* A. LOCATE EVENT VEHICLE
* B. PHOTOGRAPH EVENT VEHICLE
* C. EXAMINE EVENT VEHICLE
* D. MONITOR LOCATION OF EVENT VEHICLE
* E. ARRANGE PURCHASE OF EVENT VEHICLE
* F. PURCHASE EVENT VEHICLE
* G. TRANSPORT EVENT VEHICLE
* H. STORE EVENT VEHICLE
* I. ARRANGE INSPECTION OF EVENT VEHICLE
* J. ACCOMPANY INSPECTORS TO EVENT VEHICLE
* K. OBTAIN SVC HISTORY OF EVENT VEHICLE
* L. OBTAIN ANY AVAILABLE DATA AS IT MAY RELATE TO THIS MATTER FROM THE AMERICAN SOCIETY FOR TESTING AND MATERIALS.

2. REPORTS, DOCUMENTS AND RECORDS

* A. OBTAIN TRAFFIC COLLISION REPORT
* B. OBTAIN FIRE INCIDENT REPORT
* C. OBTAIN DEATH CERTIFICATE FOR:
* D. OBTAIN CORONER'S REPORTS FOR:
* E. OBTAIN PARAMEDIC'S REPORT FOR:
* F. OBTAIN AMBULANCE REPORT FOR:
* G. OBTAIN INSURANCE FILE FOR:
* H. OBTAIN CRIMINAL INDEX FOR:
* I. OBTAIN CRIMINAL DOCKET FOR:
* J. CIVIL INDEXES FOR CLIENT & DEFENDANTS
* K. DRIVING RECORDS FOR CLIENT & ADVERSE DRIVER
* L. AS-BUILTS
* M. NEWS-MEDIA COVERAGE

3. PHOTOGRAPHS

* A. GOVERNMENT AGENCY PHOTOGRAPHS
* B. OBTAIN ALL PHOTOGRAPHS TAKEN BY INDEPENDENTS
* C. OBTAIN ALL AVAILABLE AERIAL PHOTOGRAPHS
* D. SUMMARY OF VIDEOTAPE OF INVOLVED VEHICLES & SCENE
* E. CLIENT VEHICLE AND SCENE
* F. ADVERSE VEHICLE
* G. SATELLITE PHOTOS
* H. OBTAIN A PROOF SHEET OF ALL ROLLS OF FILM TAKEN BY ANYONE INCLUDING THE ASSIGNED INVESTIGATOR

4. SCENE

* A. PHOTOGRAPH SCENE
* B. TAKE MEASUREMENTS OF SCENE
* C. DRAW ROUGH DIAGRAM OF SCENE
* D. PREPARE FORMAL DIAGRAM OF SCENE
* E. OBTAIN SOIL DESCRIPTION OF SCENE
* F. NOTATE, TAKE DETAILED PHOTOS AND VIDEO OF ANY SECURITY SPECIFIC WARNINGS AT THE EVENT SITE AND SURROUNDING AREA (1/2 MILE IN EACH DIRECTION).

5. WITNESS

* A. DETAILED AREA CANVASS FOR WITNESSES

EYE WITNESSES
* B. IDENTIFY EYEWITNESSES
* C. INTERVIEW EYEWITNESSES
* D. AUDIO/VIDEO TAPE RECORD STATEMENT OF EYEWITNESSES
(CIRCLE METHODOLGY)
* E. TRANSCRIBE STATEMENT OF EYEWITNESSES

* F. SUMMARIZE RECORDED STATEMENT OF:
OTHER WITNESSES
* G. IDENTIFY OTHER WITNESSES
* H. INTERVIEW OTHER WITNESS:
* I. TAPE RECORD STATEMENT OF OTHER WITNESS:
* J. TRANSCRIBE STATEMENT OF OTHER WITNESS:
* K. SUMMARIZE RECORDED STATEMENT

POLICE AND FIRE PERSONNEL

* L. IDENTIFY POLICE AND FIRE PERSONNEL
* M. INTERVIEW OFFICER
* N. TAPE RECORD STATEMENT OF OFFICER:
* O. TRANSCRIBE STATEMENT OF OFFICER:
* P. SUMMARIZE RECORDED STATEMENT OF:
* Q. 911 EMERGENCY CALL PRINTOUT
* R. POLICE COMPUTER TRANSMISSION PRINTOUTS (PATROL CAR TO CAR - CAR TO BASE/BASE TO PATROL CAR)

MEDICAL PERSONNEL

* S. IDENTIFY MEDICAL PERSONNEL
* T. INTERVIEW MEDICAL PERSON:
* U. TAPE RECORD STATEMENT OF MEDICAL PERSON:
* V. TRANSCRIBE STATEMENT OF MEDICAL PERSON:
* W. SUMMARIZE RECORDED STATEMENT OF:
* X. BIO COM RECORDING TRANSCRIPT

TOW SERVICE PERSONNEL

* Y. IDENTIFY TOW SERVICE PERSONNEL
* Z. INTERVIEW TOW PERSON:
* A. TAPE STATEMENT OF TOW PERSON:
* B. TRANSCRIBE STATEMENT OF TOW PERSON:
* C. SUMMARIZE RECORDED STATEMENT OF:

