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)

Requests for Production — Set One

2025-01-10

[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.                                      PLAINTIFF'S REQUESTS FOR PRODUCTION
                                                OF DOCUMENTS — SET ONE
PACIFIC WESTERN LOGISTICS, INC.,
a California corporation; JOHN DOE;
and DOES 1 through 50,
                        Defendants.

PLAINTIFF’S REQUESTS FOR PRODUCTION OF DOCUMENTS — SET ONE

Propounding Party: Plaintiff MARIA REYES
Responding Party: Defendants PACIFIC WESTERN LOGISTICS, INC. and JOHN DOE
Set Number: One (1)

PLAINTIFF hereby requests that Defendants produce for inspection and copying all documents and things described herein pursuant to California Code of Civil Procedure §§ 2031.010 et seq. Documents shall be produced within thirty (30) days of service. Production is to be made at [FIRM ADDRESS — REDACTED], or electronically in PDF or native format as agreed by the parties.

DEFINITIONS:

  1. “DOCUMENT” means any writing as defined in California Evidence Code § 250, including electronically stored information (ESI) in any format.
  2. “INCIDENT” means the motor vehicle collision occurring on or about November 4, 2023, at Milliken Avenue and the I-15 interchange in Ontario, California.
  3. “VEHICLE” means the semi-truck operated by John Doe on the date of the INCIDENT.
  4. “COMPANY” means Pacific Western Logistics, Inc., its officers, employees, agents, and subsidiaries.
  5. “DRIVER” means the person operating the VEHICLE at the time of the INCIDENT.

REQUEST FOR PRODUCTION NO. 1

All documents evidencing or relating to the employment or contractor relationship between COMPANY and the DRIVER, including employment applications, contracts, offer letters, termination records, and any independent contractor agreements.

REQUEST FOR PRODUCTION NO. 2

All documents reflecting or constituting the DRIVER’s commercial driver’s license (CDL), endorsements, medical examiner’s certificates (DOT physical), and any CDL compliance records maintained by COMPANY.

REQUEST FOR PRODUCTION NO. 3

All documents reflecting the DRIVER’s driving history, accident record, moving violation record, or safety rating maintained by COMPANY or obtained from any state DMV or FMCSA database during the five (5) years preceding the INCIDENT.

REQUEST FOR PRODUCTION NO. 4

All daily driver logs, hours-of-service records, and duty status records (paper or electronic) for the DRIVER for the thirty (30) days preceding and including the date of the INCIDENT.

REQUEST FOR PRODUCTION NO. 5

All Electronic Logging Device (ELD) data, raw files, and data exports for the VEHICLE for the thirty (30) days preceding and including the date of the INCIDENT, in both native format (including all metadata) and human-readable format.

REQUEST FOR PRODUCTION NO. 6

All event data recorder (EDR), engine control module (ECM), or “black box” data for the VEHICLE for the period from forty-eight (48) hours before the INCIDENT through forty-eight (48) hours after the INCIDENT, including speed, braking, acceleration, and fault code records.

REQUEST FOR PRODUCTION NO. 7

All GPS tracking data, telematics data, or fleet management system records for the VEHICLE for the seventy-two (72) hours preceding the INCIDENT.

REQUEST FOR PRODUCTION NO. 8

All dispatch records, trip sheets, manifests, load sheets, bills of lading, and delivery orders associated with the DRIVER’s assignment on November 4, 2023.

REQUEST FOR PRODUCTION NO. 9

All communications (including emails, text messages, dispatch system messages, Qualcomm or similar communications) between COMPANY and the DRIVER on November 3 and November 4, 2023.

REQUEST FOR PRODUCTION NO. 10

All vehicle maintenance records, inspection logs, and repair orders for the VEHICLE for the twelve (12) months preceding the INCIDENT, including all pre-trip and post-trip inspection reports.

REQUEST FOR PRODUCTION NO. 11

All records of any Federal Motor Carrier Safety Administration (FMCSA) compliance reviews, roadside inspections, out-of-service orders, or violations assessed against COMPANY or against the VEHICLE in the five (5) years preceding the INCIDENT.

REQUEST FOR PRODUCTION NO. 12

All COMPANY safety manuals, driver handbooks, policies, and procedures relating to hours-of-service compliance, fatigue management, and driver training in effect as of November 4, 2023.

REQUEST FOR PRODUCTION NO. 13

All documents relating to training provided to the DRIVER on hours-of-service regulations, fatigue awareness, defensive driving, or any other safety topic during the two (2) years preceding the INCIDENT.

REQUEST FOR PRODUCTION NO. 14

All accident reports, incident reports, near-miss reports, or safety incident records relating to the DRIVER during the five (5) years preceding the INCIDENT.

REQUEST FOR PRODUCTION NO. 15

All internal COMPANY investigations, root-cause analyses, or post-accident reviews conducted in connection with the INCIDENT, including any written findings, conclusions, or recommendations.

REQUEST FOR PRODUCTION NO. 16

All photographs, videos, dashcam footage, traffic camera footage, surveillance footage, or any other visual recording of the INCIDENT or of the scene of the INCIDENT, including any footage downloaded from the VEHICLE.

REQUEST FOR PRODUCTION NO. 17

All photographs of the VEHICLE taken on or after November 4, 2023, including post-accident photographs.

REQUEST FOR PRODUCTION NO. 18

All records of cellular telephone calls, text messages, and data transmissions made or received by the DRIVER on any cellular telephone (personal or company-issued) on November 4, 2023.

REQUEST FOR PRODUCTION NO. 19

All insurance policies in force on November 4, 2023, under which COMPANY or the DRIVER was insured or might be insured for the claims asserted in this lawsuit, including any umbrella, excess, or MCS-90 endorsement.

REQUEST FOR PRODUCTION NO. 20

All reservation-of-rights letters, coverage opinion letters, or coverage correspondence between COMPANY and any insurer relating to this lawsuit.

REQUEST FOR PRODUCTION NO. 21

All documents relating to any prior motor vehicle accident, insurance claim, or property damage claim involving the VEHICLE in the three (3) years preceding the INCIDENT.

REQUEST FOR PRODUCTION NO. 22

All indemnification agreements, hold-harmless agreements, or any other agreements between COMPANY and the DRIVER relating to liability arising from the DRIVER’s operation of COMPANY vehicles.

Date: January 10, 2025

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

How this was made

Method

Generated 25 candidate RFP demands with Claude using the SROG set as a factual backbone, targeting categories of documentary evidence likely held by Pacific Western Logistics as a FMCSA-regulated carrier; paralegal pruned overlapping demands and added specific data format requirements for ELD data.

Human judgment points

  • Added a specific demand for the driver's Cell Phone Records (RFP No. 18) after reviewing the CHP report note that no phone was observed — decided the absence of an observation doesn't preclude production of carrier records, particularly if Pacific Western issued a company phone
  • Determined RFP No. 22 (indemnification agreements between Pacific Western and Doe) was strategically important for trial preparation even though defendants would likely object on relevance — preserved for potential motion practice
  • Calibrated the time window for safety records to five years (RFP Nos. 10, 11) rather than three to capture the maximum period covered by FMCSA carrier safety data, which requires knowing the regulatory retention requirements

Time

~2 hours AI-augmented vs ~5 hours traditional RFP drafting