Sample 30(B)(6) Deposition

Below is a sample 30(B)(6) deposition subpoena. Rule 30(b)(6) requires a party to present witnesses who are prepared to testify “about information known or reasonably available to the organization.” Fed. R. Civ. P. 30(b)(6).

This mechanism allows plaintiffs' lawyers to obtain discovery against a corporation by specifying topics on which testimony is sought, requiring the organization to designate witnesses to provide testimony on these subject that may bound the corporation at trial.

This same procedure is available under in Maryland state court under Maryland Rule 2-412(d) based on the federal rule.

IN THE CIRCUIT COURT FOR BALTIMORE CITY, MARYLAND

MICHAEL THOMAS MARTINEZ, II, et al. :
Plaintiffs, :
v. : Case No.: 24-C-15-003129
Jones Supply COMPANY, LP, et al. :
Defendants. :


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NOTICE OF VIDEOTAPED DEPOSITION OF CORPORATE REPRESENTATIVE FOR Jones Supply COMPANY, LP

You are hereby notified that Plaintiff, Taylor Martinez, by and through her attorneys, Ronald V. Miller, Jr., Laura G. Zois, Esq., Justin P. Zuber, Esq., and Miller & Zois, LLC, pursuant to the Maryland Rules of Procedure § 2-412 and § 2-416, will take the deposition upon oral examination, for use in discovery and at trial, of the following persons on the date and at the time indicated below before a person duly authorized to administer an oath under Maryland law to be recorded stenographically/audio/videotape. The deposition will be recorded via stenographic, audio, and/or videotaped means for the purpose of discovery and/or used as evidence and/or any other purposes permitted by the Maryland Rules of Civil Procedure, including use at trial, and will continue day to day until completed. Defendant Jones Supply Company, LP shall produce a corporate representative(s) with the knowledge and ability to testify regarding the topics described in the attached "Schedule A." In addition, the Deponent shall bring to the deposition the documents/things listed in the "Schedule A." You are advised that you must designate one or more officers, directors, managing agents, or other persons who will testify on your behalf regarding the matters listed in "Schedule A" which are known or reasonably available to Jones Supply Company, LP.

DEPONENT: Corporate Representative for Jones Supply
Company, LP
DATE: Friday, October 14, 2019
TIME: 10:00 a.m.
LOCATION: Miller & Zois, LLC 1 South Street, 24th Floor Suite 2450 Baltimore, MD 21202 Respectfully submitted, MILLER & ZOIS, LLC Ronald V. Miller, Jr. 1 South Street, 24th Floor Suite 2450 Baltimore, MD 21202 Phone: 410-553-6000 Fax: 844-712-5151

Attorneys for the Plaintiff Taylor D. Martinez and the Estate of Abigail Martinez