6. LEGAL AND INVESTIGATIVE SUPPORT SERVICES

* A. OBTAIN COPY OF COMPLAINT:
* B. MONITOR CIVIL FILINGS
* C. PREPARE SUBPOENA FOR:
* D. SERVE SUBPOENA ON:
* E. LITERATURE SEARCH/NATIONAL/INTERNATIONAL
* F. PRESERVATION OF EVIDENCE/FORMAL NOTIFICATION
* G. NATIONAL/INTERNATIONAL SALES-PROMOTIONAL MATERIAL SEARCH
* H. NATIONAL/INTERNATIONAL TELEVISION OR RADIO BROAD- CAST RE EVENT OR EVENT INVOLVED VEHICLE/DEFENDANT OR EXPERTS
* I. OBTAIN FATAL ACCIDENT REPORTING SYSTEM STATISTICS (FARS) ON:

* J. RESEARCH AND PROVIDE COPIES OF APPLICABLE INTERNATIONAL STANDARDS ORGANIZATION (ISO) ON:

* K. CONTACT THE CONSUMER PROTECTION SAFETY COMMISSION AND DETERMINE IF PRODUCT IS SUBJECT TO AND HAS COMPLIED WITH CPSA SEC 37 (15 U.S.C. 2084) OR SEC 15(b)(3) (AND 16 CFR 1115.6(A)

* L. LOCATE AND OBTAIN DOCUMENTS CONCERNING ANY AND ALL MEETINGS OR CONFERENCES BETWEEN ANY EMPLOYEES OR AGENTS OF THE MANUFACTURER OF THE SUBJECT PRODUCT WHEREIN THE SUBJECT OF STABILITY OF THE SUBJECT PRODUCT WAS IN ANY WAY DISCUSSED, INCLUDING, BUT NOT LIMITED TO, WHAT SPECIFIC THINGS WERE DISCUSSED IN THIS REGARD, THE IDENTITY OF THE INDIVIDUALS PRESENT AT EACH SUCH MEETING OR CONFERENCE, AND THE IDENTIFY OF ANY DOCUMENTS PREPARED IN ANTICIPATION OF OR AT THE CONCLUSION OF SUCH MEETING OR CONFERENCE.

* M. LOCATE AND OBTAIN DOCUMENTS CONCERNING ANY AND ALL TESTING, BIOMECHANICS RESEARCH AND/OR COMPUTER MODELING DONE BY OR ON BEHALF OF THE MANUFACTURER OF THE SUBJECT PRODUCT TO ANALYZE VEHICLE OVERTURNS, INCLUDING, BUT NOT LIMITED TO, LATERAL TIPOVERS, ROLLOVERS OR UPSETS OF THE SUBJECT PRODUCT.

* N. DETERMINE THE FINANCIAL STATUS OF THE DEFENDANT MANUFACTURER BOTH TO INCLUDE THE ASSETS OF THE CORPORATION IN THE COUNTRY OF ORIGIN AND OWNERSHIP INTERESTS IN ANY SUBSIDIARIES IN THE UNITED STATES, INCLUDING, BUT NOT LIMITED TO, ASSETS IN TRANSIT.

* O. LOCATE AND OBTAIN DOCUMENTS CONCERNING ANY AND ALL STABILITY TESTING WHICH SUPPORTS THE MANUFACTURER'S ADVERTISED CLAIMS AS TO THE PRODUCTS PERFORMANCE.

* P. LOCATE AND OBTAIN DOCUMENTS CONCERNING ANY AND ALL DYNAMIC TESTING OF THE PRODUCT AT VARIOUS SPEEDS AND VARIOUS TURNING RATIOS, TIPOVER/ROLLOVER/UPSET TESTS OF THE SUBJECT PRODUCT.

* Q. LOCATE AND OBTAIN CERTIFIED COPIES OF ANY ADVERTISING AND MARKETING OF THE SUBJECT PRODUCT, INCLUDING, BUT NOT LIMITED TO, PRESS RELEASES, BROCHURES AND ADVERTISING IN TRADE OR OTHER PUBLICATIONS.

* R. LOCATE AND DOCUMENT SUGGESTIONS OR RESTRICTIONS CONCERNING RECOMMENDED USE OF THE SUBJECT PRODUCT MADE BY THE MANUFACTURER OR SALES REPRESENTATIVE AT THE TIME OF THE SALE.

* S. LOCATE AND DOCUMENT CONSUMER COMPLAINTS OF INJURIES RELATING TO OVERTURNS, ROLLOVERS, OR LATERAL TIPOVERS FROM 1970 THROUGH THE PRESENT TIME.

* T. LOCATE AND DOCUMENT CONSUMER COMPLAINTS OF INJURIES RELATING TO OCCUPANT/OPERATOR EJECTIONS (COMPLETE AND PARTIAL) FROM THE PRODUCT FROM 1970 THROUGH THE PRESENT TIME.

* U. LOCATE AND DOCUMENT INTER-OFFICE AND/OR INTER-COMPANY COMMUNICATIONS PREPARED OR RECEIVED BY THE MANUFACTURER, DISTRIBUTOR, MARKETING, AND SALES RELATING TO DISSEMINATION AND IMPLEMENTATION OF A OPERATOR TRAINING PROGRAM TO DISTRIBUTORS, DEALERS AND RETAILERS OF THE SUBJECT PRODUCT IN THE UNITED STATES, CANADA AND THROUGHOUT SELECTED COUNTRIES OF THE WORLD FROM 1970 THROUGH THE PRESENT TIME.

