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)

Special Interrogatories — 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 SPECIAL INTERROGATORIES
                                                TO DEFENDANTS — SET ONE
PACIFIC WESTERN LOGISTICS, INC.,
a California corporation; JOHN DOE;
and DOES 1 through 50,
                        Defendants.

PLAINTIFF’S SPECIAL INTERROGATORIES TO DEFENDANTS — SET ONE

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

PLAINTIFF hereby propounds the following Special Interrogatories upon Defendants pursuant to California Code of Civil Procedure § 2030.010 et seq. Responses are required within thirty (30) days of service pursuant to CCP § 2030.260. Each interrogatory must be answered separately and fully under oath.

DEFINITIONS: “INCIDENT” means the motor vehicle collision that occurred on or about November 4, 2023, on Milliken Avenue at the I-15 interchange in Ontario, California. “VEHICLE” means the semi-truck operated by John Doe on that date. “COMPANY” means Pacific Western Logistics, Inc. “YOU” and “YOUR” refer to the responding Defendant.

INTERROGATORY NO. 1

State the full legal name, date of birth, driver’s license number, and state of licensure of the person who operated the VEHICLE at the time of the INCIDENT.

INTERROGATORY NO. 2

State all CDL endorsements held by the driver of the VEHICLE at the time of the INCIDENT, including the class of license and all endorsements (e.g., HazMat, Tanker, Double/Triple).

INTERROGATORY NO. 3

Describe all training programs, courses, or certifications completed by the driver of the VEHICLE in connection with commercial motor vehicle operation in the five (5) years preceding the INCIDENT, including the name of each program, the date completed, and the name of the providing organization.

INTERROGATORY NO. 4

State whether the driver of the VEHICLE had been involved in any prior motor vehicle accidents, traffic citations, or moving violations in the five (5) years preceding the INCIDENT. If so, for each incident state the date, location, nature of the incident, and disposition.

INTERROGATORY NO. 5

State the date on which the driver of the VEHICLE was first employed or contracted by COMPANY to operate commercial motor vehicles, and the nature of the employment or contractor relationship at the time of the INCIDENT.

INTERROGATORY NO. 6

Describe all pre-employment background checks, driving record reviews, and screening procedures performed by COMPANY prior to permitting the driver of the VEHICLE to operate a commercial motor vehicle on COMPANY’s behalf.

INTERROGATORY NO. 7

State the specific route, origin, destination, and cargo load assigned to the driver of the VEHICLE on the day of the INCIDENT, and identify the dispatcher or supervisor who assigned the route.

INTERROGATORY NO. 8

State the scheduled departure time and actual departure time of the driver of the VEHICLE from the origin point of his November 4, 2023 route.

INTERROGATORY NO. 9

State the total number of hours the driver of the VEHICLE had been on duty, as defined by 49 C.F.R. § 395.2, in the twenty-four (24) hours immediately preceding the INCIDENT.

INTERROGATORY NO. 10

State the total number of hours the driver of the VEHICLE had driven, as defined by 49 C.F.R. § 395.2, in the twenty-four (24) hours immediately preceding the INCIDENT.

INTERROGATORY NO. 11

State the total number of hours the driver of the VEHICLE had driven in the seventy-two (72) hours immediately preceding the INCIDENT.

INTERROGATORY NO. 12

State the total number of hours the driver of the VEHICLE had been on duty in the seven (7) consecutive days immediately preceding the INCIDENT.

INTERROGATORY NO. 13

Identify all rest breaks and off-duty periods taken by the driver of the VEHICLE in the twenty-four (24) hours immediately preceding the INCIDENT, including the start time, end time, and location of each break.

INTERROGATORY NO. 14

State whether the hours-of-service records for the driver of the VEHICLE, for any period in the thirty (30) days preceding the INCIDENT, reflect any violation of 49 C.F.R. §§ 395.3 or 395.5 (maximum driving time for property-carrying or passenger-carrying drivers). If so, describe each violation.

INTERROGATORY NO. 15

Identify the make, model, serial number, and software version of the Electronic Logging Device (“ELD”) installed in the VEHICLE at the time of the INCIDENT, and identify the ELD vendor or service provider.

INTERROGATORY NO. 16

State whether the ELD installed in the VEHICLE recorded any malfunction, data gap, or compliance event in the thirty (30) days preceding or the seven (7) days following the INCIDENT. If so, describe each event.

