Preview
Filing # 46926897 E-Filed 09/26/2016 04:13:34 PM
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY, FLORIDA
CIVIL ACTION
WILLIAM H. SCHMITZ and JANICE K. SCHMITZ,
as Husband and Wife,
Plaintiffs,
v. CASE NO.: 16001754CA
ALEXMAR PIMIENTA GARRIDO,
JLL LOGISTIC INC and ROBERTO LI,
Defendants.
/
PLAINTIFFS’ FIRST REQUEST FOR PRODUCTION TO DEFENDANTS
COME NOW the Plaintiffs, WILLIAM H. SCHMITZ and JANICE K. SCHMITZ, by and
through their undersigned attorneys, hereby serve this First Request for Production to the
Defendants, ALEXMAR PIMIENTA GARRIDO, JLL LOGISTIC INC and ROBERTO LI, pursuant
to Rule 1.350(b), Florida Rules of Civil Procedure. Defendants shall serve responses within
thirty (30) days after service of this Request by producing for review and/or copying at the
offices of Plaintiffs’ attorneys, GOLDBERG, RACILA, D'‘ALESSANDRO & NOONE, LLC, 1533
Hendry Street, Suite 200, Fort Myers, FL 33901, all documents and things described on the
attached list.
If the Defendants claim any privilege or the right to protection of any requested materials
as trial preparation materials, the defendants shall make the claim expressly with respect to
each document or thing which the defendant claims to be privileged or protected and, without
revealing the information which is claimed to be privileged or protected, shall describe the
nature of the document, communications, writings or things not produced or objected to on the
grounds of such privilege.
CERTIFICATE OF SERVICE
| HEREBY CERTIFY that a true and correct copy of the above and foregoing has been
furnished by Electronic Mail to William Boltrek, Esquire, Henderson, Franklin, et al., Attorney for
Defendants, P.O. Box 280, Fort Myers, FL 33902-0280 at the designated email addresses of:
William.boltrek@henlaw.com; Brenda.sitar@henlaw.com on this Ww WS of September, 2016.
GOLDBERG, RACILA,
D'ALESSANDRO & NOONE, LLC
Attorneys for Plaintiffs
Post Office Box 190
Fort Myers, Florida 33902-0190
(239) 461-5508
(239) 461-3915 (Facsimile)
DO Michael M. Noone
Video
Florida ar No.: 0105139
Email: MikeNoone@goldberg-law.com
service@goldberg-law.com
Elizete D. Velado
Florida Bar No.: 0099668
Email: ElizeteVelado@goldberg-law.com
DEFINITIONS
DOCUMENT or DOCUMENTS mean any written or graphic matter or other means of
preserving thought or expression, and all tangible things from which information can
be processed or transcribed, including the originals and all non-identical copies,
whether different from the original by reason of any notation made on such copy or
otherwise, including, but not limited to, correspondence, memoranda, notes,
messages, letters, telegrams, teletype, telefax, bulletins, meetings or other
communications, interoffice and intra-office telephone calls, diaries, claim diaries,
chronological data, minutes, books, reports, studies, summaries, pamphlets, printed
matter, charts, ledgers, invoices, worksheets, receipts, returns, computer printouts,
prospectuses, financial statements, schedules, affidavits, contracts, canceled
checks, statements, transcripts, statistics, surveys, magazine or newspaper articles,
releases (any and all drafts, alterations and modifications, changes and amendments
of any of the foregoing), graphic or natural records or representations of any kind
(including without limitation photographs, microfiche, microfilm, videotape,
recordings, motion pictures), audio recordings, and electronic, computer, or
mechanical records or representations of any kind (including without limitation tapes,
cassettes, computer discs and records).
fl JLL LOGISTIC INC refers to defendant, JLL Logistic Inc, its agents, employees,
officers, directors, attorneys or other designated representatives.
Ml ALEXMAR PIMIENTA GARRIDO refers to defendant, Alexmar Pimienta Garrido.
Vv. ROBERO LI refers to defendant, Roberto Li.
CRASH refers to the motor vehicle collision involving William Schmitz and
Defendant, Alexmar Pimienta Garrido, that occurred on or about November 24, 2015
on US 17 at or near the intersection of Regent Road, Punta Gorda, Charlotte County,
Florida.
Vi TRACTOR refers to the 1999 commercial motor vehicle bearing VIN
AVG7DARJ9XN769587 owned by JLL Logistic Inc and Roberto Li.
VIL. TRAILER refers to any trailer that was attached to the TRACTOR at the time of the
CRASH.
PLAINTIFFS REQUEST FOR PRODUCTION OF DOCUMENTS
1 A copy of any fully-executed lease agreement for the TRACTOR or TRAILER
that was in effect at the time of the CRASH.
2 All other documents, whether maintained in paper or electronically, including
written communications or written memoranda of verbal communication, that reflect any
agreement, arrangement, contract, rental conveyance, lease or promise between JLL Logistic
inc and anyone, that was in effect on November 24, 2015, and that relates to the use of the
TRACTOR or TRAILER.