SCHEDULE A

A. LIST OF TOPICS FOR Jones Supply COMPANY, LP REPRESENTATIVE

  1. Knowledge of 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.
  2. Knowledge of 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.
  3. Knowledge of any employee handbook for Defendant Rolfes that was in effect at the time of the incident.
  4. Knowledge of the driver manual, company handbook, or their equivalent issued to Defendant Rolfes and Dughly by Jones Supply.
  5. Knowledge of the company safety rules or its equivalent issued to Defendant Rolfes and Dughly by Jones Supply that were in effect on August 27, 2018, and for 1 year prior.
  6. Knowledge of the company safety rules or its equivalent for Defendant Rolfes that were in effect on August 27, 2018, and for 3 years prior.  [Note: this is a stretch, probably better to ask for one year.]
  7. Knowledge of 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.
  8. Knowledge of all memoranda, policies, procedures or correspondence given or sent to Defendant Rolfes about the falsification of records during their engagements with Jones Supply.
  9. Knowledge of all policies or procedures of Defendant Rolfes 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.
  10. Knowledge of 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.
  11. Knowledge of 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.
  12. Knowledge of 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.
  13. Knowledge 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.
  14. Knowledge of each of the following documents 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.
  15. Knowledge of all documents reflecting the repair history for the truck and trailer involved in the occurrence.
  16. Knowledge of 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 Jones Supply during the five (5) year period prior to the subject incident and through the present date, together with all amendments, revisions or supplements thereto.
  17. Knowledge of all training or instructional videotapes, CDs or DVDs used by any Defendant Jones Supply in its training any of its drivers at any time during the five years before the occurrence.
  18. Knowledge of 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 Defendant Jones Supply to Defendant Rolfes and/or Defendant Dughly for the 5 year period preceding the collision in question.
  19. Knowledge of all safety ratings issued to Defendant Rolfes by any federal government agency for the five years preceding the incident.
  20. Knowledge 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.
  21. Knowledge of 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 from five (5) years prior to and including date of loss.
  22. Knowledge 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.
  23. Knowledge of all documents that indicate your company is a common carrier, a contract carrier, or a private carrier.
  24. Knowledge of all DOT and State agency reviews of your company for the period commencing 10 years prior to this collision, to the present time.
  25. Knowledge of all correspondence writings and/or documents sent by Defendant Jones Supply to Defendant Rolfes 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.
  26. Knowledge of 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.
  27. Knowledge of any job, driver, independent contractor, and/or employment application filled out or signed by Defendant Dughly.
  28. Knowledge of 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).
  29. Knowledge of all documents reflecting any background check performed on Defendant Dughly with regard to their employment history or job references, including letters of reference.
  30. Knowledge of 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).
  31. Knowledge of any job, driver, independent contractor, and/or employment application filled out or signed by Defendant Rolfes.
  32. Knowledge of any investigations performed by Jones Supply regarding Defendant Rolfes's safety history, safety ratings, driver qualifications, driver fitness, accident history, drug, and alcohol testing, and vehicle maintenance.
  33. Knowledge of all documents reflecting any background check performed on Defendant Rolfes with regard to their safety protocols, safety manuals, safety guidelines, and record keeping.
  34. Knowledge of 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.
  35. Knowledge of all documents reflecting any background check performed on Defendant Dughly with regard to his criminal history.
  36. Knowledge 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.
  37. Knowledge of 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.
  38. Knowledge of all actual driver's motor carrier written tests administered to Defendant Dughly, including all answers.
  39. Knowledge of 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.
  40. Knowledge of the job description of the position that Defendant Dughly was initially hired, employed or retained to perform for Defendant Rolfes.
  41. Knowledge 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.
  42. Knowledge of the entire personnel file of Defendant Dughly.
  43. Knowledge of the entire file for Defendant Rolfes.
  44. Knowledge of 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.
  45. Knowledge of 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.
  46. Knowledge of all evaluations or criticism of the job performance of Defendant Rolfes by Jones Supply, including but not limited to annual evaluations, interim evaluations, or specific incidents that gave rise to an evaluation or criticism.
  47. Knowledge of all evaluations or criticism of the job performance of any of Defendant Rolfes's drivers by Jones Supply, including but not limited to annual evaluations, interim evaluations, or specific incidents that gave rise to an evaluation or criticism.
  48. Knowledge of 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.
  49. Knowledge of each annual review of Defendant Rolfes's safety and fitness to haul on behalf of Defendant Jones Supply.
  50. Knowledge 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.
  51. Knowledge 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.
  52. Knowledge of any and all state safety audits and/or state roadside inspections for Defendant Rolfes for the year of this incident and five years prior.
  53. Knowledge of any and all long-form DOT physicals for Defendant Dughly for the time he was a driver for Defendant Rolfes.
  54. Knowledge of all documents relating to any disqualification of Defendant Dughly made pursuant to any Federal Motor Carrier Safety Regulation.
  55. Knowledge of 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.
  56. Knowledge of all DOT inspection reports filed for Defendant Rolfes for the year of this incident and five years prior.
  57. Knowledge 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).
  58. Knowledge 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).
  59. Knowledge 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.
  60. Knowledge of all driver's licenses and truck driver certifications which Defendant Dughly possesses (currently) and did possess on the date of the incident.
  61. Knowledge of 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.
  62. Knowledge of all medications being taken or prescribed to Defendant Dughly for the year prior to the occurrence.
  63. Knowledge of all arrests and or/convictions of the Defendant Dughly.
  64. Knowledge of all payroll, compensation, incentive pay for Defendant Dughly for work performed covering the 5 years preceding the collision and including the date of the collision.
  65. Knowledge of any compensation from Jones Supply to Rolfes, including any bonuses and/or discounts on Jones Supply products.
