver's record (including but not limited to traffic tickets, incidents, and prior employment as a driver).
  36. Please produce all documents received, obtained or filed by Defendant Rolfes when qualifying Defendant Dughly as a truck driver in accordance with the Federal Motor Carrier Safety Regulations.
  37. Please produce any and all documents reflecting any background check performed on Defendant Dughly with regard to his criminal history.
  38. Please produce copies of all road or test cards, medical cards, DOT physical examination log forms, motor carrier certification of driver qualification cards and any other motor carrier transportation-related cards in the possession of the Defendant Rolfes regardless of card issuance date or origin.
  39. Please produce all road and written test certificates issued by Defendant Rolfes or any other motor carrier or organization to Defendant Dughly regardless of the date issued or the originator of such certificates.
  40. Please produce all actual driver's motor carrier written tests administered to Defendant Dughly, including all answers.
  41. Please produce the entire drug and alcohol file of Defendant Dughly including but not limited to pre-employment, post-accident, random, reasonable suspicion, and return to duty drug and alcohol testing results maintained pursuant to 49 CFR 382.401, preserved pursuant to 49 CFR 379 (including Appendix A, Note A), and released pursuant to 49 CFR 40.323.
  42. Please produce a copy of the job description of the position that Defendant Dughly was initially hired, employed or retained to perform for Defendant Rolfes.
  43. Please produce a copy of the job description of the position or job that Defendant Dughly was performing at the time of the incident if such exists.
  44. Please produce a copy of the job description of the position or job that Defendant Rolfes was performing as a commercial carrier for Defendant Jones Supply at the time of the incident if such exists.
  45. Please produce a copy of any driver's license issued to Defendant Dughly. If this is in the driver qualification file/personnel file, you may indicate so in your response.
  46. Please produce the entire personnel file of Defendant Dughly.
  47. Please produce any and all evaluations or criticism of the job performance of Defendant Dughly by Rolfes, including but not limited to annual evaluations, interim evaluations, or specific incidents that gave rise to an evaluation or criticism.
  48. Please produce any and all evaluations or criticism of the job performance of Defendant Dughly by Jones Supply, including but not limited to annual evaluations, interim evaluations, or specific incidents that gave rise to an evaluation or criticism.
  49. Please produce any and all letters, writings, memoranda, or any other documents which reflect or contain the resignation or termination of the employment or contractual relationship of Defendant Rolfes with Defendant Jones Supply.
  50. Please produce copies of each annual review of Defendant Dughly's driving record, as required by 49 CFR 391.25, for the past five years leading up to and including the year of this crash.
  51. Please produce copies of each annual review of Defendant Dughly's driving record, as required by 49 CFR 391.25, for the past five years leading up to and including the year of this crash.
  52. Please produce a record of Defendant Dughly's violations, as required by the Federal Motor Carrier Safety Regulations for the past ten years.
  53. Please produce copies of any documentation evidencing the completion or non-completion of training programs, safe driving programs, and driver orientation programs by Defendant Rolfes for Defendant Jones Supply.
  54. Please produce copies of any documentation evidencing the completion or non-completion of training programs, safe driving programs, and driver orientation programs by Defendant Dughly for Defendant Rolfes.
  55. Please produce any and all state safety audits and/or state roadside inspections for Defendant Rolfes for the year of this incident and five years prior.
  56. Please produce any and all long-form DOT physicals for Defendant Dughly for the time he was a driver for Defendant Rolfes.
  57. Please produce all documents relating to any disqualification of Defendant Dughly made pursuant to any Federal Motor Carrier Safety Regulation.
  58. Please produce all documents relating to any out of service records for the vehicle involved in this incident extending from the date of the incident and 5 years prior.
  59. Please produce any and all federal accident reports filed for Defendant Rolfes for the year of this incident and five years prior.
  60. Please produce any and all DOT inspection reports filed for Defendant Rolfes for the year of this incident and five years prior.
  61. A copy of every federal, state, county, municipal, insurer and/or internal motor carrier collision report or other collision reports concerning all collisions in which Defendant Dughly has been involved, including the collision at issue in this cause and all collisions prior to the collision at issue in this cause, pursuant to Federal Motor Carrier Safety Regulation §390.15(b)(1) and §390.1 5(b)(2).
  62. A copy of every federal, state, county, municipal, insurer and/or internal motor carrier collision report or other collision reports concerning all collisions in which Defendant Rolfes (or one of Rolfes's drivers) has been involved, including the collision at issue in this cause and all collisions prior to the collision at issue in this cause, pursuant to Federal Motor Carrier Safety Regulation §390.15(b)(1) and §390.1 5(b)(2).