3 All documents, whether maintained in paper or electronically, related to the
relationship between JLL LOGISTIC INC, ROBERTO LI and/or ALEXMAR PIMIENTA
GARRIDO and the following entities:
4 A copy of the registration and title for the TRACTOR in effect at the time of the
CRASH, and any other documents, whether maintained in paper or electronically, that contains
information about the ownership of the TRACTOR.
5. A copy of all trailer exchange records for the TRACTOR for the months of
November 2015 and December 2015.
6 A copy of the registration and title for the TRAILER in effect at the time of the
CRASH, and any other documents, whether maintained in paper or electronically, that contains
information about the ownership of the TRAILER.
7. All documents, whether maintained in paper or electronically, that contain
information about the individuals or entities authorized to use the TRACTOR and/or TRAILER at
the time of the CRASH.
8. All contracts in effect at the time of the CRASH between JLL LOGISTIC INC,
ROBERTO LI and ALEXMAR PIMIENTA GARRIDO.
9 All documents, whether maintained in paper or electronically, pertaining to
compensation paid to ALEXMAR PIMIENTA GARRIDO for any and all trips during the period of
November 1, 2014 through present.
10. A copy of JLL LOGISTIC INC'S entire Driver Qualifications File for ALEXMAR
PIMIENTA GARRIDO, as is required to be maintained by JLL LOGISTIC INC under any federal
or state regulations.
11. All documents, whether maintained in paper or electronically, reflecting the
requisite qualifications and training requirements for drivers of semi-tractors employed by JLL
LOGISTIC INC from the years 2011 through present.
12. All other documents and information, whether maintained electronically or in a
physical file, relative to training, experience, safety-performance history, education, licensure,
pay level, job positions, responsibilities and duties associated with those job positions, any
complaints, commendations, or other documentation of performance evaluations or reviews or
similar assessments of responsibilities and performance of ALEXMAR PIMIENTA GARRIDO for
the years 2011 through present, or the end of his employment with JLL LOGISTIC INC.
Plaintiffs are not seeking the production of social security numbers, telephone numbers,
information relating to the employee’s family, or any protected health information. Please
include all documents, whether maintained in paper or electronically, evidencing the
qualifications of ALEXIMAR PIMIENTA GARRIDO to operate a commercial motor vehicle,
including but not limited to his:
application for employment;
list of previous employers and references and any records relating to the
verification of previous employment;
copies of any commercial licenses;
verifications of driving record through state agencies;
disciplinary information including reprimands;
list of driving violations;
medical examiner's certificates;
road test certificate;
certificate of completion of any written examinations;
records relating to all drug and alcohol testing for ALEXMAR PIMIENTA
GARRIDO, including any responses from state and federal agencies regarding
ALEXMAR PIMIENTA GARRIDO's drug and alcohol testing; and
k. accident register listing all DOT recordable preventable accidents.
13. A copy of the Drive-A-Check (DAC) report for ALEXMAR PIMIENTA GARRIDO.
14. A copy of the front and back of ALEXMAR PIMIENTA GARRIDO's standard
driver's license and any commercial driver's licenses.
15. A copy of ALEXMAR PIMIENTA GARRIDO’s driving record from any state in
which he has been domiciled since turning 16 years old.
16. Any documentation evidencing the attendance at, completion or non-completion
of training programs, safe-driving programs, and driver orientation programs by ALEXMAR
PIMIENTA GARRIDO, including materials presented or provided to ALEXMAR PIMIENTA
GARRIDO at those programs.
17. A copy of any employee handbook, safety handbook, rules, or policies and
procedures maintained by JLL LOGISTIC INC, whether maintained in paper or electronically,
that were in effect on November 24, 2015.
18. All documents, whether maintained in paper or electronically, that reference or
concern any policies, procedures, protocols, programs, plans, directives, guidelines or
suggestions relating to the investigation of motor vehicle accidents involving either JLL
LOGISTIC INC employees or vehicles owned or operated by JLL LOGISTIC INC and
ROBERTO LI, that were in effect on November 24, 2015,
19. All documents, whether maintained in paper or electronically, reflecting
procedures to be followed by JLL LOGISTIC employees or agents following any crash or injury.
20. All federal and state:
a. Safety audits of ALEXMAR PIMIENTA GARRIDO from 2011 through present.
b. Accident reports filed by ALEXMAR PIMIENTA GARRIDO, JLL LOGISTIC
INC or ROBERTO LI from 2011 through present.
C. Inspections of the TRACTOR or TRAILER from 2011 through present.
at. All long-form DOT physicals and records of health insurance claims, disability
claims, sickness or doctors’ excuses of YUNIOR VAZQUEZ LEYVA from 2011 through present.
22. The accident register maintained by JLL LOGISTIC INC as required by federal
and state regulations.