* V. LOCATE AND DOCUMENT ANY AND ALL WRITINGS AND DOCUMENTS PREPARED, PRODUCED OR RECEIVED BY THE MANUFACTURER IN CONNECTION WITH INDUSTRY TRENDS, COMPETITIVE INFORMATION, RESEARCH, FEEDBACK FROM

DEALERS/USERS AND ANALYSIS RELATIVE TO THE SUBJECT PRODUCT FROM 1970 THROUGH THE PRESENT TIME, INCLUDING:

(a) REPORTS, STUDIES OR OTHER DATA RELATING TO COMPETITORS' COMPARABLE PRODUCT TO THE SUBJECT PRODUCT FROM 1970 THROUGH THE PRESENT TIME.

(b) REPORTS, STUDIES OR OTHER DATA FROM THE MANUFACTURER'S TRADE ASSOCIATIONS RELATING TO STABILITY, OPERATOR RESTRAINTS, OPERATOR EJECTIONS (COMPLETE OR PARTIAL) AND/OR OPERATOR SAFETY FROM 1970 THROUGH THE PRESENT TIME.

(c) REPORTS OR MEMORANDA PREPARED OR PRODUCED BY THE MANUFACTURER OR ORGANIZATIONS OF WHICH IT IS A MEMBER CONCERNING MODIFICATIONS TO THE DESIGN OF THE SUBJECT PRODUCT FROM 1970 THROUGH THE PRESENT TIME.

* W. DETERMINE LIKELY VERDICT, STATE, NTL.
* X. IDENTIFY, AND LOCATE EXPERT WITNESSES AND ASSESS THEIR TRIAL SUCCESS RATE.
* Y. RESEARCH THE BACKGROUNDS OF THE OPPOSITION'S TRIAL ATTORNEYS, AS WELL AS JUDGES AND PARTIES INVOLVED IN THIS CASE TO DETERMINE WIN/LOSS RATE ALONG WITH BACKGROUNDS OF THE OTHER HISTORICAL DECISION AND TESTIMONY PATTERNS.

7. OPERATOR/OCCUPANT RESTRAINT

* A. OBTAIN ANY AND ALL ENGINEERING AND ENGINEERING CHANGES TO THE OPERATOR RESTRAINT SYSTEM, INCLUDING ANY PART, SUBPART OR COMPONENT PART THEREOF FROM THE ORIGINAL DESIGN TO THE PRESENT.

* B. OBTAIN ENGINEERING DRAWINGS WHICH DEPICT THE PARTS, SUBPARTS AND COMPONENTS OF THE OPERATOR RESTRAINT SYSTEM ON THE SUBJECT PRODUCT FROM THE DATE OF THE ORIGINAL DRAWING TO THE PRESENT, INCLUDING, BUT NOT LIMITED TO ANY DRAWINGS WHICH REFLECT ANY CHANGES OR MODIFICATIONS TO THE ABOVE ITEMS.

* C. OBTAIN THE ORIGINAL AND ANY SUBSEQUENT RESEARCH AND DEVELOPMENT TEST WHICH WAS CONDUCTED IN ORDER TO DESIGN, MACHINE, MANUFACTURE AND ASSEMBLE THE OPERATOR RESTRAINT SYSTEM ON SUBJECT PRODUCT.

* D. OBTAIN THE ORIGINAL AND ANY SUBSEQUENT RESEARCH AND DEVELOPMENT TEST WHICH WAS CONDUCTED IN ORDER TO EVALUATE ALTERNATIVE DESIGNS OF THE OPERATOR RESTRAINT SYSTEM ON THE SUBJECT PRODUCT, INCLUDING, BUT NOT LIMITED TO, RESEARCH AND DEVELOPMENT BY OTHER MANUFACTURERS.

* E. LOCATE AND OBTAIN DOCUMENTS CONCERNING ANY AND ALL MEETINGS OR CONFERENCES BETWEEN ANY EMPLOYEES OR AGENTS OF THE MANUFACTURER OF THE SUBJECT PRODUCT AND THE COMPETITIVE COUNTERPARTS WHEREIN THE SUBJECT PRODUCT WAS IN ANY WAY DISCUSSED, INCLUDING BUT NOT LIMITED TO, SPECIFIC SUBJECTS DISCUSSED IN THIS REGARD, THE IDENTITY OF THE INDIVIDUALS PRESENT AT EACH SUCH MEETING OR CONFERENCE AND THE IDENTITY OF ANY DOCUMENTS PREPARED IN ANTICIPATION OF OR AS A RESULT OF EACH SUCH MEETING OR CONFERENCE.

* F. LOCATE AND OBTAIN DOCUMENTS CONCERNING THE MANNER OF PREPARATION OF ANY AND ALL OPERATOR'S MANUALS FOR THE SUBJECT PRODUCT, INCLUDING, BUT NOT LIMITED TO, WHO PREPARED THE MANUALS, WHO PROVIDED INPUT FOR THE PREPARATION OF THE MANUALS, WHO HAD FINAL APPROVAL FOR PUBLICATION, REVISIONS, MODIFICATIONS, AND UPDATES OF EACH SUCH MANUAL AS WELL AS THE PRINTER OF SAME.

