Truck Accident Lawyer Blog

12. Produce all manifests, receipts, orders, shipping documents, shipping invoices, waybills, routing slips, delivery schedules, bills of lading, or other records of pickups and deliveries for the routes of the driver for the six month period prior to the subject accident through one week after the date of the accident.

13. Produce any forms submitted by the driver to the motor carrier during the entire length of his employment with the motor carrier.

14. Produce all records and notations of communications, or records which memorialize or relate to any communications or contact, or to tracking or which provide an historical record of such communications or contact between the motor carrier and the driver, including letters, correspondence, e-mails, telephone records, telephone notes, SATCOM, data, radio records, radio notes, manual logs, notations, or memoranda.

15. Produce all forms or reports completed by the motor carrier or its officers, employees, or agents, during the entire length of the driver's employment demonstrating that the annual review of the driver's driving was performed.

16. Produce all records and notations regarding the driver and his rig, including computer records, computer logs, manual logs, driver logs, e-mail, QUALCOMM records, SATCOM records, COMDATA records, computer histories, trip records, trip sheets, locator histories, position histories, and any other computerized or manual records whatsoever, for the six month period prior to the accident through one week subsequent to the date of the accident.

17. Produce the request for check of driving record submitted to any governmental agency or private entity by the motor carrier, or its officers, employees, or agents requesting a copy of the driving record of the driver and the results received in response to the request(s).

18. Produce all accident, incident or investigative reports prepared by, filed or requested by you concerning the subject accident, including all notes, memoranda, photographs or other documents relating thereto.

19. Produce the results of all pre-employment, periodic, random or post accident controlled substance or alcohol testing of the driver.

20. Produce a complete copy of any and all cellular telephone records for any phone used by the driver while operating any vehicles owned, leased, used or controlled by the motor carrier and/or the driver for the period beginning six months prior to the date of the collision and ending one week after the date of the collision.

21. Produce the request for information from previous employers submitted to all former employers of the driver, by the motor carrier, or its officers, employees or agents and the results received in response to the requests.

22. Produce the entire personnel file, cover to cover, of the driver.

23. Produce all notes or other records included in the driver's qualification file for the driver which set forth the dates all annual reviews of the driving record of the driver were performed.

24. Produce the driver's qualification file, cover to cover, of the driver.

25. Produce the driver's duty status records of the driver that were completed by the driver for the six month period prior to the accident through one week subsequent to the date of the accident, which relate to the driver's operation of any vehicle owned, leased or controlled by the motor carrier.

26. Produce the driver's daily or multi-daily log or log book of the motor carrier that the driver completed for the six month period prior to the accident through one week subsequent to the date of the accident, which relate to the driver's operation of any vehicles owned, leased, used or controlled by the motor carrier.

27. Produce the on-board computer records that relate to the driver's operation of any vehicles owned, leased, used or controlled by the motor carrier.

28. Produce the driver's vehicle inspection reports for any vehicles operated by the driver for the six month period prior to the accident through one week subsequent to the date of the accident, which relate to any vehicles owned, leased, used or controlled by the motor carrier.

29. Produce the driver's pre-trip check list completed by the driver prior to departure on the trip in which the driver collided with the vehicle being driven by the Plaintiff.

30. Produce the MCS 50-T or MCS 50-B forms completed by either the driver or any officers, agents or employees of the motor carrier concerning the collision between the vehicle operated by the driver and the vehicle operated by the Plaintiff which were submitted to any governmental or regulatory agency.

31. Produce all MCS 50-T or MCS 50-B forms completed by either the driver or any officers, agents, or employees of the motor carrier which were submitted to any governmental or regulatory agency concerning any accidents involving the driver during the period of the driver's employment with the motor carrier.

32. Produce a copy of the title for the tractor trailer operated by the driver on the date of the subject accident.

33. Produce any photographs, movies and videotapes taken by the motor carrier and/or the driver, or by their agents, attorneys, investigators or insurance carriers, or in the possession of the Defendants or their agents, attorneys, investigators or insurance carriers, which you intend to use in any deposition taken in this case, that reflect the scene of the collision which is the subject of the Complaint, the vehicles involved in the collision or of any of the parties to this case.