23. If ISO certified, please produce ail ISO Certification documents.
24. All vehicle use logs for the TRACTOR or TRAILER for the period of January 1,
2015 through January 1, 2016.
25. All digital and written logs/logbooks — official and unofficial - of ALEXMAR
PIMIENTA GARRIDO for the period of January 1, 2015 through January 31, 2016. (Please also
include the fegend/key If needed to understand the documents as presented).
26. All operator documents, whether maintained in paper or electronically, and all
pertaining to ALEXMAR PIMIENTA GARRIDO's driving schedule for the period of July 1, 2015
through December 31, 2015.
27. All records of duty status and all expense documentation for ALEXMAR
PIMIENTA GARRIDO for the seven days prior to the CRASH and for the day of the CRASH
including but not limited to:
Expense receipts;
Manifests and waypbills;
Bills of lading;
Carrier pros;
Freight bills;
Dispatch records;
Electronic mobile communication/tracking records;
Gate record receipts;
Weigh/scale tickets;
Fuel receipts;
Fuel billing statements;
Toll receipts;
Toll billing statements;
Port of entry receipts;
Delivery receipts;
Lumper receipts;
Interchange and inspection reports;
Lessor settlement sheets;
Over/short and damage reports;
Agricultural inspection report;
Driver and vehicle examination reports;
Crash reports;
Telephone billing statements;
Credit card receipts;
Border crossing reports;
Customs declarations;
aa. Traffic citations; and
bb. Overweight/oversize permits and citations.
28. All operational documents, whether maintained in paper or electronically,
pertaining to the trip that this TRACTOR and TRAILER were on at the time of the CRASH.
29. All documents, whether maintained in paper or electronically, including but not
limited to trip summaries, delivery manifests, invoices, bills of landing and waypbills, that contain
information about any loads picked up or delivered by anyone using the TRACTOR or TRAILER
and the routes traveled for the period of January 1, 2015 through January 31, 2016, including
the day of the CRASH.
30.
A copy of any billing and payment records for work being performed by the
TRACTOR or TRAILER on January 1, 2015 through January 31, 2016, including the day of the
CRASH.
31. All records evidencing cellular telephone calls made to or from the personal or
business cell phone of ALEXMAR PIMIENTA GARRIDO on November 24, 2015.
32. All satellite communications and Qualcomm e-mails for the day of the CRASH
and seven days prior, as well as all recorded ECM data with reference to all data available,
including, but not limited to:
Trip distance;
Total vehicle driving time;
Load factor;
Vehicle speed limit;
Maximum vehicle speed recorded:
Number of hard brake incidents;
Current engine speed (rpm);
Maximum and minimum cruise speed limits;
Total vehicle driving distance;
Fuel consumption (gal/hr.);
Idle time;
Engine governed speed;
Maximum engine speed recorded;
Current throttle position;
Brake switch status (on/off);
Odometer;
Trip driving time;
Overall fuel economy (MPG)
Average driving speed;
Number of engine overspeeds;
Number of vehicle overspeeds;
Current vehicle speed (MPH);
Clutch switch status (on/off);
Clock; and
GPS data.
33. All information obtained from the download of any on-board computer system
that was in use in the TRACTOR on November 24, 2015.
34. Any documents that contain information about inspections by JLL LOGISTIC INC
or anyone, of the TRACTOR or TRAILER which were made from November 24, 2015 to the
present.
35. All documents that contain tachometer records or mileage records or readings for
the TRACTOR from January 1, 2015 through January 31, 2016.
36. All records generated by any collision avoidance system, within the TRACTOR at
the time of the CRASH, that document any event or sequence of events from November 24,
2015, including but not limited to the CRASH itself including position reports and status updates
from the in-cab communication system in the TRACTOR that was utilized by ALEXMAR
PIMIENTA GARRIDO on November 24, 2015.
Any accident report, incident report or accident evaluation records prepared by
37.
JLL LOGISTIC INC as a result of the CRASH or containing any information relating to the
CRASH.
38. All documents, whether maintained in paper or electronically, containing a
determination regarding whether or not this CRASH was a “preventable accident.”
39. All documents, whether maintained in paper or electronically, which contain
information about any payment of any claim for damages arising out of the CRASH made on
JLL LOGISTIC INC or ALEXMAR PIMIENTA GARRIDO’s behalf.
40. All written communications or written memoranda of verbal communications
addressed to or from JLL LOGISTIC INC or any person acting on JLL LOGISTIC INC’s behalf
other than JLL LOGISTIC INC’s attorneys, concerning the CRASH.
41.All written communications or written memoranda of verbal communications
within JLL LOGISTIC INC’s possession or control, to or from ALEXMAR PIMIENTA GARRIDO,
or anyone purporting to act on ALEXMAR PIMIENTA GARRIDO’s behalf, relating to any
subject, from the date of the CRASH through present.