  63. A copy of each traffic citation, FBMCS terminal or road equipment and driver compliance inspection, warning and/or citation issued to Defendant Rolfes and/or Dughly by any city, county, state federal agency or law enforcement official.
  64. Any written waivers regarding any medical condition of Defendant Dughly, which allowed him to engage in interstate trucking.
  65. Copies of the driver's signed receipt for any materials, brochures, books, policies, standards, safety matters, or other written material provided by the Defendant Rolfes to Defendant Dughly.
  66. Copies of all driver's licenses and truck driver certifications which Defendant Dughly possesses (currently) and did possess on the date of the incident.
  67. All documents as to the physical or mental condition of the Defendant Dughly before and at the time of the occurrence, including but not limited to his driver qualification file, post-collision drug testing results, and all other information regarding his medical condition for a one year period before the crash and the 48 hours after the crash.
  68. All documents regarding medications being taken or prescribed to Defendant Dughly for the year prior to the occurrence.
  69. The complete safety or violations file, permits file and/or safety department file for Defendant Dughly.
  70. All documents regarding arrests and or/convictions of the Defendant Dughly.
  71. Payroll, compensation, incentive pay, and records regarding the Defendant Dughly for work performed covering the 5 years preceding the collision and including the date of the collision.
  72. Records reflecting any compensation from Jones Supply to Rolfes, including any bonuses and/or discounts on Jones Supply products.
  73. All documents, phone call logs, or correspondence reflecting complaints or criticisms of any kind received by you from any source, including your personnel, concerning your driver, your company's jobs, the operation of, or failure to repair or maintain any power unit or trailer, including the tractor-trailer involved in this incident.
  74. All documents relating to traffic accidents involving Defendant Rolfes, including logbook and hours of service violations and other regulatory violations for the duration of the company's engagement with Jones Supply.
  75. All documents relating to traffic accidents involving Defendant Dughly, including logbook and hours of service violations and other regulatory violations for the duration of the driver's engagement with Rolfes.
  76. All records and reports of audits performed by the Bureau of Motor Carrier Safety or by any other state or federal agencies for Defendant Rolfes and/or Dughly.
  77. Any documents relating to disciplinary action contemplated or taken against Defendant Dughly involving the operation of the motor vehicle he was operating at the time of the collision.
  78. Please produce any and all titles, contracts, letters, leases, or payments reflecting the first termination or completion of any lease related to the tractor or the trailer since the incident.
  79. Please produce any title related to the tractor.
  80. Please produce each rental or lease agreement related to the tractor or the trailer.
  81. Please produce any agreements to place the Jones Supply logo on the tractor or trailer involved in this incident.
  82. Please produce all lease agreements, employment agreements, independent contractor agreements, or any other agreements between Defendant Jones Supply and Defendant Rolfes.
  83. A copy of the registration and title to the vehicle involved in this occurrence.
  84. Any and all records required to be kept pursuant to 49 C.F.R. 396.3, for any tractor and/or trailer/tanker operated by Defendant Rolfes at the time of the accident in this case.
  85. A copy of each out of service report or violation concerning the tractor or trailer involved in this incident from the year prior to the collision through the present, to include copies of any supplements, responses, or amendment to the same. This request specifically includes each out of service report or violation concerning each leased power unit or trailer utilized, maintained, or controlled by this defendant from the year prior to the collision through the present.
  86. A copy of each out of service report or violation concerning any tractor or trailer in the possession of Defendant Rolfes for 5 years prior to the collision through the present, to include copies of any supplements, responses, or amendment to the same. This request specifically includes each out of service report or violation concerning each leased power unit or trailer utilized, maintained, or controlled by this defendant from the year prior to the collision through the present.
  87. Please produce complete and clearly readable copies of all maintenance files and records from (at least one year prior to accident) maintained by Defendant Jones Supply in accordance 49 CFR 396 on the truck tractor involved in the accident inclusive of any inspections, repairs or maintenance done to the tractor tractor.
  88. Please produce all driver daily vehicle inspection reports (DVIRs) submitted by any driver(s) on the truck tractor from at least 30 days prior to the accident in the possession of Defendant Rolfes. This specifically includes all the driver's daily vehicle inspection reports (DVIRs), maintenance files and records maintained by any other person(s) or organization(s) that are in the possession of Defendant Rolfes.
  89. Please produce copies of all inspection reports for the vehicle which were conducted by state or municipal law enforcement agencies, as required by 49 CFR 390.30, or any state or municipal statutes or ordinances from for a period of five years leading up to the incident.