* G. LOCATE AND OBTAIN DOCUMENTS CONCERNING ANY AND ALL MEETINGS OR CONFERENCES BETWEEN ANY EMPLOYEES OF THE MANUFACTURER OF THE SUBJECT PRODUCT WHEREIN THE SUBJECT OF SAFETY OF THE SUBJECT PRODUCT WAS IN ANY WAY DISCUSSED INCLUDING, BUT NOT LIMITED TO, WHAT SPECIFIC THINGS WERE DISCUSSED IN THIS REGARD AND THE IDENTITY OF THE INDIVIDUALS PRESENT AT EACH SUCH MEETING OR CONFERENCE.

* H. LOCATE AND OBTAIN DOCUMENTS CONCERNING ANY AND ALL MEETINGS OR CONFERENCES BETWEEN ANY EMPLOYEES OR AGENTS OF THE MANUFACTURER OF THE SUBJECT PRODUCT WHEREIN THE SUBJECT OF OPERATOR/OCCUPANT SAFETY OF THE SUBJECT PRODUCT WAS IN ANY WAY DISCUSSED INCLUDING, BUT NOT LIMITED TO, WHAT SPECIFIC THINGS WERE DISCUSSED IN THIS REGARD AND THE IDENTITY OF THE INDIVIDUALS PRESENT AT EACH SUCH MEETING OR CONFERENCE AND THE IDENTITY OF ANY DOCUMENTS PREPARED IN ANTICIPATION OF OR AS A RESULT OF EACH SUCH MEETING OR CONFERENCE.

* I. LOCATE AND OBTAIN DOCUMENTS CONCERNING ANY AND ALL MEETINGS OR CONFERENCES BETWEEN ANY EMPLOYEES OR AGENTS OF THE MANUFACTURER OF THE SUBJECT PRODUCT WHEREIN THE SUBJECT OF OPERATOR/OCCUPANT RESTRAINTS FOR THE SUBJECT PRODUCT WAS IN ANY WAY DISCUSSED, INCLUDING, BUT NOT LIMITED TO, WHAT SPECIFIC THINGS WERE DISCUSSED IN THIS REGARD, THE IDENTITY OF THE INDIVIDUALS PRESENT AT SUCH MEETING OR CONFERENCE, AND THE IDENTIFY OF DOCUMENTS PREPARED IN ANTICIPATION OF OR AS A RESULT OF SUCH MEETINGS OR CONFERENCES.

* J. LOCATE AND OBTAIN DOCUMENTS CONCERNING ANY AND ALL MEETINGS OR CONFERENCES BETWEEN AND AMONG ANY EMPLOYEES, REPRESENTATIVES OR AGENTS OF THE MANUFACTURER WHEREIN THE SUBJECT OF PROPOSED STATE AND FEDERAL STANDARDS REQUIRING OPERATOR/OCCUPANT RESTRAINTS ON THE SUBJECT PRODUCT WAS IN ANY WAY DISCUSSED, INCLUDING BUT NOT LIMITED TO, WHAT SPECIFIC THINGS WERE DISCUSSED IN THIS REGARD, THE IDENTITY OF THE INDIVIDUALS PRESENT AT EACH SUCH MEETING OR CONFERENCE, AND THE IDENTITY OF ANY DOCUMENTS PREPARED IN ANTICIPATION OF OR AS A RESULT OF EACH SUCH MEETING OR CONFERENCE.

* K. LOCATE AND OBTAIN ANY DOCUMENTS CONCERNING ANY AND ALL TESTING, BIOMECHANICS RESEARCH AND/OR COMPUTER MODELING DONE BY OR ON BEHALF OF THE MANUFACTURER TO ANALYZE OPERATOR RESTRAINT SYSTEMS FOR THE SUBJECT PRODUCT.

* L. LOCATE AND OBTAIN ANY DOCUMENTS CONCERNING ANY AND ALL MEETINGS AND CONFERENCES BETWEEN ANY EMPLOYEES OR AGENTS OF THE PRODUCT MANUFACTURER WHEREIN THE SUBJECT OF OPERATOR/OCCUPANT WARNINGS RELATING TO THE SUBJECT PRODUCT WAS IN ANY WAY DISCUSSED, INCLUDING, BUT NOT LIMITED TO, WHAT SPECIFIC THINGS WERE DISCUSSED IN THIS REGARD, THE IDENTITY OF THE INDIVIDUALS PRESENT AT EACH SUCH MEETING OR CONFERENCE AND THE IDENTITY OF ANY DOCUMENTS

PREPARED IN ANTICIPATION OF OR AS A RESULT OF EACH SUCH MEETING OR CONFERENCE.

* M. LOCATE AND OBTAIN DOCUMENTS CONCERNING ANY AND ALL MEETINGS OR CONFERENCES BETWEEN ANY EMPLOYEES OR AGENTS OF THE PRODUCT MANUFACTURER WHEREIN THE SUBJECT OF DYNAMIC TIPOVER/ROLLOVER/UPSET TESTING WAS IN ANY WAY DISCUSSED, INCLUDING, BUT NOT LIMITED TO, WHAT SPECIFIC THINGS WERE DISCUSSED IN THIS REGARD, THE IDENTITY OF THE INDIVIDUALS PRESENT AT EACH SUCH MEETING OR CONFERENCE.

* N. LOCATE AND OBTAIN DOCUMENTS CONCERNING MODIFI- CATIONS MADE BY THE MANUFACTURER TO THE OPERATOR SEAT OR OPERATOR COMPARTMENT ON THE SUBJECT PRODUCT FROM ITS ORIGINAL DESIGN AT ANY TIME BEFORE MM/DD/YY.