34. Produce any photographs, movies and videotapes taken by the motor carrier and/or the driver, or by their agents, attorneys, investigators or insurance carriers, or in the possession of the Defendants or their agents, attorneys, investigators or insurance carriers, which you intend to use at the trial of this case, that reflect the scene of the collision which is the subject of the Complaint, the vehicles involved in the collision or of any of the parties to this case.

35. Produce any drawings or diagrams of the scene of the collision which is the subject of the Complaint which are in the possession and/or custody of the motor carrier and/or the driver, or their agents, attorneys, investigators, or insurance carriers, which you intend to use in any deposition taken in this case.

36. Produce any drawings or diagrams of the scene of the collision which is the subject of the Complaint which are in the possession and/or custody of the motor carrier and/or the driver, or their agents, attorneys, investigators, or insurance carriers, which you intend to use at the trial of this case.

37. Produce any exhibits prepared by the motor carrier and/or the driver, or their agents, attorneys, investigators or insurance carriers, which are in the possession, custody or control of same, and which you intend to use at any deposition taken in this case.

38. Produce any exhibits prepared by the motor carrier and/or the driver, or their agents, attorneys, investigators or insurance carriers, which are in the possession, custody or control of same, and which you intend to use at the trial of this case.

39. Produce a copy of the application and/or claims for benefits and/or claims for payments submitted by the motor carrier and/or the driver to any insurance company for personal injuries and/or property damage allegedly sustained by the Defendants in the collision.

40. Produce all maintenance invoices in the possession, custody or control of the Defendants, or their agents, attorneys, investigators, experts, or insurance carriers regarding the tractor and trailer operated on the date of the collision, which was involved in the collision alleged in the Complaint for the period commencing six months prior to the date of the accident and including the date of the accident, up to and until the date of your response to this request. Maintenance invoices, as defined herein, include any mechanical services or products added to the tractor and/or trailer which you owned or operated on the date of the collision, and any mechanical operations performed on the motor vehicle for the time period stated herein.

41. Produce any statements, either written or recorded, made by the Plaintiff and/or Plaintiff's family members which are in the possession, custody or control of the motor carrier and/or the driver, or their agents, attorneys, investigators or insurance carriers.

42. Produce a certified copy of any liability insurance policies, including, but not limited to any excess or umbrella policies, covering the motor carrier and/or the driver and/or the tractor and/or the trailer operated by the driver on the date of the collision. This request is also meant to discover and shall include any information regarding any agreements to extend coverage beyond the original limits.

43. Produce all compliance reviews or safety reviews of the motor carrier and/or the driver performed by any state or federal government agency for the period beginning ten years prior to the date of the collision up through and including the time of your response to this request to produce.

44. Produce all safety management controls that the motor carrier and/or the driver had in effect on the date of the collision.

45. Produce all safety ratings issued to the motor carrier and/or the driver by any state or federal government agency for the period beginning ten years prior to the date of the collision up to and including the time of your response to this request to produce.

46. Produce all notifications of safety ratings provided to the motor carrier and/or the driver by any state or federal governmental agency.

47. Produce a complete copy of the motor carrier and/or the driver's motor carrier identification report.

48. Produce all requests submitted by the motor carrier and/or the driver for a change in safety rating.

49. Produce the MCS-90 form that covers the motor carrier and/or the driver and/or the tractor and/or the trailer operated by the driver which was in effect on the date of the collision.

50. Produce the permanent lease for the tractor and/or the trailer operated by the driver during the collision.

51. Produce the trip lease for the tractor and/or the trailer operated by the driver during the collision.

52. Produce the MCS-151, Parts A, B and/or C form for the tractor and/or trailer operated by the driver during the collision.

53. Produce the MCS-82 form for the tractor and/or the trailer operated by the driver during the collision.

54. Produce copies of all trip envelopes, trip reports or expense sheets relating to any trips made by the driver for the period beginning six months prior to the date of the collision and ending one week after the collision, whether for the motor carrier or any other person or entity.

