Discovery checklist

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Discovery checklist 

Obtaining the full scope of relevant manufacturer documents is essential. Where original documentation is electronic, insist on electronic production in original and native format to retain important metadata and links to other data or documents. You should also acquire documents available outside formal discovery, including from other similar litigation. At a minimum, you should obtain:

  • design drawings (preliminary, final, package, assembly, and change orders)

  • design specifications

  • crash testing

  • internal and government certification testing

  • correspondence between vehicle and seat belt manufacturers, including sales presentations

  • contracts between vehicle and seat belt manufacturers

  • internal guidelines, standards, design goals, and objectives

  • cost-benefit studies

  • field performance studies and analysis

  • failure mode effect analysis

  • alternative designs considered or rejected, including policy discussions and decision-making

  • alternative design availability, benefits, effectiveness, and cost

  • memoranda and meeting minutes

  • service notices, recalls, and defect investigations

  • quality control processes

  • warnings, instructions, advertisements, and promotional materials

  • reports of other similar incidents

  • documents, depositions, and testimony from other similar litigation

  • documents exchanged with the government regarding restraint system performance

  • identity of responsible organizational units, managers, and engineers

  • document retention policies and a list of relevant documents destroyed.

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