* O. LOCATE AND OBTAIN DOCUMENTS CONCERNING MODIFICATIONS MADE BY THE MANUFACTURER ON THE SUBJECT PRODUCT AT ANY TIME AFTER MM/DD/YY.

* P. LOCATE AND DOCUMENT SUGGESTIONS OR RESTRICTIONS CONCERNING RECOMMENDED USE OF THE SUBJECT PRODUCT MADE BY THE MANUFACTURER OR SALES REPRESENTATIVE AT THE TIME OF DISTRIBUTION.

* Q. LOCATE AND DOCUMENT WARNINGS GIVEN BY THE MANUFACTURER OR SALE REPRESENTATIVE AT THE TIME OF MANUFACTURE CONCERNING RECOMMENDED USE OF THE SUBJECT PRODUCT.

* R. LOCATE AND DOCUMENT WARNINGS GIVEN BY THE MANUFACTURER OR SALES REPRESENTATIVE AT THE TIME OF DISTRIBUTION CONCERNING RECOMMENDED USE OF THE SUBJECT PRODUCT.

* S. LOCATE AND DOCUMENT STATUTES, CODES, ORDINANCES OR WRITTEN STANDARDS CONSTITUTING GUIDELINES APPLICABLE TO THE MANUFACTURER'S DESIGN OF THE SUBJECT PRODUCT.

* T. LOCATE AND DOCUMENT STATUTES, CODES, ORDINANCES OR WRITTEN STANDARDS CONSTITUTING GUIDELINES APPLICABLE TO THE MANUFACTURER'S MANUFACTURE OF THE SUBJECT PRODUCT.

* U. LOCATE AND DOCUMENT ALL LITERATURE THAT THE MANUFACTURER MIGHT CONTEND WAS SUPPOSED TO ACCOMPANY THE SUBJECT PRODUCT WHEN DELIVERED TO THE BUYER.

* V. LOCATE AND DOCUMENT ANY AND ALL WARNINGS THE MANUFACTURER MIGHT CONTEND SHOULD HAVE BEEN INSTALLED ON THE SUBJECT PRODUCT WHEN DELIVERED TO THE PURCHASER.

* W. LOCATE AND DOCUMENT ALL TIPOVER/ROLLOVER/UPSET ACCIDENT REPORTS RELATING TO OCCUPANT/OPERATOR EJECTIONS FROM TIPOVER/ROLLOVER OR UPSET OF THE PRODUCT FROM THE TIME THE MANUFACTURER FIRST MANUFACTURED THE INVOLVED SERIES OF PRODUCTS.

* X. LOCATE AND DOCUMENT THE STATISTICS RELATING TO OVERTURNS, ROLLOVERS, OR LATERAL TIPOVERS FROM 1970 THROUGH THE PRESENT TIME OF THE SUBJECT PRODUCT.

* Y. LOCATE AND DOCUMENT RESEARCH AND DEVELOPMENT CONCERNING THE OCCUPANT/OPERATOR RESTRAINT SYSTEM FOR THE PRODUCT FROM 1970 THROUGH THE PRESENT TIME.

* Z. LOCATE AND DOCUMENT IMPLEMENTATION AND DISTRIBUTION CONCERNING THE OCCUPANT/OPERATOR RESTRAINT SYSTEM FOR THE PRODUCT IN THE UNITED STATES AND THROUGHOUT SELECTED COUNTRIES OF THE WORLD FROM 1970 THROUGH THE PRESENT TIME.

* A-1 LOCATE AND DOCUMENT CONSUMER COMPLAINTS OF INJURIES RELATING TO OCCUPANT/OPERATOR RESTRAINT SYSTEM OR LACK THEREOF, FOR THE PRODUCT FROM 1970 THROUGH THE PRESENT TIME.

* A-2 LOCATE AND DOCUMENT SUGGESTIONS OR RECOMMENDED CHANGES OR MODIFICATIONS RELATING TO THE DESIGN, MANUFACTURE, SALE, OR DISTRIBUTION OF THE SUBJECT PRODUCT, OR ANY OF ITS COMPONENT PARTS, INCLUDING THE OCCUPANT/OPERATOR RESTRAINT SYSTEM FROM 1970 THROUGH THE PRESENT TIME.

* A-3 LOCATE AND DOCUMENT SUGGESTIONS OR RECOMMENDED MODIFICATIONS/ CHANGES TO THE OCCUPANT/OPERATOR RESTRAINT SYSTEM RECEIVED BY THE MANUFACTURER FROM DEALERS, WHOLESALERS OR RETAILERS OF THE SUBJECT PRODUCT.

* A-4 LOCATE AND DOCUMENT ALL REPORTS, STUDIES, STATISTICS OR OTHER DATA RECEIVED BY THE MANUFACTURER DISTRIBUTOR/MARKETING AND SALES RELATING TO STABILITY, OPERATOR RESTRAINTS, OPERATOR EJECTIONS (COMPLETE AND PARTIAL) AND/OR OPERATOR SAFETY FROM 1970 THROUGH THE PRESENT TIME.

