Fictional matter — created for portfolio demonstration. No real parties, courts, or facts.
[ATTORNEY NAME — STATE BAR NO. ######]
[FIRM NAME]
[ADDRESS LINE 1]
[CITY, STATE ZIP]
[PHONE | EMAIL]
Attorneys for Plaintiff MARIA REYES
PRIVILEGED AND CONFIDENTIAL — ATTORNEY-CLIENT COMMUNICATION / WORK PRODUCT
CASE STATUS AND AUDIT REPORT
Case: Reyes v. Pacific Western Logistics, Inc., et al.
Court: San Bernardino County Superior Court
Case No.: CIVDS2401847 (FICTIONAL)
Report Date: April 15, 2026
Prepared By: [PARALEGAL NAME]
Supervising Attorney: [ATTORNEY NAME — STATE BAR NO. ######]
I. EXECUTIVE SUMMARY
This report provides a current status audit of all pleadings, discovery, pending motions, and upcoming deadlines in Reyes v. Pacific Western Logistics, Inc., et al. The matter arises from a November 4, 2023 semi-truck collision on Milliken Avenue, Ontario, California, resulting in C5-C6 and L4-L5 disc herniations to Plaintiff Maria Reyes. As of the report date, the case is in active written discovery with a motion to compel pending and a trial-setting conference scheduled for May 2026.
Overall case health: YELLOW — Two discovery deficiencies unresolved; motion to compel pending hearing.
II. PARTIES AND COUNSEL
| Party | Counsel | Contact |
|---|
| Plaintiff Maria Reyes | [FIRM NAME] / [ATTORNEY NAME — BAR NO. ######] | [CONTACT — REDACTED] |
| Pacific Western Logistics, Inc. | [DEFENSE FIRM — REDACTED] / [DEFENSE ATTORNEY — BAR NO. ######] | [CONTACT — REDACTED] |
| John Doe (Driver) | Same defense counsel (jointly represented) | [CONTACT — REDACTED] |
III. PLEADINGS STATUS
| Document | Filed | Status |
|---|
| Complaint (Negligence, Neg. Entrustment, Vicarious Liability) | 2024-07-15 | Filed; summons issued |
| Summons — Pacific Western Logistics, Inc. | 2024-07-16 | Issued |
| Proof of Service — Pacific Western Logistics, Inc. | 2024-09-03 | Filed — served 2024-08-28 |
| Proof of Service — John Doe | 2024-09-03 | Filed — served 2024-08-30 |
| Answer — Pacific Western Logistics, Inc. | 2024-09-03 | Filed; general denial + affirmative defenses (comparative fault) |
| Answer — John Doe | 2024-09-03 | Filed; same counsel; same defenses |
| Statement of Damages (CCP § 425.11) | 2024-08-01 | Served on defendants prior to complaint; copy in file |
Pleadings status: COMPLETE — no pending pleadings motions
IV. DISCOVERY STATUS
A. Plaintiff’s Written Discovery to Defendants
| Discovery | Served | Responses Due | Responses Received | Status |
|---|
| Form Interrogatories, Set One (DISC-001) | 2025-01-10 | 2025-02-11 | 2025-02-11 | Complete |
| Special Interrogatories, Set One (30 Qs) | 2025-01-10 | 2025-02-11 | 2025-02-11 | Deficient — Qs 14, 22 |
| Requests for Production, Set One (22 demands) | 2025-01-10 | 2025-02-11 | 2025-02-11 | Pending — MTC filed |
B. Meet-and-Confer Log
| Date | Method | Topic | Result |
|---|
| 2025-03-04 | Letter | SROG Qs 14, 22 — driver hours-of-service logs | Defendants agreed to supplement by 2025-03-21 |
| 2025-03-25 | Letter | SROG supplemental responses received — still deficient | Defendants disputed deficiency |
| 2025-04-02 | Phone call | RFP Set One — ELD data, maintenance records | No resolution; motion to compel authorized |
