Much of this information, you may already
have available electronically, but I have a checklist available in PDF
or Word version. Please let me know and I will forward it to
you.
Legal counsel need to know the good, the bad and the
ugly. If an attorney is taking the driver’s statement, his investigation is
arguably privileged work product. This is NOT to say that the driver’s
deposition will not be taken ultimately, so the information is discoverable;
however, if field adjuster or in-house claims professional take the statement,
then the information IS more likely to be discoverable unless you can argue
that the information was prepared in anticipation of litigation.
With Hours of Service issues that may
come up as to the driver’s negligence or even the independent negligence of the
company negligent supervision, I want to be sure that I get the following:
Number of hours driving that day Time day
Started _______
Amt.of sleep ______
Are log books current Y or N –
Under dispatch Y or N - To
Whom:__________ (This issue is increasingly important when evaluating possible
shipper or broker liability)