* A-5 LOCATE AND DOCUMENT ALL REPORTS, STUDIES, GUIDELINES OR RECOMMENDATIONS RECEIVED FROM THE CALIFORNIA GOVERNMENTAL AGENCY MOST RESPONSIBLE RELATING TO STABILITY, OPERATOR RESTRAINTS, OPERATOR EJECTIONS AND/OR OPERATOR/OCCUPANT SAFETY FROM 1970 THROUGH THE PRESENT TIME.

* A-6 LOCATE AND DOCUMENT ALL REPORTS, STUDIES, GUIDE- LINES OR RECOMMENDATIONS RECEIVED BY THE MANUFAC- TURER FROM ANSI RELATING TO STABILITY, OPERATOR RESTRAINTS, OPERATOR EJECTIONS AND/OR OPERATOR/OCCUPANT SAFETY FROM 1970 THROUGH THE PRESENT TIME.

** A-7 LOCATE AND DOCUMENT ALL REPORTS, STUDIES, GUIDELINES OR RECOMMENDATIONS RECEIVED BY THE MANUFACTURER FROM THE AMERICAN SOCIETY OF MECHANICAL ENGINEERS RELATING TO STABILITY, OPERATOR RESTRAINTS, OPERATOR EJECTIONS AND/OR OPERATOR/OCCUPANT SAFETY FROM 1970 THROUGH THE PRESENT TIME.

8. ROADWAY CASES

* A. OBTAIN STATE/CITY SWTRS (STATE WIDE TRAFFIC REPORTING SYSTEM). REPORT

* B. OBTAIN COUNTY TRANSPORTATION ROAD IMPROVEMENT PLAN (TIP REPORT) CITY/STATE AND MINUTES OF ALL COUNTY ROAD COMMISSION/SUPERVISORY HEARINGS IN REFERENCE TO PARTICULAR SECTION OF EVENT INVOLVED ROADWAY

* C. COUNTY/STATE/CITY SPEED AND TRAFFIC FLOW STUDIES AND RECOMMENDATIONS

* D. HISTORICAL SOCIETY AERIAL PHOTOS AND GROUND LEVEL PHOTOS OF EVENT SITE

* E. ROADWAY MAINTENANCE RECORDS/INTERVIEW OF MAIN- TENANCE PERSONNEL AND ADDRESS OF NEAREST MAINTENANCE STORAGE YARD SERVICING EVENT SITE

* F. CIVIL (POLICE, SHERIFF, PARKING VIOLATIONS IF APPLICABLE, AND HIGHWAY PATROL) AUTHORITY CITATION HISTORY OF EVENT SITE

* G. CITY/STATE/COUNTY MAINTENANCE RECORDS FOR TRI-SIGNALS AT SCENE

* H. CITIZEN COMPLAINT HISTORY OF EVENT SITE

* I. LOCAL/NATIONAL D.R. (DISTRICT REPORTING): SYSTEMS SUMMARY

* J. 911 CALL SUMMARY AND EVENT 911 CALL PRESERVATION
* K. VIDEO TAPE THE SCENE OF THE EVENT AT THE TIME THE EVENT OCCURRED, OR AS SOON AS IS POSSIBLE
FOLLOWING THE DATE OF EVENT, OR THE ASSIGNMENT. UTILIZE THE SAME TYPE OF VEHICLE AS INVOLVED IN THE EVENT. TO SHOW SUBSTANTIAL SIMILARITIES OF CONDITIONS, MAKE SEVERAL RUNS THROUGH THE SCENE OF THE EVENT WHILE VIDEO TAPING AT VARIOUS SPEEDS AS IS WARRANTED DEPENDING ON WITNESS TESTIMONY/ESTIMATES.

* L. DETERMINE OWNERSHIP, MAINTENANCE, PROPOSALS, SPECIFICATIONS, DESIGNER OF ROADWAY

* M. UTILIZING THE "UNIQUE FACTS" OF THIS EVENT, ADVISE WHETHER THE ROADWAY APPEARS TO BE DANGEROUS WHEN USED WITH DUE CARE AND WHETHER PLAINTIFF'S INJURY WAS PROXIMATELY CAUSED BY THE DANGEROUS CONDITION EVEN IF THE ROADWAY WAS USED WITH "DUE CARE".

* N. CONSIDERING ITEM __M__ ABOVE, WAS THE RESULTANT INJURY SUFFERED IN A WAY THAT WAS REASONABLY FORESEEABLE AND THE CONSEQUENCE OF THE DANGEROUS CONDITION OF THE ROADWAY/PROPERTY?

* O. DETERMINE THE IDENTITY OF THE PERSON MOST KNOWLEDGEABLE RELATIVE TO THE DANGEROUS CONDITION WHICH WAS CREATED BY A NEGLIGENT/WRONGFUL ACT OR OMISSION OF A GOVERNMENTAL ENTITY/EMPLOYEE/ CONSULTANT/INDEPENDENT CONTRACTOR WHEN ACTING/OR EMPLOYED WITHIN THE SCOPE OF EMPLOYMENT FOR THE GOVERNMENTAL ENTITY.

* P. ALTERNATIVELY DETERMINE WHETHER THE GOVERNMENTAL ENTITY HAD ACTUAL OR CONSTRUCTIVE NOTICE OF THE DANGEROUS CONDITION IN SUFFICIENT TIME PRIOR TO THE EVENT TO HAVE TAKEN MEASURES TO HAVE PROTECTED AGAINST THE DANGEROUS CONDITION.