INTERROGATORY NO. 17

State the Vehicle Identification Number (VIN), year, make, model, and gross vehicle weight rating of the VEHICLE.

INTERROGATORY NO. 18

Identify all maintenance and inspection records for the VEHICLE in the twelve (12) months preceding the INCIDENT, including the date of each inspection, the name of the person or company performing the inspection, and all deficiencies noted.

INTERROGATORY NO. 19

State whether the VEHICLE underwent any pre-trip inspection on November 4, 2023. If so, identify the person who performed the inspection, the time of the inspection, and all deficiencies noted.

INTERROGATORY NO. 20

State whether any post-accident inspection of the VEHICLE was performed following the INCIDENT. If so, identify the person or company that performed the inspection, the date, and all findings.

INTERROGATORY NO. 21

Identify all traffic signals, warning signs, and intersection control devices present at the intersection of Milliken Avenue and the I-15 off-ramp in Ontario, California, as of November 4, 2023, to the extent known to any Defendant.

INTERROGATORY NO. 22

State whether the VEHICLE was equipped with any onboard telematics, GPS tracking, event data recorder (EDR), dashcam, or other electronic data recording system at the time of the INCIDENT. For each system, state the name of the system, the data it records, the data retention period, and whether the data for the period surrounding the INCIDENT has been preserved.

INTERROGATORY NO. 23

State the name, title, and contact information of the dispatcher or supervisor at COMPANY who had last contact with the driver of the VEHICLE prior to the INCIDENT.

INTERROGATORY NO. 24

State all communications (including phone calls, text messages, dispatch messages, and emails) between COMPANY and the driver of the VEHICLE in the four (4) hours preceding the INCIDENT, including the time, method, and content of each communication.

INTERROGATORY NO. 25

State whether COMPANY has ever conducted an audit or review of the driver of the VEHICLE’s hours-of-service compliance, driver safety record, or driving behavior. If so, describe the scope and findings of each audit.

INTERROGATORY NO. 26

State whether COMPANY received any complaints, reports, or concerns about the driver of the VEHICLE’s driving behavior, fatigue, or safety practices prior to the INCIDENT. If so, describe each complaint or report, its date, source, and the action taken.

INTERROGATORY NO. 27

Identify all safety training, fatigue-management programs, or hours-of-service compliance training provided by COMPANY to the driver of the VEHICLE in the two (2) years preceding the INCIDENT.

INTERROGATORY NO. 28

Identify all Federal Motor Carrier Safety Administration (FMCSA) audits, inspections, or compliance reviews of COMPANY conducted in the five (5) years preceding the INCIDENT, and state the findings and any corrective actions required.

INTERROGATORY NO. 29

State whether COMPANY has ever been cited, fined, or placed out of service by any federal or state regulatory agency in connection with hours-of-service violations, driver safety violations, or vehicle maintenance violations. If so, describe each citation, the date, the agency, and the disposition.

INTERROGATORY NO. 30

State all facts on which COMPANY relies to support any affirmative defense alleged in its Answer to the Complaint, including any contention of comparative fault, assumption of risk, or superseding cause.

Date: January 10, 2025

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

How this was made

Method

Drafted 35 candidate SROGs with Claude using the CHP traffic collision report, the FMCSA hours-of-service regulatory framework (49 C.F.R. Part 395), and the Reyes fact pattern; AI applied a FRCP-to-CCP translation layer; pruned to 30 final interrogatories by hand after reviewing strategic redundancy and proportionality under CCP § 2030.030.

Human judgment points

  • Decided to include Interrogatory 22 demanding the electronic logging device (ELD) provider's name and data format even though defendants objected to the RFP for ELD data — creating a parallel interrogatory record for the motion to compel
  • Chose to structure Interrogatory 14 to ask about hours driven in the 72-hour window (not just 24-hour) to capture the full FMCSA averaging period that regulators use, requiring substantive legal knowledge of 49 C.F.R. § 395.3
  • Omitted questions about Pacific Western's specific revenue from the at-risk contract route because counsel determined that financial discovery at this phase risked a premature punitive-damages objection that could slow down the liability core discovery

Time

~3 hours AI-augmented vs ~8 hours traditional SROG drafting