  90. Please produce a copy of any vehicle inspection report made by Defendant Rolfes during the 5 years prior to the incident including the date of the incident.
  91. Please produce a copy of any vehicle inspection report for the tractor or the trailer made by any person, company or agency during the five years before the incident and including the date of the incident.
  92. Please produce any and all DOT and State inspections of the tractor involved in the crash for the five years leading up to the date of this crash.
  93. Please produce complete and clearly readable copies of the maintenance files and records created from at least one year prior to accident maintained by Defendant Rolfes in accordance with 49 CFR 396 on the trailer pulled by Defendant Dughly on the day of the occurrence.
  94. Please produce complete and clearly readable copies of all driver's record of duty status or driver's daily logs and 70/60 hour - 8/7 day summaries or otherwise described time worked records created by Defendant Dughly and/or any of his/her co-driver(s) for the period from at least 90 days prior to the accident and for 30 days after the accident. This includes all logs prepared by any co-driver(s) operating with Defendant Dughly from at least 30 days prior to the accident.
  95. Please produce all unofficial logs of Defendant Dughly for the thirty days leading up to the incident involving Plaintiff and for thirty days after the incident maintained pursuant to 49 CFR 395.8(k) and preserved pursuant to 49 CFR 379 (including Appendix A, Note A).
  96. Please produce any and all Seven Day Prior Forms or Eight Day Prior Forms for Defendant Dughly for the month preceding the incident and the month of the incident.
  97. Please produce the printout(s) from any commercial software program (e.g. JJ Keller's LogChecker) or customized program used to record and audit Defendant Dughly logbook entries for the five years preceding the incident.
  98. Any and all audits of Defendant Dughly's logs, on-duty and driving time that you created during the six (6) month period preceding the collision through the delivery of the cargo being hauled at the time of the collision.
  99. Please produce all cellular telephone records and bills for any cellular telephone that was used by Defendant Dughly on the date of the incident and for the 3 days prior to the incident.
  100. Please produce all e-mail or text messages sent by or to Defendant Dughly from Defendant Jones Supply (including its agents, employees, dispatchers) for the seven days prior to the incident and the date of the incident.
  101. Please produce any and all driver call-in records, notes, logs or e-mail indicating communications between Defendant Jones Supply and Defendant Dughly for the seven days prior to the incident and om the date of the incident.
  102. Please produce any and all driver call-in records, notes, logs or e-mail indicating communications between Defendant Jones Supply and Defendant Dughly for the seven days prior to the incident and on the date of the incident.
  103. Please produce complete and clearly readable copies of any driver call-in records or otherwise described written or computer (all screen) records indicating any communications between Defendant Jones Supply and Defendant Dughly on the day of the incident.
  104. Please produce any and all mileage logs and travel reimbursement records for Defendant Dughly for the month of the incident.
  105. Please produce any and all receipts for fuel for the tractor involved in this incident for the 12 months prior to the incident.
  106. Please produce complete and clearly readable copies of Defendant Dughly's trip reports, daily loads delivered or picked up reports or any otherwise titled or described work reports, work schedule reports, fuel purchased reports, or any other reports made by Defendant Dughly to Defendant Jones Supply, inclusive of daily, weekly or monthly cargo transported, time and/or distance traveled reports or work records excluding only those documents known as "driver's daily logs or driver's record of duty status" for the month of the incident.
  107. Please produce complete and clearly readable copies of all cargo pickup and delivery documents prepared by Defendant Jones Supply, any transportation brokers, involved shippers or receivers, motor carriers operations/dispatch personnel, drivers, or other persons or organizations relative to the cargo transported and the operations of Defendant Dughly for the seven (7) days leading up to and including the date of the incident.
  108. Please produce complete and clearly readable copies of all bills of lading and/or cargo manifest prepared or issued by any shippers, brokers, transporting motor carriers, receivers of cargo, or Defendant Jones Supply. This specifically includes readable and complete copies of bills of lading, manifest, or other documents regardless of form or description, that show signed receipts for cargo pickup and delivered along with any other type of document that may show dates and times of cargo pickup or delivery that are relative to operations and cargo transported by Defendant Dughly on the date of the incident.
  109. Please produce complete and clearly readable copies of all cargo transported freight bills, Pros or otherwise described similar documents inclusive of all signed or unsigned cargo pickup and delivery copies that indicate date and/or time of pick up or delivery of cargo by Defendant Dughly or his/her co-driver(s) on the date of the incident.
  110. Please produce all records of Defendant Dughly for the 7 days prior to the incident and for the day of the incident. Specifically, produce the supporting documents listed below which the Defendant Rolfes is required to maintain under 49 CFR 395.8(k) and to preserve under 49 CFR 379 (including Appendix A, Note A).