42. All photographs or images depicting:
a injuries suffered by any individual in connection with the CRASH;
b. the TRACTOR or TRAILER taken before, during or after the CRASH;
C. any other motor vehicles involved in the CRASH; and
d the scene of the CRASH.
43. All documents, whether maintained in paper or electronically, concerning
required maintenance on tractors and trailers, including but not limited to, preventive
maintenance checklists and schedules, scheduled maintenance checklists or calendars, policies
and procedures for repairing tractors and trailers, and policies and procedures for the ordering
of repair or replacement parts, for the period of January 1, 2015 through January 31, 2016.
44. Any and all repair records and bills, maintenance records, service records and
documents or papers of any type dealing with the maintenance, servicing, repairs, work, or
salvage of any type within JLL LOGISTIC INC’s possession or control for the TRACTOR or
TRAILER, including but not fimited to all driver trip reports, all driver vehicle inspection reports,
and all records, sheets, logs, notes or other written documentation concerning inspection or
maintenance performed on the TRACTOR or TRAILER, created between January 1, 2015
through January 31, 2016.
45. All documents, whether maintained in paper or electronically, pertaining to any
safety recall issued by the National Highway Traffic Safety Administration for the TRACTOR or
TRAILER, and any documents reflecting any repairs or actions taken as a result of said recall.
46. A copy of any estimate, bill and evidence of payment for the repair of damage
sustained by the TRACTOR or TRAILER as a result of the CRASH.
47. A list of all medications, including prescription and nonprescription drugs which
ALEXMAR PIMIENTA GARRIDO consumed in the 48 hours preceding the CRASH.
48. All documents, whether maintained in paper or electronically, that contain
information about the results of any drug or alcohol testing conducted upon anyone at JLL
LOGISTIC INC’s request following the CRASH, including but not limited to ALEXMAR
PIMIENTA GARRIDO.
49, All documents, whether maintained in paper or electronically, that contain
information pertaining to ALEXMAR PIMIENTA GARRIDO’s violation of any federal, state or
local law, regulation or ordinance relating to the CRASH.
50. All documents, whether maintained in paper or electronically, that contain
information pertaining to JLL LOGISTIC INC’s violation of any federal, state or local law,
regulation or ordinance relating to the CRASH.
51. All documents, whether maintained in paper or electronically, referred to,
consulted, or reviewed in preparation for answering Plaintiffs’ First interrogatories served
concurrently herewith.
52. Copies of any and ail documents which reflect the job description for the position
held by ALEXMAR PIMIENTA GARRIDO with JLL LOGISTIC INC, at the time of the CRASH,
including, but not limited to, qualification requirements for the position held by ALEXMAR
PIMIENTA GARRIDO with JLL LOGISTIC INC.
53. Produce for inspection the TRACTOR and TRAILER and any parts or systems
therefrom operated by JLL LOGISTIC INC, ROBERTO LI and/or ALEXMAR PIMIENTA
GARRIDO, on November 24, 2015.
54. Copies of any photos, still or motion picture, plans, maps, drawings, blueprints,
sketches, diagrams, computer simulations or any other demonstrative evidence relevant to the
CRASH, including without limitation, pictures of the vehicles involved in the CRASH and the
area of the CRASH.
55. Copy of all written records with respect to each past employer who was
contacted about ALEXMAR PIMIENTA GARRIDO's qualifications.
56. Copies of educational materials explaining drug and alcoho! testing regulations
submitted to JLL LOGISTIC INC’s drivers and all JLL LOGISTIC INC’s policies and procedures
relating to alcohol and drug testing.
57. All writings giving notification to JLL LOGISTIC INC of ALEXMAR PIMIENTA
GARRIDO's convictions or suspensions for violating a state or local law relating to motor vehicle
traffic control.
58. Any and all statements, whether written, transcribed, taped or otherwise
memorialized, obtained from or purportedly made by the Plaintiff or any other person or persons
which may have information regarding the CRASH.
59. Copy of all:
a Dispatch records for the TRACTOR.
b Mobile radio records related to the TRACTOR.
c Pro-rate records for the TRACTOR.
d. Wrecker or tow truck records for the TRACTOR.
e. Out of service orders for the TRACTOR.
60. Copy of all JLL LOGISTIC INC company manuals covering truck safety,
maintenance, fleet safety programs, and driver's standards and a copy of the accident review
procedures or rules adopted by JLL LOGISTIC INC to determine whether any collision is
chargeable or non-chargeable, preventable or non-preventable.
61. Copy of any and all claims or lawsuits (Complaints) made (or brought) against
JLL LOGISTIC INC arising out of the CRASH.
62. Copy of any and all claims or lawsuits (Complaints) made (or brought) against
ALEXMAR PIMIENTA GARRIDO arising out of the CRASH.
63. All claim forms and correspondence concerning the CRASH from the owner of
the property being transported at the time of the COLLISION.
