PLAINTIFFS’ FIRST SET OF INTERROGATORIES TO DEFENDANT

Explain the relationship between SAIA and JOHN PITTS at the time of the Subject Incident (e.g., leased driver, company driver, etc.); Explain how JOHN PITTS was paid for driving (by hour, by load, by mile, salary or other); Explain all steps SAIA undertook to qualify JOHN PITTS in accord with the Federal Motor Carrier Safety Regulations; ................
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