  66. Knowledge of any compensation from Jones Supply to Defendant Dughly (or any other Rolfes driver), including any bonuses and/or discounts on Jones Supply products.
  67. Knowledge of all phone call logs, or correspondence reflecting complaints or criticisms of any kind received by Defendant Jones Supply from any source, including Jones Supply personnel, concerning the performance of Defendant Rolfes drivers while hauling for Defendant Jones Supply.
  68. Knowledge of 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.
  69. Knowledge of 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.
  70. Knowledge of 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.
  71. Knowledge of all disciplinary action contemplated or taken against Defendant Dughly involving the operation of the motor vehicle he was operating at the time of the collision.
  72. Knowledge of the title related to the tractor.
  73. Knowledge of each rental or lease agreement related to the tractor or the trailer.
  74. Knowledge of any agreement or requirement to place the Jones Supply logo on the tractor or trailer involved in this incident.
  75. Knowledge of all lease agreements, employment agreements, independent contractor agreements, or any other agreements between Defendant Jones Supply and Defendant Rolfes.
  76. Knowledge of a copy of the registration and title to the vehicle involved in this occurrence.
  77. Knowledge 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.
  78. Knowledge 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.
  79. Knowledge of all maintenance files and records from at least one year prior to accident maintained by Defendant Rolfes 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.
  80. Knowledge of 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 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.
  81. Knowledge 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.
  82. Knowledge of any vehicle inspection report made by Defendant Rolfes during the 5 years prior to the incident including the date of the incident.
  83. Knowledge 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.
  84. Knowledge of 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.
  85. Knowledge of all 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.
  86. Knowledge 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.
  87. Knowledge of 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).
  88. Knowledge of 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.
  89. Knowledge of all e-mail or text messages sent by or to Defendant Dughly from Defendant Rolfes (including its agents, employees, dispatchers) for the seven days prior to the incident and the date of the incident.
  90. Knowledge of all driver call-in records, notes, logs or e-mail indicating communications between Defendant Rolfes and Defendant Dughly for the seven days prior to the incident and om the date of the incident.
  91. Knowledge of 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.
  92. Knowledge of all mileage logs and travel reimbursement records for Defendant Dughly for the month of the incident.
  93. Knowledge of all receipts for fuel for the tractor involved in this incident for the 12 months prior to the incident.
  94. Knowledge 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 Rolfes and/or 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.
  95. Knowledge 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.
  96. Knowledge 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.
  97. Knowledge 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 the 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.
  98. Knowledge of 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.
  99. Knowledge of 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
  100. Knowledge of all 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.
  101. Knowledge of 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.
  102. Knowledge of 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).
  103. Knowledge of any photographs taken of the tractor-trailer operated by Defendant Dughly at the scene of the incident, or any time after.
  104. Knowledge of 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).
  105. Knowledge 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.
  106. Knowledge of 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).
  107. Knowledge of 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.
  108. Knowledge of any statements, written, audiotaped, or otherwise recorded or memorialized of any of the parties or witnesses to the incident.
  109. Knowledge of any 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.
  110. Knowledge of any 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.
  111. Knowledge of 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.
  112. Knowledge of 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.
  113. Knowledge of 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 the Plaintiff.
  114. Knowledge of 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.
  115. Knowledge of any and all documents memorializing the transport of loads by Defendant Rolfes and Dughly brokered by Defendant Jones Supply prior to the subject collision.
  116. Knowledge of 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.
  117. Knowledge of 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.
  118. Knowledge of 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, driver fitness, controlled substances/alcohol, vehicle accidents, list of crashes, roadside inspections and commercial vehicle violations prior to the date of the subject collision.
  119. Knowledge of 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, driver fitness, controlled substances/alcohol, vehicle accidents, list of crashes, roadside inspections and commercial vehicle violations prior to the date of the subject collision.
  120. Knowledge of any and all documents relating to any broker/carrier agreements between Defendant Jones Supply and Defendant Rolfes.
  121. Knowledge of all documents regarding the Defendant Rolfes, including Defendant Rolfes's safety rating, authority, insurance information and/or BASIC scores.
  122. Knowledge of each Defendant Jones Supply employee who investigated Defendant Rolfes's fitness to haul on behalf of Jones Supply prior to the date of the subject collision (this includes the initial investigation and any subsequent investigations, whether annually, bi-annually, etc.). This would include anyone who investigated Defendant Rolfes's safety rating, safety fitness, Federal Motor Carrier Safety Administration's safety measurement system rating, behavioral analyst and safety improvement category (BASICs) score, unsafe driving history, hours of service compliance, drivers qualifications, drivers history with controlled substances/alcohol abuse, vehicle accidents, list of crashes, roadside inspections, maintenance history, compliance with Federal and State regulations, records keeping violations, and commercial vehicle violations prior to the date of the subject collision.
  123. Knowledge of the Defendant Jones Supply employees who were responsible for and played a role in negotiating and establishing the hauler relationship between Defendant Jones Supply and Defendant Rolfes.
  124. Knowledge of any 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.
  125. Knowledge of any maps, directions, or delivery instructions that were provided by Defendant Jones Supply to Defendant Rolfes drivers prior to the date of the subject collision.
  126. Knowledge of any forms 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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