Free Request for Production of Documents - District Court of Delaware - Delaware

Case 1 :08-cv-00001-GIVIS Document 9 Filed 03/06/2008 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
DISTRICT OF DELAWARE
KENNETH S. BANNING, I R.,
PLAINTIFF, C.A. NO. 08-00001 GMS
v. TRIAL BY JURY DEMANDED
ALIN AUGUSTIN MASCA AND
MAHAI DORU POP,
DEFENDANTS.
REQUEST FOR PRODUCTION OF DOCUMENTS DIRECTED TO DEFENDANTS
AND NOW, comes the Plaintiff above named who does request Defendants produce the
following within thirty (3 0) days of the date of service.
I. Any and all regulations in effect between the defendants regarding the operation of
the vehicle involved in the incident of November 4, 2005.
2. The complete personnel tile of Alin Masca.
3. All investigation into and vetting of driver Alin Masca by co-defendant
Mahai Doru Pop prior to the incident of November 4, 2005 with regards to his qualilications to
operate a tractor trailer.
4. A copy of any and all documentation concerning prior incidents and/or accidents,
prior citations and/or motor vehicle code violations and/or other history which would impact on
driver l\/Iasca’s abilities as a driver.
5. A copy of the trip logs relating to the week prior to the incident of November 4, 2005
including the date of the incident, November 4, 2005 concerning Alin Masca.
6. Any and all incident reports prepared by you or by anyone else relative to the
accident ofNovernber 4, 2005.
7. Any documentation concerning any disciplinary hearing, penalties, suspensions

Case 1:08-cv—00001-G|\/IS Document 9 Filed 03/06/2008 Page 2 of 2
relative to the operation of a vehicle by defendant Alin Masca prior to the incident of November
4, 2005.
8. Any and all documents defendants intend to use at time of trial.
ROBINSON GRAYSON DRYDEN
& ARD
site N i¤. i—;.N, ESQU1RE
Bar l.D. No. 2157
910 Foulk Road, Suite 200
Wilmington, DE 19803
(302) 655-6262
Attorney for Plaintiff
Dated: March 6, 2008

Case 1:08-cv-00001-GMS

Document 9

Filed 03/06/2008

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Case 1:08-cv-00001-GMS

Document 9

Filed 03/06/2008

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