Get a comprehensive notice of taking the deposition of a company that employed a driver. Determine the control, plus determine the independent negligence of the company. Six pages.
Notice of Taking Deposition of Company With List of Items to Bring to the Deposition and With Attached List of Subjects on Which Examination Is Sought
In every truck or car accident there is a driver. Some drivers are under the control of an employer or other entity sufficiently so that the entity is responsible under the doctrine of respondeat superior. In addition, negligence in hiring, in supervision, or training of the employee may be grounds for independent negligence of the entity.
Taking depositions of employees of an adverse corporation presents problems because initially you do not know all of the possible sources of information within that organization. Federal Rule of Civil Procedure 30(a) limits you to 10 depositions, and most states have similar limitations on the number of depositions. You cannot afford to wander in the dark taking multiple depositions.
The solution to the problem is the deposition of the organization. Under Federal Rule 30(b)(6) the corporation has a duty to produce and prepare sufficient the witnesses to give "complete, knowledgeable and binding answers" to all the subjects of which you give notice. You need a laundry list form to prepare a comprehensive list of subjects.
For motor vehicle accident cases, whether it be an 18 wheeler truck case or a two car automobile case, we have a form of notice of organization regarding the issues of control and of independent negligence of the employer.
Over the years, this form that also serves as a checklist -- notice to company of deposition regarding vehicle accident by driver -- will save you hours of depo and trial prep time. A real value for the time it saves you!
Before I had a set of comprehensive deposition checklists, for all the standard types of cases (and believe me, a motor vehicle accident, whether car, truck, or one auto accident, is "standard") I would spend hours getting my notes ready for a deposition. But --- after 35 years of litigation, I had developed wonderful checklists that I could whip out and be half way to final depo or trial question preparation. I had no trouble being fully prepared for most depositions in a motor vehicle case, sometimes in a half-hour.
This is a mentor in a box, coaching you on the points you should consider during your examination of the corporate defendant. (Or if you are the defense attorney, telling you the points on which you need to prepare your defendant.)
You don't have to worry about getting your money's worth because if you are not delighted, you're completely protected by my "100%, No Questions Asked, Money Back Guarantee!
Not only will you get a great deposition testimony preparation tool, saving you lots of time over the year ahead, you will get it for the special pricing of only $16.
You have everything to gain and nothing to lose by using the Notice of Taking Deposition of Corporation regarding Control of Driver Notice of Depo of Corporation re Control of Driver the next time you have a car or truck accident that invovles the employer of one of the drivers.
This is your invitation to become one of the attorneys who take advantage of this power litigation tool.
All the best,
Leonard Bucklin, Civil Trial Attorney
P.S. If Notice of Taking Deposition of Corporation regarding Control of Driver saves you just one - tenth hour of time - ever - it will have paid for itself. It's guaranteed to see you an hour of drafting, if you start from scratch. That's money in your pocket.
Our "100% money back, No Questions Asked, Guarantee."
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