* Q. OBTAIN A TASA (TRAFFIC ACCIDENTS SURVEILLANCE ANALYSIS SYSTEM) REPORT MAINTAINED BY THE STATE OF JURISDICTION OR SIMILAR REPORTING SYSTEM FOR AREA OF EVENT AND DETERMINE WHETHER THE CITY/COUNTY IN WHICH THIS EVENT OCCURRED MAINTAINS THEIR OWN SEPARATE TRAFFIC CRASH ANALYSIS SYSTEM, AND IF SO, OBTAIN THAT HISTORY OF THE EVENT SITE FOR ONE MILE IN ALL COMPASS DIRECTIONS FOR THE PAST TEN YEARS.

* R. COLLECT ALL PRIOR CIVIL AUTHORITY INVESTIGATION RE- PORTS RELATIVE TO THE EVENT SITE INCLUDING THE NAMES AND ADDRESSES OF WITNESSES TO THOSE PRIOR EVENTS IN THE AREA WHERE THE INSTANT EVENT OCCURRED.

* S. DETERMINE WHETHER THERE HAVE BEEN ANY EVENTS SUBSEQUENT TO THE INSTANT EVENT WHICH HAS A SUBSTANTIAL SIMILARITY TO THE CIRCUMSTANCES OF THE INSTANT EVENTS, AND OBTAIN A COPY OF THE SUBSEQUENT EVENTS FROM THE RESPONSIBLE CIVIL INVESTIGATING AGENCY.

* T. REVIEW AND DETERMINE WHETHER THE EVENT SITE COMPLIES WITH THE CAL TRANS TRAFFIC MANUAL.

* U. REVIEW AND DETERMINE WHETHER THE EVENT SITE COMPLIES WITH THE CAL TRANS DESIGN MANUAL.

* V. REVIEW AND DETERMINE WHETHER THE EVENT SITE COMPLIES WITH THE U.S. FEDERAL GOVERNMENT'S MANUAL ON UNIFORM TRAFFIC CONTROL DEVICES.

* W. DETERMINE THE NAME OF THE PERSON MOST KNOWLEDGEABLE IN THE STATE/COUNTY/CITY OR UNINCORPORATED AREA WHO IS RESPONSIBLE FOR TRAFFIC DESIGN OR TRAFFIC STANDARDS.

* X. DETERMINE AND ACCUMULATE ALL RELATIVE DATA OF THE HISTORY OF REMEDIAL REPAIR ON/TO THE EVENT SITE FOR THE ROAD LEADING UP TO OR PAST THE EVENT SITE.

* Y. OBTAIN ALL AS-BUILTS AND DESIGN PLANS FOR THE EVENT SITE BY RESPONSIBLE GOVERNMENT ENTITIES, AS WELL AS PROPOSED CHANGES FOR EVENT SITE.

* Z. DETERMINE WHETHER A "PROOF PLAN" FOR THE DESIGN OF THE EVENT SITE WAS "APPROVED IN ADVANCE" AND, IF SO, BY WHOM AT THE INVOLVED GOVERNMENTAL ENTITY.

* A-1 DETERMINE THE INCREASE/DECREASE IN TRAFFIC VOLUME OVER THE PAST 20 YEARS FOR THE EVENT SITE AS WELL AS THE INCREASE/DECREASE AND GENERAL CITIZEN POPULATION AROUND THE AREA OF THE EVENT SITE.

* B-2 IF SUBSEQUENT REMEDIAL REPAIR HAS BEEN MADE TO THE EVENT SITE, IDENTIFY, INTERVIEW AND STATEMENTIZE THE INDIVIDUAL WHO AUTHORIZED THE CHANGE OR THE SUBSEQUENT REMEDIAL REPAIR.

* C-3 DETERMINE WHAT THE PARTICULAR FEATURE OF THE INVOLVED EVENT SITE IS THAT IS INVOLVED IN THIS PARTICULAR EVENT THAT MAKES THE ROADWAY DEFECTIVE/NON DEFECTIVE WHICH WAS NOT/WHICH WAS A PART OF THE "PRE-APPROVED ROADWAY PLAN/DESIGN".

* D-4 DETERMINE IF/SINCE THE MOST RECENT CHANGE IN THE ROADWAY, HAVE ANY OF THE ROADWAY CONDITIONS CHANGED? WHAT HAS CHANGED SPECIFICALLY, WHY AND HOW LONG HAS CHANGE BEEN CONSIDERED/RECOMMENDED?

* E-5 DETERMINE WHETHER THERE ARE ANY CONCURRENT CAUSES FOR THE CRASH AND SPECIFY THOSE CONCURRENT CAUSES.

* F-6 SINCE A WARNING SIGN DOES NOT IN AND OF ITSELF CONSTITUTE A DANGEROUS CONDITION, WAS THE EVENT SITE DANGEROUS IN THE ABSENCE OF WARNING SIGNS? IF SO, SPECIFY.

* G-7 DETERMINE HOW THE EVENT SITE IS CATEGORIZED BY THE STATE/ COUNTY/CITY. IS THE EVENT SITE AN "ACCESS ROAD"/RECREATIONAL TRAIL AND IF SO, SUPPLY SUPPORTING DOCUMENTATION TO THE CATEGORIZATION OF THE EVENT SITE BY THE STATE/COUNTY/CITY.

