Investigating Catastrophic 18 Wheeler Wrecks -  A Paralegal's Perspective

When The Alfred Firm was hired after a wrong-way, head-on 18-wheeler wreck that claimed the lives of two women, our team acted immediately. The Alfred Firm’s paralegal team, led by Chief of Staff Amanda Zubire,  took four important steps in conducting this investigation: 

Step 1: The Alfred Firm’s Paralegals Obtain Police Report and Make Contact with the Investigating Officer

In a catastrophic incident, the police report is often not readily available due to the ongoing investigation. Because of this, The Alfred Firm’s team of paralegals made direct contact with the investigating officer, who was able to share the time and location of the incident, provide the at-fault driver’s name and driver’s license number, identify the trucking company, and provide the tractor and trailer vehicle identification number. 

The investigating officer also shared inside information, including where the driver was coming from and where the driver was going. With the exact coordinates, The Alfred Firm’s paralegal team was able to pull up the location of the wreck on Google Earth. From this information, it was determined that the gas station from which the 18 wheeler driver departed was also a truck stop. 

This led to further questions such as: How long had the driver been on the road? How long was the truck driver resting at the truck stop?

Step 2: The Alfred Firm’s Paralegals Conduct Background Search to Locate the Missing Truck Driver

The Alfred Firm’s paralegal team then engaged a private investigator team and requested that they pull a complete background check on the at-fault driver and trucking company. And upon receiving the investigator’s report, the unthinkable was revealed.

The at-fault truck driver’s driving record had multiple violations which showed that this driver should have never been on the road. In cases involving 18-wheeler wrecks, it is important to show that the trucking company hired an unsafe driver to operate their trucks. The trucking company is liable for all negligence of their driver while in the course and scope of employment. 

Amanda and her investigative team worked then identified several addresses for the at fault driver. One of the addresses was linked to a small trucking company that was not identified on the police report. And though the truck driver had fled to another state, the small trucking company’s owner was able to share information that assisted The Alfred Firm’s paralegal team in locating the missing truck driver.

Step 3: The Alfred Firm Files a Temporary Restraining Order

Once the truck driver and trucking company had been identified, Amanda worked with The Alfred Firm’s Founder Byron Alfred to draft the lawsuit and Application for Temporary Restraining Order seeking a court order that the trucking company and its driver were prohibited from:

• Damaging,  modifying, altering, selling or disposing of, in any way, the tractor and/or trailer involved in the incident in question;
• Removing or transporting the tractor and/or trailer from its present location without leave of Court;
• Damaging,  modifying,  altering,  selling  or  disposing  of,  in  any  way,  any  of  the  Johnny Druoin’s  employee  file,  post-incident  drug  screening,  training  materials,  employee evaluations,  employee  write  ups,  and/or  any  documents  related to discipline levied against the truck driver;
• Destroying or tampering with any of the records or documents or any material item whatsoever that pertain to the incident made the basis of this lawsuit;
• Damaging, modifying, altering, selling or disposing of, in any way, the electronic data, the truck driver’s cell phone data, GPS data, video or audio recordings, PeopleNet data associated with the subject truck, and Qualcomm data associated with the subject truck;
• Damaging,  modifying,  altering,  selling  or  disposing  of,  in  any  way,  any  of  witness statements collected as a result of this incident;
• Damaging,  modifying,  altering,  selling  or  disposing  of,  in  any  way,  the truck driver' cell phone or other wireless devices;
• Damaging, modifying, altering, selling or disposing of, in any way, the log books, pre and post trip inspections, bills of lading, work orders, maintenance documents, gas receipts, and
• Damaging, modifying, altering, selling or disposing of, in any way, any data recording devices or modules in the tractor and/or trailer involved in this incident.

Knowing that some trucking companies regularly hide and/or alter evidence following a catastrophic incident, Amanda and The Alfred Firm’s paralegals took these immediate steps in investigating the trucking company and driver. The restraining order and all requested relief was granted by a Harris County judge.

Step 4: The Alfred Firm’s Paralegal Team Investigated Other Potential Targets Due to the Catastrophic Damage and Fatalities

In catastrophic 18-wheeler wreck cases it is important to investigate all potential angles of the case. In this case, we knew the 18 wheeler truck crashed head on into our client’s vehicle and that the vehicle caught fire.

Having worked with a team of renowned cause and origin fire experts in one of the most deadly apartment fires, Chief of Staff Amanda Zubire immediately contacted the expert to discuss the details of the case, and what we needed. 

The first step was to have the expert photograph and inspect the vehicle and, in order to accomplish this, The Alfred Firm’s paralegals found out where the vehicle was being stored. After identifying the tow yard from the police report, Amanda contacted the tow yard to determine what permissions our expert fire investigators needed to inspect and photograph the vehicle. The vehicle, which had already been sent to auction by the insurance company, was located and The Alfred Firm’s Paralegals were able to coordinate with the expert cause and origin investigators to inspect the involved vehicles.

This investigation was led by The Alfred Firm’s Chief of Staff and Head Paralegal, Amanda Zubire.

Amanda Zubire is the Chief of Staff/Head Paralegal at The Alfred Firm. Amongst the top paralegals in the country, Amanda has been Byron Alfred’s Senior Paralegal and Case Manager since 2015.

As Chief of Staff, Amanda contributes to all of The Alfred Firm’s business objectives, provides direct support in discovery for all catastrophic injury cases, manages all staff level team members, and is the point person for productivity and client relations – based initiatives. 

Amanda has been lead paralegal in all of Attorney Byron’s jury trials since 2015 and, together, they have never lost a jury trial.  In September 2018, Amanda was the lead paralegal on the case where the jury awarded a $44,370,000 verdict for the family of a rigger who died in a crane accident. This verdict was the #1 ranked work injury verdict in Texas in 2018 and a Top 10 Work Accident Verdicts in the United States in 2018.

Amanda is a 2014 Graduate of the University of Houston.