Edward Ciarimboli · Joseph Camerlengo · Jay Vaughn

Does Amazon control the "manner and means" of its delivery operations? While Amazon frequently argues that Relay carriers and Delivery Service Partners (DSPs) are merely independent contractors, their own internal documents, dashboards, and agreements tell a different story.

We invite you to a rigorous 3-hour intensive workshop designed to arm plaintiff attorneys with the evidence needed to dismantle the "independent contractor" defense and establish Amazon’s direct control in personal injury and wrongful death crashes.

Strategic Deep Dive: What You Will Master

1. Technical Evidence of Control (The Flex App and Relay App)

• Mandatory Technology: Learn how to use Amazon's own documents and terms to prove that the Flex and Relay apps are mandatory tools for all DSPs/Carriers and drivers.
• Performance Monitoring: Identify the four key metrics—On Time, Acceptance, App Usage, and Disruption-Free—that Amazon uses to exert direct economic leverage over every trip.
• Real-Time Surveillance: Document how Amazon tracks geo-location, speed, and even weather events in real-time, giving them constructive notice of every risk on the road.

2. Dismantling the DSP "Shield"

• Near-Complete Control: Uncover evidence that Amazon dictates DSP employment applications, training materials, and even employee handbooks.
• The Power to Terminate: Show the jury that Amazon retains the unilateral right to discipline and fire DSP drivers without notice, a hallmark of an employer-employee relationship.
• Unsafe Time Pressures: Use Amazon's "exceedingly aggressive" time limits to explain why drivers are forced to make unsafe choices, like urinating in bottles, to meet delivery quotas.

3. Workshop Highlights

• Middle Mile/Relay Cases: Establishing control through the Amazon Relay App, Terms of Service and Program Policies
• Last Mile/Flex Cases: Establishing control through the Flex App, DSP Program Agreement, DSP Program Policies and DSP Operations Manual
• Discovery Strategies and tips for involving the Court to force the production of internal white papers, dashboards, spreadsheets and more.
• Agency: Navigating the nuances of the principal-agent relationship.

*This is a new offering as part of TLU’s Advanced Deposition Strategy and Practice training using Advance Deposition College faculty and authors Phillip H. Miller and Edward J. Ciarimboli, J. Vaughn, and Joseph V. Camerlengo.