[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 WITNESS LIST AND
                                                EXHIBIT LIST
PACIFIC WESTERN LOGISTICS, INC.,
a California corporation; JOHN DOE;
and DOES 1 through 50,
                        Defendants.

PLAINTIFF’S WITNESS LIST AND EXHIBIT LIST

Case: Reyes v. Pacific Western Logistics, Inc., et al.
Case No.: CIVDS2401847 (FICTIONAL)
Court: San Bernardino County Superior Court
Prepared: April 15, 2026

PART I — WITNESS LIST

A. PERCIPIENT WITNESSES

No.	Witness	Role / Anticipated Testimony
1	MARIA REYES (Plaintiff)	Plaintiff. Will testify regarding the circumstances of the collision, her injuries and medical treatment, her employment as an LVN and the impact of her injuries on her work and daily life, and the damages she has sustained.
2	JOHN DOE (Defendant Driver)	Defendant. Will be called adversely. Expected to testify regarding his route assignment, driving hours, knowledge of hours-of-service regulations, events leading up to and at the time of the collision, and his employment history with Pacific Western Logistics.
3	[CHP OFFICER — BADGE NO. — REDACTED]	CHP Officer who responded to the scene. Will testify regarding observations at the scene, interviews of witnesses, measurements, and the CHP collision report.
4	[CHP OFFICER — BADGE NO. — REDACTED]	Second responding officer. Will testify regarding scene documentation and traffic signal observations.
5	[DISPATCH SUPERVISOR — NAME SUBJECT TO PROTECTIVE ORDER]	Pacific Western Logistics dispatch coordinator. Will be called adversely. Will testify regarding the route assignment, driver instructions, communications with John Doe, and the company’s knowledge of Doe’s hours.
6	[HR REPRESENTATIVE — NAME SUBJECT TO PROTECTIVE ORDER]	Pacific Western Logistics HR. Will be called adversely. Will testify regarding pre-employment screening, driver file, training records, and safety compliance history.
7	[PLAINTIFF’S TREATING PHYSICIAN — NAME REDACTED]	Plaintiff’s primary treating orthopedic physician. Will testify regarding Plaintiff’s injuries, treatment course, prognosis, and medical bills.
8	[PHYSICAL THERAPIST — NAME REDACTED]	Plaintiff’s physical therapist. Will testify regarding treatment, functional limitations, and ongoing needs.
9	[ELD VENDOR REPRESENTATIVE — NAME REDACTED]	Representative of the ELD vendor whose device was installed on the VEHICLE. Will testify regarding data recorded, data retention, data export format, and the accuracy of the ELD records.
10	[PLAINTIFF’S EMPLOYER REPRESENTATIVE — NAME REDACTED]	Representative from Plaintiff’s employer. Will testify regarding Plaintiff’s employment status, work restrictions, and lost wages.

B. EXPERT WITNESSES (Anticipated — Subject to Designation Cutoff)

No.	Expert	Discipline	Anticipated Opinion
E-1	[ACCIDENT RECONSTRUCTION EXPERT — NAME TBD]	Accident Reconstruction / Traffic Engineering	Speed of VEHICLE, sight lines, signal phase, point of impact, and whether a reasonable driver exercising due care could have avoided the collision.
E-2	[TRUCKING SAFETY EXPERT — NAME TBD]	FMCSA / Commercial Vehicle Safety	Whether John Doe’s hours-of-service records reflect violations of 49 C.F.R. §§ 395.3, 395.5; whether Pacific Western Logistics’ safety policies and training met the applicable duty of care for commercial carriers.
E-3	[BIOMECHANICAL EXPERT — NAME TBD]	Biomechanics / Injury Causation	Whether the collision forces described in the accident reconstruction are consistent with the C5-C6 and L4-L5 disc herniations suffered by Plaintiff.
E-4	[VOCATIONAL REHABILITATION EXPERT — NAME TBD]	Vocational Rehabilitation	Plaintiff’s future earning capacity as an LVN given her physical limitations; economic damages from diminished career trajectory.
E-5	[LIFE CARE PLANNER — NAME TBD]	Life Care Planning	Future medical needs and associated costs, including both conservative and surgical treatment scenarios.

PART II — EXHIBIT LIST

Authenticity and Hearsay Stipulations

The parties are encouraged to stipulate to the authenticity and admissibility of routine business records pursuant to California Evidence Code § 1271. Plaintiff will provide defendants’ counsel with a proposed stipulation list in advance of trial.

Ex. No.	Description	Bates / Source	Objection Status
1	Arrowhead Regional Medical Center Emergency Department Records (11/4/2023)	ARMC-001 to ARMC-147	Business records
2	CHP Collision Report No. [######] (FICTIONAL) and all supplements	CHP-001 to CHP-042	Official records
3	Aerial and ground-level photographs of the intersection (Milliken Ave. / I-15)	PHOTO-001 to PHOTO-028
4	MRI Reports — Cervical (C5-C6) and Lumbar (L4-L5) — January 22, 2024	MRI-001 to MRI-018	Business records
5	Physical Therapy Records — [PT PROVIDER — REDACTED]	PT-001 to PT-214	Business records
6	Primary Care Physician Records (11/2023 – present)	PCP-001 to PCP-088	Business records
7	Medical Billing Statements — all providers	BILL-001 to BILL-063	Business records
8	Plaintiff’s Employment Records — [FACILITY NAME — REDACTED]	EMPL-001 to EMPL-044	Business records
9	Plaintiff’s Wage and Compensation Records	WAGE-001 to WAGE-022	Business records
10	Deposition Transcript of John Doe (6/18/2025) — relevant excerpts	DEP-DOE-001 to DEP-DOE-412	Deposition transcript
11	Hours-of-Service Log produced by John Doe at deposition	ELD-001 to ELD-031	Business records
12	ELD Data Export — VEHICLE (to be supplemented pending MTC ruling)	ELD-NATIVE	TBD — MTC pending
13	GPS / Telematics Records — VEHICLE (to be supplemented)	TELEM-001	TBD — MTC pending
14	Pre-Trip Inspection Report — November 4, 2023 (produced by defendants)	DEF-PROD-001	Business records
15	Vehicle Maintenance Records — VEHICLE (12 months pre-incident)	DEF-PROD-002 to DEF-PROD-087	Business records
16	John Doe’s CDL and DOT Medical Certificate (produced by defendants)	DEF-PROD-088 to DEF-PROD-091	Official records
17	Defendant’s Driver Safety Manual — in effect November 4, 2023	DEF-PROD-092 to DEF-PROD-117	Business records
18	Litigation Hold Letter — Plaintiff to Pacific Western Logistics (6/25/2024)	FIRM-RECORDS-001
19	Plaintiff’s photographs of vehicle damage	PLPHOTO-001 to PLPHOTO-019
20	Day-in-the-Life Video (to be produced by vocational expert, if applicable)	TBD	TBD
21	Life Care Plan Report — [EXPERT NAME TBD]	TBD — expert designation pending	TBD
22	Vocational Rehabilitation Report — [EXPERT NAME TBD]	TBD — expert designation pending	TBD
23	Accident Reconstruction Report and Demonstrative Exhibits — [EXPERT NAME TBD]	TBD	TBD
24	FMCSA Carrier Safety Data — Pacific Western Logistics (publicly available data)	FMCSA-001 to FMCSA-012	Public records

Plaintiff reserves the right to supplement this exhibit list as discovery proceeds and additional documents are produced.

Prepared by: [PARALEGAL NAME]
Supervising Attorney: [ATTORNEY NAME — STATE BAR NO. ######]
Date: April 15, 2026