64. Copies of all documents pertaining to any/all brokers involved in the load being
transported at the time of the CRASH.
65. Copies of any documents or writings which JLL LOGISTIC INC contends support
any contention that this CRASH was the fault of any other person or entity.
66. Copies of any documents or writings which ALEXMAR PIMIENTA GARRIDO
contends support any contention that this CRASH was the fault of any other person or entity.
Preview
Filing # 46926897 E-Filed 09/26/2016 04:13:34 PM IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIVIL ACTION WILLIAM H. SCHMITZ and JANICE K. SCHMITZ, as Husband and Wife, Plaintiffs, v. CASE NO.: 16001754CA ALEXMAR PIMIENTA GARRIDO, JLL LOGISTIC INC and ROBERTO LI, Defendants. / PLAINTIFFS’ FIRST REQUEST FOR PRODUCTION TO DEFENDANTS COME NOW the Plaintiffs, WILLIAM H. SCHMITZ and JANICE K. SCHMITZ, by and through their undersigned attorneys, hereby serve this First Request for Production to the Defendants, ALEXMAR PIMIENTA GARRIDO, JLL LOGISTIC INC and ROBERTO LI, pursuant to Rule 1.350(b), Florida Rules of Civil Procedure. Defendants shall serve responses within thirty (30) days after service of this Request by producing for review and/or copying at the offices of Plaintiffs’ attorneys, GOLDBERG, RACILA, D'‘ALESSANDRO & NOONE, LLC, 1533 Hendry Street, Suite 200, Fort Myers, FL 33901, all documents and things described on the attached list. If the Defendants claim any privilege or the right to protection of any requested materials as trial preparation materials, the defendants shall make the claim expressly with respect to each document or thing which the defendant claims to be privileged or protected and, without revealing the information which is claimed to be privileged or protected, shall describe the nature of the document, communications, writings or things not produced or objected to on the grounds of such privilege. CERTIFICATE OF SERVICE | HEREBY CERTIFY that a true and correct copy of the above and foregoing has been furnished by Electronic Mail to William Boltrek, Esquire, Henderson, Franklin, et al., Attorney for Defendants, P.O. Box 280, Fort Myers, FL 33902-0280 at the designated email addresses of: William.boltrek@henlaw.com; Brenda.sitar@henlaw.com on this Ww WS of September, 2016. GOLDBERG, RACILA, D'ALESSANDRO & NOONE, LLC Attorneys for Plaintiffs Post Office Box 190 Fort Myers, Florida 33902-0190 (239) 461-5508 (239) 461-3915 (Facsimile) DO Michael M. Noone Video Florida ar No.: 0105139 Email: MikeNoone@goldberg-law.com service@goldberg-law.com Elizete D. Velado Florida Bar No.: 0099668 Email: ElizeteVelado@goldberg-law.com DEFINITIONS DOCUMENT or DOCUMENTS mean any written or graphic matter or other means of preserving thought or expression, and all tangible things from which information can be processed or transcribed, including the originals and all non-identical copies, whether different from the original by reason of any notation made on such copy or otherwise, including, but not limited to, correspondence, memoranda, notes, messages, letters, telegrams, teletype, telefax, bulletins, meetings or other communications, interoffice and intra-office telephone calls, diaries, claim diaries, chronological data, minutes, books, reports, studies, summaries, pamphlets, printed matter, charts, ledgers, invoices, worksheets, receipts, returns, computer printouts, prospectuses, financial statements, schedules, affidavits, contracts, canceled checks, statements, transcripts, statistics, surveys, magazine or newspaper articles, releases (any and all drafts, alterations and modifications, changes and amendments of any of the foregoing), graphic or natural records or representations of any kind (including without limitation photographs, microfiche, microfilm, videotape, recordings, motion pictures), audio recordings, and electronic, computer, or mechanical records or representations of any kind (including without limitation tapes, cassettes, computer discs and records). fl JLL LOGISTIC INC refers to defendant, JLL Logistic Inc, its agents, employees, officers, directors, attorneys or other designated representatives. Ml ALEXMAR PIMIENTA GARRIDO refers to defendant, Alexmar Pimienta Garrido. Vv. ROBERO LI refers to defendant, Roberto Li. CRASH refers to the motor vehicle collision involving William Schmitz and Defendant, Alexmar Pimienta Garrido, that occurred on or about November 24, 2015 on US 17 at or near the intersection of Regent Road, Punta Gorda, Charlotte County, Florida. Vi TRACTOR refers to the 1999 commercial motor vehicle bearing VIN AVG7DARJ9XN769587 owned by JLL Logistic Inc and Roberto Li. VIL. TRAILER refers to any trailer that was attached to the TRACTOR at the time of the CRASH. PLAINTIFFS REQUEST FOR PRODUCTION OF DOCUMENTS 1 A copy of any fully-executed lease agreement for the TRACTOR or TRAILER that was in effect at the time of the CRASH. 2 All other documents, whether maintained in paper or electronically, including written communications or written memoranda of verbal communication, that reflect any agreement, arrangement, contract, rental conveyance, lease or promise between JLL Logistic inc and anyone, that was in effect on November 24, 2015, and that relates to the use of the TRACTOR or TRAILER. 