Trucking Discovery – Part 1- RFP

Here is part one of a trucking RFP we use  – let me know if you have success with it.

REQUESTS FOR PRODUCTION

            Please produce the following:

1.         A copy of each document (as that term is defined above) referred to in your responses to Plaintiff’s First Interrogatories to Defendant MYLAR Industries, Inc.

2.         A copy of each insurance policy, including declarations page, that provides or may provide coverage for damages sustained in the Subject Incident.

3.         A copy of all correspondence that you have had with any insurer and/or adjuster regarding in any way the Subject Incident.

4.         A copy of each and every document (as that term is defined above) that you provided to Defendant Fennell for educational, training, instructional or like purposes, including without limitation any and all training manuals, standards, policies, procedures, and the like.

5.         A copy of each document (as that term is defined above) evidencing, illustrating and/or relating in any way to each of the collisions, wrecks and/or accidents identified in your response to Interrogatory No. 11.

6.         A copy of all documents (as that term is defined above) evidencing, related to and/or referring in any way to any of the lawsuits and/or claims identified in your response to Interrogatory No. 12.

7.         A copy of each statement and report (written, oral, recorded, transcribed, not transcribed, etc) identified in your response to Interrogatory No. 17.

8.         A current resume or curriculum vita for each expert witness identified in your response to Interrogatory No. 18.

9.        A copy of each license, permit and other grant of authority identified in your response to Interrogatory No. 16.

10.       A copy of every photograph (negative, positive, video, digital and/or other) in your (including your attorney’s) possession, custody and/or control that depicts in any way either of the vehicles (including trailer) or persons involved in the Subject Incident, the location of the collision, and/or any other item, person, vehicle or other matter relevant to this lawsuit.

11.      A copy of every photograph and other document (as that term is defined above) in your (or your attorney’s) possession, custody and/or control that relates, refers, mentions, illustrates and/or discusses in any way any of the following facts regarding the tractor operated by Defendant Fennell at the time of the Subject Incident:

(a)                Copy of Title for tractor;

(b)               Registered owner of tractor on Incident;

(c)                When tractor was purchased, mileage at purchase, and from whom purchased;

(d)               Mileage at time of collision;

(e)                Damage resulting from collision and repairs of the damage;

(f)                All maintenance records regarding tractor;

(g)               All driver condition reports (daily/weekly); and

(h)               Copy of each and every logbook, ledger, file or the like maintained for any reason regarding this tractor.

 

12.    A copy of every photograph and other document (as that term is defined above) in your (or your attorney’s) possession, custody and/or control that relates, refers, mentions, illustrates and/or discusses in any way any of the following facts regarding the trailer that was being hauled by Defendant Fennell at the time of the Subject Incident:

(a)                Copy of Title for trailer;

(b)               Registered owner of trailer on Incident;

(c)                When trailer was purchased and from whom purchased;

(d)               Manufacturer name and model number;

(e)                Damage resulting from collision and repairs of the damage;

(f)                All maintenance records regarding trailer;

(g)               All driver condition reports (daily/weekly) regarding trailer; and

(h)               Copy of each and every logbook, ledger, file or the like maintained for any reason regarding this tractor.

13.             A copy of every photograph and other document (as that term is defined above) in your (or your attorney’s) possession, custody and/or control that relates, refers, illustrates and/or discusses in any way the Plaintiff.

14.             A copy of every photograph and other document (as that term is defined above) in your (or your attorney’s) possession that relates, refers, illustrates and/or discusses in any way the load being hauled by Defendant Fennell at the time of the Subject Incident, including, by way of example and without limitation, all documents evidencing: (a) contents of the load; (b) who owned the load at any time; (c) where it came from; (d) where it was loaded; (e) owner of the location where loaded; (f) where it was to be delivered; (g) owner of location where it was to be delivered; and (h) quantity and/or weight of load.

            15.       A copy of each and every document that reflects any statements made by the        Plaintiff and/or that purports to contain the signature of the Plaintiff.

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