This case takes place in Kentucky and involves an injury of a man as he helped unload a pallet of cargo off the liftgate of a truck. His manager had asked the plaintiff to assist in the unloading of a pallet of goods from a freight trailer while at the place of his employment. While in the process of unloading the trailer as per the instructions and under the direction of the defendant , the plaintiff was seriously and permanently injured. The project manager of the unloading facility failed to inform the plaintiff that the pallet was far heavier than the plaintiff had anticipated. The plaintiff alleges that the defendants were negligent in their duty to supervise their employees in a reasonably safe manner, as well as being negligent in the selection, hiring, training, and supervision of their management staff.
Question(s) For Expert Witness
- 1. What is your experience in setting safety policies/procedures for freight delivery services?
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2. Are there protocols set in place for employees that would further ensure the safety of the customers?
Expert Witness Response E-000398
I need to review the shipping documents and the company’s policies to see duties. I also need to review the company policy of the Plaintiff’s employer. Why wasn’t a pallet jack used on the pallet? I have worked on many loading & unloading cases. Also, I have 30 years in the transportation industry with practical experience in these situations.
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