* H-8 DOES THE ALLEGED/PERCEIVED DEFECT CREATE A "TRAP" FOR THE CONSUMER USING THIS ROAD. DEFINE THAT TRAP.

9. DESIGNATED EXPERT DETAILED BACKGROUND

* A. JURY SHEET BACKGROUND;

* B. DEPOSITION BANK EXPERIENCE AND TRANSCRIPT COPIES;
* C. TRIAL BANK EXPERIENCE AND TRANSCRIPT COPIES;

* D. ANALYZE ALL PRIOR DEPOSITION AND TRIAL TESTIMONY GIVEN, BY SUBJECT EXPERT;

* E. SEARCH FOR OLD LETTERHEADS/PUBLICATION IN WHICH EXPERT MAY HAVE PARTICIPATED IN OR WRITTEN PAPERS FOR;

* F. DETERMINE WHAT COLLEGE ATTENDED; OBTAIN YEARBOOKS FOR THAT GRADUATING CLASS AND DETERMINE THE INDIVIDUAL EXPERT'S STANDING WITHIN THAT CLASS RANKING;

* G. CHECK BOARD CERTIFICATIONS, BOARD TEST RESULTS AND/OR QUALIFICATIONS NEEDED TO TAKE SAID CERTIFICATION OR TO RECEIVE SAID CERTIFICATION, AS WELL AS NUMBER OF TIMES EXAM WAS TAKEN;

* H. IDENTIFY, LOCATE AND INTERVIEW PRIOR EMPLOYEES/ EMPLOYERS OF THE INDIVIDUAL EXPERTS;

* I. PRIOR LITIGATION BACKGROUND, IF ANY;

* J. ATTEMPT TO ESTABLISH BIAS IN THIS PARTICULAR CASE;

* K. ESTABLISH BILLING RATES AND AMOUNT BILLED TO DATE ON THIS MATTER AS WELL AS CUMULATIVE DOLLARS BILLED TO THIS INDIVIDUAL DEFENDANT AND/OR ATTORNEY;

* L. DETERMINE HOW MANY TIMES/HOW OFTEN HAS THE INDIVIDUAL EXPERT BEEN EMPLOYED BY THE PARTICULAR INSURANCE CARRIER/DEFENDANT OR DEFENDANT'S ATTORNEY OR LAW FIRM;

* M. EVALUATE/CALCULATE THE RATIO OF DEFENSE WORK TO PLAINTIFF'S WORK;

* N. IF THE DEFENDANT EXPERT HAS PREVIOUSLY REPRESENTED A PLAINTIFF, THEN WHO WAS THE PLAINTIFF'S ATTORNEY, AND, IS THAT PLAINTIFF'S ATTORNEY PRIMARILY A DEFENSE LAWYER;

* O. DETERMINE WHETHER THE SO CALLED DEFENSE EXPERT IS AN "ADVOCATE" AS OPPOSED TO AN EXPERT IN THE PARTICULAR CATEGORY IN WHICH THAT EXPERT IS TESTIFYING;

* P. EXAMINE CLOSELY THE PRIOR TESTIMONY GIVEN IN PRIOR LITIGATION AND/OR DEPOSITIONS AND ATTEMPT TO DETERMINE WHETHER THEY ARE ATTEMPTING TO INSERT "FACTS OF EVIDENCE" GLEANED FROM TESTIMONY OF OTHERS AS OPPOSED TO HIS OWN INDEPENDENT EVALUATION AND THOUGHT PROCESSES;

* Q. REVIEW AND ANALYZE CAREFULLY THE CONTENT OF THEIR DEPOSITIONS GIVEN IN THE INSTANT MATTER FOR CONFLICT WITH PRIOR TESTIMONY GIVEN IN OTHER DEFENSE AND/OR PLAINTIFF MATTERS;

* R. ATTEMPT TO DETERMINE HOW MUCH TIME THE EXPERT ACTUALLY SPENT WITH THE PRODUCT IN THE PROCESS OF THE PHYSICAL EXAMINATION OF THE INVOLVED VEHICLE AND CRASH SITE;

* S. DETERMINE AND OBTAIN COMPLETE COPIES OF ALL ARTICLES WRITTEN BY OR CO-ADHERED BY THE INDIVIDUAL EXPERT;

* T. DETERMINE WHETHER THE DEFENSE EXPERT HAS ANY TEACHING CREDENTIALS, AND IF SO, AT WHAT EDUCATIONAL FACILITY;

* U. INTERVIEW CO-EDUCATORS AND STUDENTS TO OBTAIN THEIR EVALUATION OF THE SUBJECT EXPERT.

* V. REVIEW FOR ANY LITIGATION/DISPUTE HISTORY WITH THE UNITED STATES DISTRICT TAX COURT AND THE UNITED STATES DISTRICT COURT/CIVIL/CRIMINAL.

* W. REVIEW FOR ANY TAX PETITIONS WITH THE U.S. TAX COURT UNDER ANY PERSONAL/CORPORATE OR ALSO KNOWN AS NAME THAT HAS EVER BEEN USED BY OR ASSOCIATED WITH THE SUBJECT OF THIS INQUIRY AS WELL AS CURRENT OR FORMER SPOUSE'S NAME.

* X. REVIEW RECORDS THAT MAY BE AVAILABLE THROUGH THE N.A.S.D. OR S.E.C. IF APPLICABLE TO THIS INSTANCE.