3 All documents, whether maintained in paper or electronically, related to the relationship between JLL LOGISTIC INC, ROBERTO LI and/or ALEXMAR PIMIENTA GARRIDO and the following entities: 4 A copy of the registration and title for the TRACTOR in effect at the time of the CRASH, and any other documents, whether maintained in paper or electronically, that contains information about the ownership of the TRACTOR. 5. A copy of all trailer exchange records for the TRACTOR for the months of November 2015 and December 2015. 6 A copy of the registration and title for the TRAILER in effect at the time of the CRASH, and any other documents, whether maintained in paper or electronically, that contains information about the ownership of the TRAILER. 7. All documents, whether maintained in paper or electronically, that contain information about the individuals or entities authorized to use the TRACTOR and/or TRAILER at the time of the CRASH. 8. All contracts in effect at the time of the CRASH between JLL LOGISTIC INC, ROBERTO LI and ALEXMAR PIMIENTA GARRIDO. 9 All documents, whether maintained in paper or electronically, pertaining to compensation paid to ALEXMAR PIMIENTA GARRIDO for any and all trips during the period of November 1, 2014 through present. 10. A copy of JLL LOGISTIC INC'S entire Driver Qualifications File for ALEXMAR PIMIENTA GARRIDO, as is required to be maintained by JLL LOGISTIC INC under any federal or state regulations. 11. All documents, whether maintained in paper or electronically, reflecting the requisite qualifications and training requirements for drivers of semi-tractors employed by JLL LOGISTIC INC from the years 2011 through present. 12. All other documents and information, whether maintained electronically or in a physical file, relative to training, experience, safety-performance history, education, licensure, pay level, job positions, responsibilities and duties associated with those job positions, any complaints, commendations, or other documentation of performance evaluations or reviews or similar assessments of responsibilities and performance of ALEXMAR PIMIENTA GARRIDO for the years 2011 through present, or the end of his employment with JLL LOGISTIC INC. Plaintiffs are not seeking the production of social security numbers, telephone numbers, information relating to the employee’s family, or any protected health information. Please include all documents, whether maintained in paper or electronically, evidencing the qualifications of ALEXIMAR PIMIENTA GARRIDO to operate a commercial motor vehicle, including but not limited to his: application for employment; list of previous employers and references and any records relating to the verification of previous employment; copies of any commercial licenses; verifications of driving record through state agencies; disciplinary information including reprimands; list of driving violations; medical examiner's certificates; road test certificate; certificate of completion of any written examinations; records relating to all drug and alcohol testing for ALEXMAR PIMIENTA GARRIDO, including any responses from state and federal agencies regarding ALEXMAR PIMIENTA GARRIDO's drug and alcohol testing; and k. accident register listing all DOT recordable preventable accidents. 13. A copy of the Drive-A-Check (DAC) report for ALEXMAR PIMIENTA GARRIDO. 14. A copy of the front and back of ALEXMAR PIMIENTA GARRIDO's standard driver's license and any commercial driver's licenses. 15. A copy of ALEXMAR PIMIENTA GARRIDO’s driving record from any state in which he has been domiciled since turning 16 years old. 16. Any documentation evidencing the attendance at, completion or non-completion of training programs, safe-driving programs, and driver orientation programs by ALEXMAR PIMIENTA GARRIDO, including materials presented or provided to ALEXMAR PIMIENTA GARRIDO at those programs. 17. A copy of any employee handbook, safety handbook, rules, or policies and procedures maintained by JLL LOGISTIC INC, whether maintained in paper or electronically, that were in effect on November 24, 2015. 18. All documents, whether maintained in paper or electronically, that reference or concern any policies, procedures, protocols, programs, plans, directives, guidelines or suggestions relating to the investigation of motor vehicle accidents involving either JLL LOGISTIC INC employees or vehicles owned or operated by JLL LOGISTIC INC and ROBERTO LI, that were in effect on November 24, 2015, 19. All documents, whether maintained in paper or electronically, reflecting procedures to be followed by JLL LOGISTIC employees or agents following any crash or injury. 20. All federal and state: a. Safety audits of ALEXMAR PIMIENTA GARRIDO from 2011 through present. b. Accident reports filed by ALEXMAR PIMIENTA GARRIDO, JLL LOGISTIC INC or ROBERTO LI from 2011 through present. C. Inspections of the TRACTOR or TRAILER from 2011 through present. at. All long-form DOT physicals and records of health insurance claims, disability claims, sickness or doctors’ excuses of YUNIOR VAZQUEZ LEYVA from 2011 through present. 22. The accident register maintained by JLL LOGISTIC INC as required by federal and state regulations. 23. If ISO certified, please produce ail ISO Certification documents. 24. All vehicle use logs for the TRACTOR or TRAILER for the period of January 1, 2015 through January 1, 2016. 