Trial Lawyer Nation 196-How to Dig Deeper in Discovery with Sonia Rodriguez
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Jan 31, 2026 Sonia Rodriguez, a plaintiff attorney and litigation strategist known for creative discovery and trial prep. She explores nontraditional discovery sources and industry databases. Topics include using SAFER, FOIA alternatives, mining social media and PACER, interviewing former employees, and strategic subpoenas to uncover hidden employer and safety information.
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Use SAFER To Build Carrier Background Quickly
- Do a SAFER search for motor carriers to get two years of crash and violation history and company contact details.
- Use that data to identify company name variations, agent for service, and trends that support foreseeability and training failures.
Mine Court Records And Network With Other Lawyers
- Search PACER and statewide court databases to find prior lawsuits, experts, and counsel and then call those lawyers for depositions and documents.
- Leverage others' depositions to craft precise discovery requests and identify people to subpoena or depose by name.
File FOIA Early Despite Slow Turnaround
- File FOIA / public records requests early for agency audits, warning letters, and safety scores even though they can take months.
- Request DOT/FMCSA materials and agency audits immediately because they contain authenticated evidence not available online.