55. Produce the motor carrier and/or the driver's policies and procedures relating to alcohol and drug testing.

56. Produce the motor carrier and/or the driver's manuals covering truck safety, maintenance, fleet safety programs and driver standards.

57. Produce any and all documents associated with or generated as a result of any inspections performed on the tractor and/or trailer operated by the driver on the date of the collision.

58. Produce all risk management guidelines provided to the motor carrier by any and all insurance companies.

59. Produce all written requests made by the motor carrier and/or the driver to any insurance carrier for any risk management guidelines or risk management plans.

60. Produce all risk management plans prepared by or for the motor carrier.

61. Produce all videos used for training of the driver or any other drivers employed by or on behalf of the motor carrier.

62. Produce any audits or reviews performed by the motor carrier or by any other person or entity of any driver's daily or multi-daily log books, expenses and/or bills of lading for the driver.

63. Produce the sudden deceleration report for the tractor and trailer operated by the driver on the date of the collision.

64. Produce all information obtained from the electronic control module for the tractor and trailer operated by the driver on the date of the collision.

65. Produce all exit reports of audits performed by the Federal Motor Carrier Safety Administration or any other state or federal agencies for the motor carrier.

66. Produce all fuel and/or fleet card receipts for fuel obtained by the driver for the period beginning six months prior to the collision and ending one week after the collision, while operating any tractors and/or trailers for either the motor carrier or any other person or entity.

67. Produce all manuals, videos, or other similar documents used to train any of your drivers for the period beginning three years prior to the collision up through and including the date of the collision.

68. Produce the owner's operations and/or training manual for any radar collision warning system for the tractor trailer involved in the collision.

69. Produce any and all records generated and/or required to be kept for the tractor trailer operated by the driver during the collision.

70. Produce any and all reports of any inspections conducted for any and all vehicles owned, operated, or otherwise maintained by the motor carrier.

71. Produce any and all driver vehicle inspection reports prepared by the driver or any other employee of the motor carrier for either or both of the tractor and trailer operated by the driver on the date of the collision.

72. Produce any and all inspection, repair and maintenance records for either or both of the tractor and trailer operated by the driver on the date of the collision, which were kept and/or generated.

73. Produce any and all driver's pre-trip checklists completed by any employees or agents of the motor carrier or any other person or entities, for the tractor and or trailer operated by the driver during the collision, for the period beginning six months prior to the collision and ending one month after the collision.

74. Produce each and every document, tangible object or other item of real, demonstrative, or documentary evidence which contains, or may contain, material information which is or may be relevant to any of the issues involved in this action.

75. Produce all photographs, drawings, maps, or sketches of the scene of the collision.

76. Produce each and every insurance agreement under which any person carrying on an insurance business may be liable to you to satisfy part or all of any judgment which may be entered in this action or to indemnify or reimburse you for any payments made to satisfy such judgment.

77. Produce all documents relating to any controversy as to whether or not coverage is afforded to you under any insurance agreements.

78. Produce all documents comprising a report made by any person, firm, association or other entity (including insurance adjusters) that has conducted any investigation to determine any of the facts pertaining to any of the issues in this action.

79. Produce all documents comprising a report made by any person you expect to call as an expert witness on the trial of the case.

80. Produce all documents relating to any facts or information relating to the subject matter of this action furnished to you by any expert you expect to call as an expert witness on the trial of this case.

81. Produce all documents, reports and/or data relating to any facts or information relating to the subject matter of this action furnished to you by any expert with whom you have consulted about any aspect of this case.

82. Produce all documents relating to any written or recorded statement of the driver or any other potential witnesses, concerning any fact relevant to the subject matter of this action.

83. Produce all documents relating to any lease agreement or contract of employment that governed the motor carrier's relationship with the driver as of the date of the collision.

84. Produce all documents contained in any driver qualification file mainained by the motor carrier with respect to the driver.