    1. Bills of lading;
    2. Carrier pros;
    3. Freight bills;
    4. Dispatch records;
    5. Driver call-in records;
    6. Gate record receipts;
    7. Weight/scale tickets;
    8. Fuel billing statements and/or summaries;
    9. Toll receipts;
    10. International registration plan receipts;
    11. International fuel tax agreement receipts;
    12. Trip permits;
    13. Lessor settlement sheets;
    14. Delivery receipts;
    15. Over/short and damage reports;
    16. Commercial Vehicle Safety Alliance reports;
    17. Accident reports;
    18. Traffic citations;
    19. Overweight/oversize reports and citations;
    20. And/or other documents directly related to the motor carrier's operation which are retained by the motor carrier in connection with the operation of its transportation business.
  111. Please produce copies of any and all satellite communications and e-mail for the day of the incident involving Plaintiff and seven days prior, as well as all recorded ECM (electronic control module), EDR (event data recorder), and/or SDM (sensing & diagnostic module) chronological data with reference to all data available, including but not limited to:
    1. Trip distance
    2. Total vehicle driving time
    3. Load factor
    4. Vehicle speed limit
    5. Maximum vehicle speed recorded
    6. Number of hard brake incidents
    7. Current engine speed (rpm)
    8. Maximum and minimum cruise speed limits
    9. Total vehicle driving distance
    10. Fuel consumption (gal./hr.)
    11. Idle time
    12. Engine governed speed
    13. Maximum engine speed recorded
    14. Current throttle position
    15. Brake switch status (on/off)
    16. Odometer
    17. Trip driving time
    18. Overall fuel economy (MPG)
    19. Average driving speed
    20. # of engine overspeeds
    21. # of vehicle overspeeds
    22. Current vehicle speed (MPH)
    23. Clutch switch status
    24. Clock
  112. Please provide documents evidencing the job or trip that Defendant Dughly was performing at the time of the incident in question, including the name of the corporate entity for which the job or trip was being performed.
  113. Please produce any and all accident and/or incident reports and investigations prepared by Defendant Rolfes (prepared prior to any litigation) as a result of the crash other than the police report.
  114. Please produce any and all incident, accident, or injury reports related to the incident that were prepared by Defendant Dughly, or by any employee, owner, or agent of Defendant Rolfes (prepared prior to any litigation).
  115. Please produce any and all incident, accident or injury reports related to the incident that were prepared by any law enforcement agency.
  116. Please produce any photographs taken of the tractor-trailer operated by Defendant Dughly at the scene of the incident, or any time after.
  117. Please produce any photograph, film, videotape, moving pictures, electronic image or recording, or any audiotape which depicts or contains the image of the tractor or trailer at the scene of the incident, or any time after (you may exclude from your response hereto any item which you have produced in response to any previous request herein).
  118. Please produce a copy of any recorded statement, or any other statement, made by any Plaintiff to Defendants or its servants, agents, employees, contractors, investigators, or liability insurance carriers.
  119. Please produce any photograph, media coverage, film, videotape, moving pictures, electronic image or recording, or any audiotape which contains, constitutes or depicts any surveillance video, photographs, or recording related to any party (including plaintiff), or the scene (you may exclude from your response hereto any item which you have produced in response to any previous request herein).
  120. Please produce a copy of any traffic citation issued to Defendant Dughly related to the incident.
  121. Please produce any and all e-mail sent by, or to, Defendant Jones Supply (including its employees or agents) concerning the incident. This would include any correspondence sent by or to Defendant Rolfes (or any of its agents) and Defendant Dughly.
  122. Please produce any statements, written, audiotaped, or otherwise recorded or memorialized of any of the parties or witnesses to the incident.
  123. Please produce copies of data printout of any Electronic Control Module download that was performed on the tractor involved in this crash at any point in time following the crash at issue.
  124. Produce your complete file concerning the Department of Transportation (DOT) as it related to this subject incident and/or copies of any and all material, correspondence, memoranda, notes, communications, or written or printed documents of any description whatsoever which exist between this defendant and Department of Transportation (DOT) regarding the subject accident.
  125. Please produce a copy of each primary, umbrella, and excess insurance policy, or agreement, including the declarations page, for Defendant Rolfes, Defendant Dughly, and Defendant Jones Supply, which was in effect at the time of this incident.
  126. Please produce any and all insurance contracts which provide secondary or excess coverage to Defendant Rolfes, Defendant Dughly, and Defendant Jones Supply for any risk related to the incident.