| 2026-01-15 | Letter | Final meet-and-confer — SROG Qs 14, 22 | No resolution; motion to compel pending |
C. Depositions
| Deponent | Deposition Date | Status | Notes |
|---|
| John Doe (Driver) | 2025-06-18 | Completed | HOS log produced showing 14-hr prior day; transcript ordered |
| [DEFENSE EXPERT — ACCIDENT RECON] | TBD | Not yet noticed | Defense indicated expert designation pending |
| [PLAINTIFF’S MEDICAL EXPERT] | TBD | Not yet noticed | Awaiting expert designation cutoff |
| Maria Reyes (Plaintiff) | TBD | Not yet taken | Defense has not yet noticed |
D. Defendants’ Written Discovery to Plaintiff
| Discovery | Served | Responses Due | Status |
|---|
| Form Interrogatories to Plaintiff | 2025-02-20 | 2025-03-22 | Complete |
| Special Interrogatories to Plaintiff (18 Qs) | 2025-02-20 | 2025-03-22 | Complete |
| Requests for Production to Plaintiff | 2025-02-20 | 2025-03-22 | Complete — 400+ pages produced |
V. PENDING MOTIONS
Motion to Compel Further Responses — SROG Set One (Qs 14, 22)
- Filed: 2026-02-10
- Opposition deadline: 2026-04-25
- Reply deadline: 2026-05-02
- Hearing date: 2026-05-15, 8:30 a.m., Dept. [##]
- Relief sought: Order compelling further responses; monetary sanctions of $1,950 under CCP § 2023.030
- Status: PENDING
VI. UPCOMING DEADLINES (60-DAY WINDOW)
| Deadline | Date | Item | Priority |
|---|
| Opposition to MTC | 2026-04-25 | Defendants’ opposition due | HIGH — calendar monitored |
| Reply ISO MTC | 2026-05-02 | Plaintiff’s reply ISO motion | HIGH |
| MTC Hearing | 2026-05-15 | Hearing — Dept. [##] | HIGH |
| Trial-Setting Conference | May 2026 (TBD) | Court to assign trial date | HIGH |
| Expert Designation (est.) | TBD — per trial order | Plaintiff’s expert disclosures | MEDIUM |
| Plaintiff’s Deposition | TBD | Defense has not noticed | MEDIUM |
VII. OPEN ITEMS AND ACTION LIST
| Item | Assigned To | Priority | Target Date |
|---|
| File reply ISO motion to compel SROG | [ATTORNEY NAME] | HIGH | 2026-05-02 |
| Attend MTC hearing; request sanctions | [ATTORNEY NAME] | HIGH | 2026-05-15 |
| Prepare for trial-setting conference; draft proposed dates | [PARALEGAL NAME] | HIGH | Prior to TSC |
| Send supplemental RFP meet-and-confer letter re: ELD data | [PARALEGAL NAME] | HIGH | 2026-04-20 |
| Notice plaintiff’s deposition of defense expert (post-designation) | [PARALEGAL NAME] | MEDIUM | Post-designation |
| Draft plaintiff’s expert designation letter | [ATTORNEY NAME] | MEDIUM | Per court order |
| Obtain updated medical records and billing summary | [PARALEGAL NAME] | MEDIUM | 2026-04-30 |
| Update litigation budget and damages estimate | [PARALEGAL NAME] | MEDIUM | 2026-04-30 |
VIII. DAMAGES SUMMARY (CURRENT)
| Category | Amount (Estimated) |
|---|
| Medical expenses incurred to date | ~$185,000 |
| Future medical (conservative — no surgery) | ~$45,000 |
| Future medical (surgery scenario) | ~$120,000 |
| Lost wages to date (~24 months) | ~$126,000 |
| Future lost earning capacity | TBD — expert opinion pending |
| General damages (pain and suffering) | TBD — trial value analysis pending |
| Total (conservative, no surgery) | ~$356,000+ |
Report prepared by: [PARALEGAL NAME]
Date: April 15, 2026
Next audit scheduled: Post-TSC