25. All digital and written logs/logbooks — official and unofficial - of ALEXMAR PIMIENTA GARRIDO for the period of January 1, 2015 through January 31, 2016. (Please also include the fegend/key If needed to understand the documents as presented). 26. All operator documents, whether maintained in paper or electronically, and all pertaining to ALEXMAR PIMIENTA GARRIDO's driving schedule for the period of July 1, 2015 through December 31, 2015. 27. All records of duty status and all expense documentation for ALEXMAR PIMIENTA GARRIDO for the seven days prior to the CRASH and for the day of the CRASH including but not limited to: Expense receipts; Manifests and waypbills; Bills of lading; Carrier pros; Freight bills; Dispatch records; Electronic mobile communication/tracking records; Gate record receipts; Weigh/scale tickets; Fuel receipts; Fuel billing statements; Toll receipts; Toll billing statements; Port of entry receipts; Delivery receipts; Lumper receipts; Interchange and inspection reports; Lessor settlement sheets; Over/short and damage reports; Agricultural inspection report; Driver and vehicle examination reports; Crash reports; Telephone billing statements; Credit card receipts; Border crossing reports; Customs declarations; aa. Traffic citations; and bb. Overweight/oversize permits and citations. 28. All operational documents, whether maintained in paper or electronically, pertaining to the trip that this TRACTOR and TRAILER were on at the time of the CRASH. 29. All documents, whether maintained in paper or electronically, including but not limited to trip summaries, delivery manifests, invoices, bills of landing and waypbills, that contain information about any loads picked up or delivered by anyone using the TRACTOR or TRAILER and the routes traveled for the period of January 1, 2015 through January 31, 2016, including the day of the CRASH. 30. A copy of any billing and payment records for work being performed by the TRACTOR or TRAILER on January 1, 2015 through January 31, 2016, including the day of the CRASH. 31. All records evidencing cellular telephone calls made to or from the personal or business cell phone of ALEXMAR PIMIENTA GARRIDO on November 24, 2015. 32. All satellite communications and Qualcomm e-mails for the day of the CRASH and seven days prior, as well as all recorded ECM data with reference to all data available, including, but not limited to: Trip distance; Total vehicle driving time; Load factor; Vehicle speed limit; Maximum vehicle speed recorded: Number of hard brake incidents; Current engine speed (rpm); Maximum and minimum cruise speed limits; Total vehicle driving distance; Fuel consumption (gal/hr.); Idle time; Engine governed speed; Maximum engine speed recorded; Current throttle position; Brake switch status (on/off); Odometer; Trip driving time; Overall fuel economy (MPG) Average driving speed; Number of engine overspeeds; Number of vehicle overspeeds; Current vehicle speed (MPH); Clutch switch status (on/off); Clock; and GPS data. 33. All information obtained from the download of any on-board computer system that was in use in the TRACTOR on November 24, 2015. 34. Any documents that contain information about inspections by JLL LOGISTIC INC or anyone, of the TRACTOR or TRAILER which were made from November 24, 2015 to the present. 35. All documents that contain tachometer records or mileage records or readings for the TRACTOR from January 1, 2015 through January 31, 2016. 36. All records generated by any collision avoidance system, within the TRACTOR at the time of the CRASH, that document any event or sequence of events from November 24, 2015, including but not limited to the CRASH itself including position reports and status updates from the in-cab communication system in the TRACTOR that was utilized by ALEXMAR PIMIENTA GARRIDO on November 24, 2015. Any accident report, incident report or accident evaluation records prepared by 37. JLL LOGISTIC INC as a result of the CRASH or containing any information relating to the CRASH. 38. All documents, whether maintained in paper or electronically, containing a determination regarding whether or not this CRASH was a “preventable accident.” 39. All documents, whether maintained in paper or electronically, which contain information about any payment of any claim for damages arising out of the CRASH made on JLL LOGISTIC INC or ALEXMAR PIMIENTA GARRIDO’s behalf. 40. All written communications or written memoranda of verbal communications addressed to or from JLL LOGISTIC INC or any person acting on JLL LOGISTIC INC’s behalf other than JLL LOGISTIC INC’s attorneys, concerning the CRASH. 41.All written communications or written memoranda of verbal communications within JLL LOGISTIC INC’s possession or control, to or from ALEXMAR PIMIENTA GARRIDO, or anyone purporting to act on ALEXMAR PIMIENTA GARRIDO’s behalf, relating to any subject, from the date of the CRASH through present. 42. All photographs or images depicting: a injuries suffered by any individual in connection with the CRASH; b. the TRACTOR or TRAILER taken before, during or after the CRASH; C. any other motor vehicles involved in the CRASH; and d the scene of the CRASH. 