2

Request for a Protective Order

3. Pursuant to Illinois Supreme Court Rule 201(c), the Court may enter an Order to
preserve documents and other evidence that is relevant to this case.
4. It is vital to Plaintiffs claims against Defendants, and possible claims against
responsible entities other than these named Defendants, that evidence, including the Bus and all
data recorders, video recorders, and component parts of the Bus, be preserved and that Plaintiffs
counsel and their consultants and experts be allowed to inspect and photograph this evidence.
5. Plaintiffs believe that the entry of this Order is necessary to ensure that vital
evidence is not lost, destroyed, or otherwise altered and is preserved for discovery in this matter.
WHEREFORE, Plaintiffs pray that the Court enter an Order:
a. Precluding Defendants or their agents from altering, repairing, or
disposing of the Bus, data recorders, video recorders, radio transmissions,
and any and all component parts of the Bus, without first obtaining
consent of this Court.

b. Precluding Defendants from altering or disposing of other evidence
relating to the Incident, including but not limited to: (1) service and
maintenance records of the Bus and any and all component parts of the
Bus; (2) all data recorders and video recorders on the Bus; (3) all radio
transmissions and transcripts of radio transmissions; (4) all cell phone
records, text messages, or other messages sent on mobile devices by
Defendants employees, contractors, and/or agents regarding the Incident;
(5) the personal cell phone or other mobile devices of all persons who
were driving the Bus on its route from Atlanta to Chicago; (6) driver
schedules, driver logs, driver employment records, driver qualification
records; and (7) any other documents regarding the Bus, data recorders,
video recorders, or any of their component parts, without first obtaining
the consent of this Court.

c. Permitting Plaintiffs, by her attorneys or their agents, consultants, and
experts to inspect and photograph the Bus, data recorders, video recorders,
and any and all component parts of the Bus, within a reasonable time.