[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. LITIGATION TIMELINE — EXHIBIT A
PACIFIC WESTERN LOGISTICS, INC.,
a California corporation; JOHN DOE;
and DOES 1 through 50,
Defendants.
LITIGATION TIMELINE — EXHIBIT A
Case: Reyes v. Pacific Western Logistics, Inc., et al.
Case No.: CIVDS2401847 (FICTIONAL)
Prepared: April 15, 2026
PHASE 1 — PRE-LITIGATION (November 2023 – June 2024)
| Date | Event | Source | Phase |
|---|---|---|---|
| 2023-11-04 | T-bone collision at Milliken Ave. / I-15 interchange, Ontario, CA; semi-truck operated by John Doe (Pacific Western Logistics) runs red light and strikes plaintiff’s vehicle broadside at highway approach speed | CHP Collision Report No. [######] (FICTIONAL) | Incident |
| 2023-11-04 | Plaintiff transported by ambulance to Arrowhead Regional Medical Center (“ARMC”) ED; admitted with acute cervical and lumbar pain; discharged same day with cervical collar | ARMC Records | Medical |
| 2023-11-04 | Bystanders at scene provide statements to CHP indicating truck did not slow before impact (unverified — to be confirmed through investigation) | CHP Report | Liability |
| 2023-11-07 | Plaintiff placed on unpaid medical leave by employer [FACILITY NAME — REDACTED] due to lifting restrictions | Employer Records | Damages |
| 2023-11-08 | Initial follow-up visit with primary care physician; referral for MRI studies | PCP Records | Medical |
| 2024-01-22 | MRI confirms C5-C6 and L4-L5 disc herniations; treating physician recommends aggressive physical therapy and re-evaluation for surgical candidacy | MRI Report | Medical |
| 2024-02-05 | Physical therapy program initiated — 3×/week | PT Records | Medical |
| 2024-06-18 | Client intake call with firm; potential FMCSA hours-of-service violation identified | Intake Memo | Pre-Lit |
| 2024-06-20 | Conflict check completed — no disqualifying conflict found | Conflict Check Memo | Pre-Lit |
| 2024-06-25 | Litigation hold / spoliation prevention letter sent to Pacific Western Logistics, Inc. | Firm Records | Pre-Lit |
PHASE 2 — PLEADINGS (July 2024 – September 2024)
| Date | Event | Source | Phase |
|---|---|---|---|
| 2024-07-15 | Complaint filed in San Bernardino County Superior Court — Case No. CIVDS2401847 (FICTIONAL). Causes of action: (1) Negligence; (2) Negligent Entrustment; (3) Vicarious Liability | Court Docket | Pleadings |
| 2024-07-16 | Summons issued | Court Docket | Pleadings |
| 2024-08-01 | Statement of Damages (CCP § 425.11) served on defendants | Proof of Service | Pleadings |
| 2024-08-28 | Pacific Western Logistics, Inc. served with summons and complaint | Proof of Service | Pleadings |
| 2024-08-30 | John Doe served with summons and complaint | Proof of Service | Pleadings |
| 2024-09-03 | Pacific Western Logistics, Inc. and John Doe file Answers; general denial; affirmative defense of comparative fault asserted | Court Docket | Pleadings |
PHASE 3 — WRITTEN DISCOVERY (January 2025 – Present)
| Date | Event | Source | Phase |
|---|---|---|---|
| 2025-01-10 | Plaintiff serves Form Interrogatories Set One (DISC-001), Special Interrogatories Set One (30 interrogatories), and Requests for Production Set One (22 demands) on all defendants | Discovery | Discovery |
| 2025-02-11 | Defendants serve responses to all three sets of written discovery | Discovery | Discovery |
| 2025-02-20 | Defendants serve Form Interrogatories, Special Interrogatories, and RFPs on Plaintiff | Discovery | Discovery |
| 2025-03-04 | Plaintiff sends meet-and-confer letter re: deficient responses to SROG Nos. 14 and 22 (driver hours-of-service) | M&C Letter | Discovery |
| 2025-03-21 | Defendants serve supplemental SROG responses — paralegal review determines Qs 14 and 22 remain deficient | Supplemental | Discovery |
| 2025-03-22 | Plaintiff’s responses to defendants’ written discovery served | Discovery | Discovery |
| 2025-03-25 | Plaintiff sends second meet-and-confer letter disputing supplemental SROG adequacy | M&C Letter | Discovery |
| 2025-04-02 | Telephonic meet-and-confer re: RFP ELD data and maintenance records — no resolution | M&C Log | Discovery |
| 2025-06-18 | Deposition of John Doe (driver) taken; hours-of-service log produced at deposition showing 14-hour prior day — KEY LIABILITY FACT | Deposition Transcript | Discovery |
| 2025-07-01 | Deposition transcript received; ordered for indexing | Transcript | Discovery |
PHASE 4 — MOTION PRACTICE (January 2026 – Present)
| Date | Event | Source | Phase |
|---|---|---|---|
| 2026-01-15 | Plaintiff sends final meet-and-confer letter — SROG Nos. 14 and 22 — no resolution | M&C Letter | Motions |
| 2026-02-10 | Motion to Compel Further Responses to Special Interrogatories Set One filed; sanctions of $1,950 requested under CCP § 2023.030 | Court Docket | Motions |
| 2026-04-25 | Defendants’ opposition to Motion to Compel due | Calendar | Motions |
| 2026-05-02 | Plaintiff’s reply ISO Motion to Compel due | Calendar | Motions |
| 2026-05-15 | Hearing on Motion to Compel — Dept. [##], 8:30 a.m. | Calendar | Motions |
PHASE 5 — UPCOMING (May 2026 – 2027)
| Date | Event | Notes |
|---|---|---|
| May 2026 (TBD) | Trial-setting conference | Court to assign trial date |
| 2026 (TBD) | Expert designation cutoffs | Plaintiff: accident reconstruction; biomechanics; medical |
| 2026–2027 (TBD) | Defense medical examination (CCP § 2032) | Not yet noticed |
| Q1 2027 (anticipated) | Trial | Per TSC estimate |
Exhibit prepared by: [PARALEGAL NAME]
Supervising Attorney: [ATTORNEY NAME — STATE BAR NO. ######]
Date: April 15, 2026