43. All documents, whether maintained in paper or electronically, concerning required maintenance on tractors and trailers, including but not limited to, preventive maintenance checklists and schedules, scheduled maintenance checklists or calendars, policies and procedures for repairing tractors and trailers, and policies and procedures for the ordering of repair or replacement parts, for the period of January 1, 2015 through January 31, 2016. 44. Any and all repair records and bills, maintenance records, service records and documents or papers of any type dealing with the maintenance, servicing, repairs, work, or salvage of any type within JLL LOGISTIC INC’s possession or control for the TRACTOR or TRAILER, including but not fimited to all driver trip reports, all driver vehicle inspection reports, and all records, sheets, logs, notes or other written documentation concerning inspection or maintenance performed on the TRACTOR or TRAILER, created between January 1, 2015 through January 31, 2016. 45. All documents, whether maintained in paper or electronically, pertaining to any safety recall issued by the National Highway Traffic Safety Administration for the TRACTOR or TRAILER, and any documents reflecting any repairs or actions taken as a result of said recall. 46. A copy of any estimate, bill and evidence of payment for the repair of damage sustained by the TRACTOR or TRAILER as a result of the CRASH. 47. A list of all medications, including prescription and nonprescription drugs which ALEXMAR PIMIENTA GARRIDO consumed in the 48 hours preceding the CRASH. 48. All documents, whether maintained in paper or electronically, that contain information about the results of any drug or alcohol testing conducted upon anyone at JLL LOGISTIC INC’s request following the CRASH, including but not limited to ALEXMAR PIMIENTA GARRIDO. 49, All documents, whether maintained in paper or electronically, that contain information pertaining to ALEXMAR PIMIENTA GARRIDO’s violation of any federal, state or local law, regulation or ordinance relating to the CRASH. 50. All documents, whether maintained in paper or electronically, that contain information pertaining to JLL LOGISTIC INC’s violation of any federal, state or local law, regulation or ordinance relating to the CRASH. 51. All documents, whether maintained in paper or electronically, referred to, consulted, or reviewed in preparation for answering Plaintiffs’ First interrogatories served concurrently herewith. 52. Copies of any and ail documents which reflect the job description for the position held by ALEXMAR PIMIENTA GARRIDO with JLL LOGISTIC INC, at the time of the CRASH, including, but not limited to, qualification requirements for the position held by ALEXMAR PIMIENTA GARRIDO with JLL LOGISTIC INC. 53. Produce for inspection the TRACTOR and TRAILER and any parts or systems therefrom operated by JLL LOGISTIC INC, ROBERTO LI and/or ALEXMAR PIMIENTA GARRIDO, on November 24, 2015. 54. Copies of any photos, still or motion picture, plans, maps, drawings, blueprints, sketches, diagrams, computer simulations or any other demonstrative evidence relevant to the CRASH, including without limitation, pictures of the vehicles involved in the CRASH and the area of the CRASH. 55. Copy of all written records with respect to each past employer who was contacted about ALEXMAR PIMIENTA GARRIDO's qualifications. 56. Copies of educational materials explaining drug and alcoho! testing regulations submitted to JLL LOGISTIC INC’s drivers and all JLL LOGISTIC INC’s policies and procedures relating to alcohol and drug testing. 57. All writings giving notification to JLL LOGISTIC INC of ALEXMAR PIMIENTA GARRIDO's convictions or suspensions for violating a state or local law relating to motor vehicle traffic control. 58. Any and all statements, whether written, transcribed, taped or otherwise memorialized, obtained from or purportedly made by the Plaintiff or any other person or persons which may have information regarding the CRASH. 59. Copy of all: a Dispatch records for the TRACTOR. b Mobile radio records related to the TRACTOR. c Pro-rate records for the TRACTOR. d. Wrecker or tow truck records for the TRACTOR. e. Out of service orders for the TRACTOR. 60. Copy of all JLL LOGISTIC INC company manuals covering truck safety, maintenance, fleet safety programs, and driver's standards and a copy of the accident review procedures or rules adopted by JLL LOGISTIC INC to determine whether any collision is chargeable or non-chargeable, preventable or non-preventable. 61. Copy of any and all claims or lawsuits (Complaints) made (or brought) against JLL LOGISTIC INC arising out of the CRASH. 62. Copy of any and all claims or lawsuits (Complaints) made (or brought) against ALEXMAR PIMIENTA GARRIDO arising out of the CRASH. 63. All claim forms and correspondence concerning the CRASH from the owner of the property being transported at the time of the COLLISION. 64. Copies of all documents pertaining to any/all brokers involved in the load being transported at the time of the CRASH. 65. Copies of any documents or writings which JLL LOGISTIC INC contends support any contention that this CRASH was the fault of any other person or entity. 66. Copies of any documents or writings which ALEXMAR PIMIENTA GARRIDO contends support any contention that this CRASH was the fault of any other person or entity.