  127. Please produce any and all documents reflecting payments to any person or legal entity arising out of claims made against you arising out of the accident made the basis of this suit, whether paid by you or any person or entity (including insurance) on your behalf.
  128. Please produce all documents concerning any bills, attorney's fees, court costs, expenses, expert fees, formal or informal, that reduce the amount of liability insurance available to cover Plaintiff.
  129. Please produce all documents, records, reports, or memoranda regarding Plaintiff from persons or entities that gather claim information, i.e. insurance claims and worker's compensation claims, specifically including (insurance agency in dispute) and all similar persons or entities.
  130. Produce all documents in your possession, or in the possession of you insurers, representatives, agents, or investigators, regarding any property damage to any vehicle, the contents of any vehicle, any stationary object, or any other real or personal property damage resulting from the incident complained of, including but not limited to repair estimates, appraisals, purchase invoices, repair bills, and checks or drafts reflecting payment for repair or replacement, and any other documents concerning or establishing the value of any item of property before or after the incident complaint of.
  131. Copies of any diagrams of the scene of the incident.
  132. All accident reports, police reports, and or investigation reports regarding this occurrence, including but not limited to correspondence, and reports sent to or received from any federal, state or local regulatory agency pertaining to this wreck.
  133. All documents received pursuant to any subpoena requests.
  134. All documents prepared during the regular course of business as a result of the incident.
  135. Copies of any treatise, standards in the industry, legal authority, rule, case, state or federal statute, state or federal regulation, or code that will be relied upon in the defense of this case.
  136. All documents concerning any release, settlement or other agreement, formal or informal involving any of the parties.
  137. All documents, demonstrative or physical evidence you intend to place into evidence or use in front of the court or jury at the trial of this cause not previously supplied.
  138. All documents and other things identified in your Answers to interrogatories.
  139. Any and all records, documents, transcripts, and recordings (including, but not limited to, traffic transcripts) pertaining to any hearings or proceedings regarding this collision.
  140. All writings and records in the possession, custody or control of this Defendant or this Defendant's attorney listed in, referred to, or used in the preparation of this Defendant's answers or responses to Plaintiff's First Set of Interrogatories.
  141. Any and all bills of lading, shipper documents and receipts for the load being hauled by Defendant Rolfes and Dughly at the time of the subject collision.
  142. Any and all documents memorializing the transport of loads by Defendant Rolfes and Dughly brokered by Defendant Jones Supply prior to the subject collision.
  143. Any and all documents regarding any communications between Defendant Jones Supply and any Defendants, their agents or employees, concerning the load that was being transported by Defendant Rolfes and Dughly at the time of the collision.
  144. Any and all documents regarding any loads transported by Defendant Rolfes and Dughly at the request of Defendant Jones Supply prior to the subject collision.
  145. Any and all documents relating to any investigation performed by Defendant Jones Supply concerning Defendant Rolfes's safety rating, safety fitness, Federal Motor Carrier Safety Administration's safety measurement system, behavioral analyst and safety improvement categories (BASICs), including unsafe driving, hours of service compliance, maintenance history, driver fitness, controlled substances/alcohol, vehicle accidents, list of crashes, roadside inspections and commercial vehicle violations prior to the date of the subject collision.
  146. Any and all documents relating to any investigation performed by Defendant Jones Supply concerning Defendant Dughly's safety rating, safety fitness, Federal Motor Carrier Safety Administration's safety measurement system, behavioral analyst and safety improvement categories (BASICs), including unsafe driving, hours of service compliance, maintenance history, driver fitness, controlled substances/alcohol, vehicle accidents, list of crashes, roadside inspections and commercial vehicle violations prior to the date of the subject collision.
  147. Any and all documents relating to any broker/carrier agreements between Defendant 84 Lumber and Defendant Rolfes.
  148. All documents regarding the Defendant Rolfes, including Defendant Rolfes's safety rating, authority, insurance information and/or BASIC scores.
  149. All publications, manuals, literature, guidelines, or other written materials provided by Defendant Jones Supply to Defendant Rolfes (or any of its' drivers) at any time prior to the date of the subject collision.
  150. All maps, directions, or delivery instructions that were provided by Defendant Jones Supply to Defendant Rolfes drivers prior to the date of the subject collision.
  151. All records related to any form of reimbursement that was provided by Defendant Jones Supply to Defendant Rolfes drivers while hauling on behalf of Defendant 84 (this would include reimbursement for gasoline).

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★★★★★
The case settled and I got a lot more money than I expected. Ron even fought to reduce how much I owed in medical bills so I could get an even larger settlement. Nchedo Idahosa

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