Fictional matter — created for portfolio demonstration. No real parties, courts, or facts.
discovery request plaintiff

San Bernardino County Superior Court

Reyes v. Pacific Western Logistics, Inc., et al. · No. CIVDS2401847 (FICTIONAL)

Notice of Deposition — Driver Doe

2025-04-15

[ATTORNEY NAME — STATE BAR NO. ######]
[FIRM NAME]
[ADDRESS LINE 1]
[CITY, STATE ZIP]
[PHONE | EMAIL]
Attorneys for Plaintiff MARIA REYES

SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO

MARIA REYES,                                    Case No. CIVDS2401847 (FICTIONAL)
                        Plaintiff,
        v.                                      NOTICE OF TAKING ORAL DEPOSITION
                                                OF DEFENDANT JOHN DOE; DEMAND
PACIFIC WESTERN LOGISTICS, INC.,               FOR PRODUCTION OF DOCUMENTS
a California corporation; JOHN DOE;            (CCP §§ 2025.010, 2025.220, 2025.480)
and DOES 1 through 50,
                        Defendants.

NOTICE OF TAKING ORAL DEPOSITION OF DEFENDANT JOHN DOE; DEMAND FOR PRODUCTION OF DOCUMENTS AT DEPOSITION

TO ALL PARTIES AND THEIR COUNSEL OF RECORD:

PLEASE TAKE NOTICE that Plaintiff MARIA REYES, by and through her counsel of record, will take the oral deposition of Defendant JOHN DOE upon oral examination before a certified court reporter authorized to administer oaths in the State of California, pursuant to California Code of Civil Procedure § 2025.010 et seq., on the date and time and at the location set forth below.

DEPOSITION DETAILS

Deponent: JOHN DOE, Defendant
Date: June 18, 2025
Time: 9:00 a.m.
Location:
[COURT REPORTER’S OFFICE — REDACTED]
[ADDRESS — REDACTED]
[CITY, STATE ZIP]

The deposition will be recorded by stenographic means and may also be recorded by audio-visual means pursuant to CCP § 2025.330. If the deposition is recorded by audio-visual means, Plaintiff will provide additional notice as required.

The deposition is expected to last approximately one full day. Counsel should reserve the entire business day. If not completed on June 18, 2025, the deposition may continue on a mutually agreed date.

DEMAND FOR PRODUCTION OF DOCUMENTS

Pursuant to California Code of Civil Procedure § 2025.220(a)(4), Plaintiff demands that Deponent JOHN DOE produce for inspection and copying at the deposition the documents and things described in Exhibit A attached hereto. Documents shall be produced at the commencement of the deposition.

INSTRUCTIONS TO DEPONENT

  1. You are required to appear at the deposition personally. Failure to appear may subject you to sanctions pursuant to CCP § 2025.450.

  2. You must produce all documents demanded in Exhibit A that are within your possession, custody, or control as defined by CCP § 2031.010. Documents in the possession of your attorneys, agents, or representatives are within your control.

  3. If any document demanded in Exhibit A is withheld on grounds of privilege or work product protection, you must provide a privilege log identifying: (a) the date; (b) the author and all recipients; (c) the nature of the document; and (d) the specific privilege or protection claimed. A blanket objection is insufficient.

  4. If any document has been destroyed, lost, or is otherwise unavailable, you must so state and identify (a) what the document was; (b) when it was destroyed or lost; (c) by whom; and (d) the reason for the destruction or loss.

EXHIBIT A — DOCUMENTS TO BE PRODUCED AT DEPOSITION

JOHN DOE is requested to produce the following documents and things at the time and place of the deposition:

Category 1 — Personal Identification and Licensing

  1. Your current commercial driver’s license (CDL) and any medical examiner’s certificate (DOT medical card) issued to you.
  2. All CDL documents, endorsements, waivers, or renewals issued to you in the five (5) years preceding November 4, 2023.

Category 2 — Hours of Service and Driving Logs

  1. Your daily driver logs or electronic logging device (ELD) records for the period October 5, 2023 through November 4, 2023 (thirty days preceding the INCIDENT), in native file format compatible with the ELD device and in any human-readable summary format.
  2. Any personal calendars, notes, or written records reflecting your work schedule, hours worked, or rest periods during the sixty (60) days preceding the INCIDENT.

Category 3 — Communications

  1. All text messages, emails, or electronic communications sent or received by you in connection with your employment at Pacific Western Logistics, Inc. on November 3 and November 4, 2023.
  2. All records of cellular telephone calls made or received by you on any cellular telephone (personal or company-issued) on November 3 and November 4, 2023.

Category 4 — Training and Employment Records

  1. Any completion certificates, training records, or documentation of any safety training, hours-of-service training, or defensive driving course you received during your employment with Pacific Western Logistics, Inc.
  2. Any written warnings, counseling records, performance reviews, or disciplinary records related to your driving performance or safety compliance.

Category 5 — INCIDENT-Related Documents

  1. All documents, notes, photographs, or communications relating to the motor vehicle collision occurring on November 4, 2023, at Milliken Avenue and the I-15 interchange in Ontario, California.
  2. Any written statements you gave to Pacific Western Logistics, Inc., any insurance company, or any investigator in connection with the INCIDENT.
  3. Any records of medical treatment you received following the INCIDENT.

Date: April 15, 2025

[ATTORNEY NAME — STATE BAR NO. ######]
[FIRM NAME]
Attorneys for Plaintiff MARIA REYES

PROOF OF SERVICE

I, [PARALEGAL NAME], declare: I am over the age of 18 years and not a party to this action. My business address is [FIRM ADDRESS — REDACTED]. On April 15, 2025, I served a copy of the foregoing NOTICE OF TAKING ORAL DEPOSITION OF DEFENDANT JOHN DOE; DEMAND FOR PRODUCTION OF DOCUMENTS on the following counsel:

[DEFENSE COUNSEL NAME AND ADDRESS — REDACTED]

[ ] By electronic mail at [EMAIL — REDACTED], pursuant to CCP § 1010.6(a)(6)
[ ] By U.S. mail, first-class postage prepaid
[ ] By overnight delivery

I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.

Executed on April 15, 2025, at [CITY, CA].

[PARALEGAL NAME]

How this was made

Method

Generated the notice shell and document category list with Claude using the CCP § 2025.220 checklist framework and the Reyes SROG/RFP sets as source material for the document production categories; attorney reviewed and added the specific telematics and ELD format demands not captured by a generic auto-accident deposition notice template.

Human judgment points

  • Elected to schedule the deposition for a date prior to the deadline for the motion to compel further SROG responses so that John Doe's deposition testimony could be used as additional grounds in the motion — required coordination of the litigation calendar, not just scheduling logistics
  • Added a specific instruction in Exhibit A for ELD data to be produced in native format rather than PDF printout, because a PDF cannot be imported into Hours-of-Service analysis software — technical requirement not in the AI draft
  • Chose to notice JOHN DOE individually even though he is jointly represented with Pacific Western Logistics, because creating a separate notice for the individual preserves the ability to seek sanctions against him personally under CCP § 2023.030 if he fails to appear

Time

~1 hour AI-augmented vs ~2.5 hours traditional notice drafting