18 wheeler truck accident cases are not just like any other automobile accident case for the South Carolina injury lawyer. For example, there are multiple possible defendants who may not be apparent to attorneys without extensive experience in truck cases. Further, complex regulatory schemes factor into each tractor trailer accident case involving personal injuries. Here you will find some requests for production I have used in truck accident cases, which illustrate the specialized nature of this kind of litigation.
1. Produce the application for employment with the motor carrier, which was submitted or completed by the driver.
2. Produce any and all random and/or post-accident alcohol and drug testing on the driver, and include any and all chain of custody documents.
3. Produce the certificate of driver's road test completed by the person or persons who tested the driver.
4. Produce credit card account receipts, including fuel card receipts, records and printouts, for all accounts to which the driver had access during the six month period prior to the accident through one week subsequent to the date of the accident, including usage records of said accounts by the driver.
5. Produce the record road test completed by the person or persons who either tested or supervised the testing of the driver.
6. Produce toll receipts, fuel receipts, expense receipts, trip envelopes, trip sheets (including trip papers), and trip expense reports for each trip driven by the driver, for a six month period prior to the subject accident, through one week subsequent to the date of the accident.
7. Produce the certificate of written examination completed by the person or persons who either administrated or supervised the administration of the written examination given.
8. Produce all course materials (whether audio, video, written or verbal) received by the driver in any safe driving or defensive driving course for a ten year period prior to the subject accident.
9. Produce the written examination administered to the driver including the driver's answers thereto.
10. Produce all videotapes, audiotapes, presentations, manuals, hand-outs, memoranda or other materials received by the driver with regard to driver training.
11. Produce the certificate of physical examination completed by any physician who has examined the driver, and the report or forms completed by the physician.
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