85. Produce all payroll records regarding the driver maintained by the motor carrier for a period beginning one year prior to the date of the collision and ending sixty days after the collision.

86. Produce all title certificates, bills of sale, certificates of registration, and other title documents regarding the subject tractor and/or trailer.

87. Produce all maintenance and repair records maintained by you for a period preceding and including the date of the collision with respect to the subject tractor and/or trailer, pursuant to Part 396 of the Federal Motor Carrier Safety Regulations.

88. Produce all repair orders and bills pertaining to the subject vehicle and the driver on the date of the collision, and within sixty days of the date of the collision.

89. Produce all vehicle inspection reports regarding the subject tractor and/or the subject trailer prepared on the date of the collision, and within sixty days of the date of the collision.

90. Produce all trip log sheets prepared by the driver on the date of the collision and during the sixty days preceding the collision.

91. Produce all trip reports prepared by the driver on the date of the collision and during the sixty days preceding the collision.

92. Produce all fuel receipts pertaining to both the subject vehicle and the driver on the date of the collision and during the sixty days preceding the collision.

93. Produce all check-point and weight station records pertaining to both the subject vehicle and the driver on the date of the collision and during the sixty days preceding the date of the collision.

94. Produce all bills of lading pertaining to both the subject vehicle and the driver on the date of the collision and during the sixty days preceding the date of the collision.

95. Produce all licenses, permits, or certificates of convenience issued to you by any federal or state regulatory agency which authorizes the motor carrier to engage in the business of carrying cargo, freight or other property for hire.

96. Produce all documents relating to any accident report prepared and filed by you at the direction of the Regional Motor Carrier Safety Office of the Federal Highway Administration pursuant to Part 394 of the Federal Motor Carrier Safety Regulations or with any state agency as a result of the collision.

97. Produce all documents relating to any damage estimates or appraisals made of the subject tractor and/or the subject trailer.

98. Produce all documents which in any way reflect costs or expenses which you have incurred due to the unavailability of the subject vehicle as a result of the collision.

99. Produce all dispatch or operational records for both the subject vehicle and the driver on the date of the collision and during the sixty days preceding the date of the collision.

100. Produce any and all company manuals or other written materials addressing the motor carrier's standards and procedures for driver selection, testing and/or management.

101. Produce a list of all employee drivers as of the date of the collision.

102. Produce the complete maintenance file, cover to cover, for the subject tractor and/or the subject trailer.

103. Produce any and all promotional, marketing and/or advertising brochures and/or materials of the motor carrier.

104. Produce all manuals, books, and/or other written training materials used for the motor carrier's drivers, including, but not limited to, instructional manuals, videos, and/or other tangible items.

105. Produce any and all documents used by the motor carrier in the recruiting, screening, selecting and/or interviewing of applicants for employment and/or in promoting driver trainees to regular driver status.

106. Produce any and all minutes of all company committees concerning safety, operations and/or driver management.

107. Produce any and all communications, correspondence, emails, documents and/or records sent to or retrieved from any federal, state or local government, person or entity in regard to the collision.

108. Produce any and all documents regarding the analysis and review of the collision.

109. Produce any and all documents received from or sent to safety consultants employed or retained by the motor carrier.

110. Produce all minutes and documents reflecting any activities of the motor carrier's accident review board for the period beginning five years prior to the collision and ending sixty days after the collision.

111. Produce a detailed budget for the motor carrier and each of its departments for the period beginning five years prior to the collision and ending sixty days after the collision.

112. Produce a copy of the driver's driver's license in effect on the date of the collision.

113. Produce all investigative reports or other reports of the driving record or habits of the driver.

114. Produce copies of all citations issued to the driver as a result of the driver's actions on the date of the collision.

115. Produce any operational records for the transport the driver was executing at the time of the collision.

116. Produce any safety manuals or other written materials the driver was given by the motor carrier regarding the safe operation of a tractor trailer and/or any other large vehicle.

117. Produce complete time records and billing records for each and every expert witnesses whom Defendant expects to call as an expert witness at the trial of this action.