The email address cannot be subscribed. Knowledge of all memoranda, policies, procedures or correspondence given or sent to Defendant Rolfes about the falsification of records during their engagements with Jones Supply. Knowledge of all documents relating to any disqualification of Defendant Dughly made pursuant to any Federal Motor Carrier Safety Regulation. State ex rel. We serve the following localities: Baltimore; Prince George's County including Bowie, Laurel, Landover, Hyattsville; Anne Arundel County including Glen Burnie; Baltimore County including Cockeysville, Glyndon, Hunt Valley, Jacksonville, Lutherville-Timonium, Owings Mills, Parkville, Reisterstown, Plaintiff Attorney Legal Information Center, Example Pretrial Documents for Plaintiff's Lawyers, Example Deposition Transcripts and Outlines. This specifically includes all the driver daily vehicle inspection reports (DVIRs), maintenance files and records maintained by any other person(s) or organization(s) that are in the possession of Defendant Rolfes. (1) Without Leave. (2) With Leave. See CCP 2025.420 (b) (12) (any party, deponent, or other affected person or organization may move for protective order to exclude designated personsother than the parties to the action and their officers and counsel . The Missouri General Assembly recently enacted changes to the discovery rules, which became effective on August 28, 2019. Such depositions have a number of distinct characteristics and contain traps for the unwary. Initially, trial judges have great discretion in controlling litigation. 0000005124 00000 n Knowledge of any photographs taken of the tractor-trailer operated by Defendant Dughly at the scene of the incident, or any time after. Baylor University | A Nationally Ranked Christian University . Knowledge of any and all documents setting forth any policies, procedures, guidelines, recommendations or directives regarding driver conduct, driver safety, driver hiring, subcontractor hiring, commercial carrier hiring, discipline or firing prepared or used by Defendant Jones Supply during the five (5) year period prior to the subject incident and through the present date, together with all amendments, revisions or supplements thereto. All Rule 30(b)(6 . 11-80818-MC, 2011 WL 13228574, *4 (S.D. Corporate officers who cannot meet the Rule 1.280(h) test (or choose not to do so) remain free to . SKU: LIT6400. Fl. All rights reserved. Knowledge of each annual review of Defendant Rolfes's safety and fitness to haul on behalf of Defendant Jones Supply. Copyright 2023, Thomson Reuters. : NOTICE OF VIDEOTAPED DEPOSITION OF CORPORATE REPRESENTATIVE FOR Jones Supply COMPANY, LP. 45 0 obj <> endobj 608, 51 S.W.2d 13, 16 (1932)). [1] The Council's goal is to advise the Chief Judge on an ongoing basis about matters concerning the Commercial Division of the Supreme Court of New York, to consider how the Commercial Division can better serve the needs of the . xref It's time to renew your membership and keep access to free CLE, valuable publications and more. Knowledge of Defendant Dughly's trip reports, daily loads delivered or picked up reports or any otherwise titled or described work reports, work schedule reports, fuel purchased reports, or any other reports made by Defendant Dughly to Defendant Rolfes and/or Jones Supply, inclusive of daily, weekly or monthly cargo transported, time and/or distance traveled reports or work records excluding only those documents known as "driver's daily logs or driver's record of duty status" for the month of the incident. I. (a) Unless the court orders otherwise under Section 2025.260, the deposition of a natural person, whether or not a party to the action, shall be taken at a place that is, at the option of the party giving notice of the deposition, either within 75 miles of the deponent's residence, or within the county where the action is pending and . 0000003586 00000 n This request specifically includes each out of service report or violation concerning each leased power unit or trailer utilized, maintained, or controlled by this defendant from the year prior to the collision through the present. Knowledge of all documents as to the physical or mental condition of the Defendant Dughly before and at the time of the occurrence, including but not limited to his driver qualification file, post-collision drug testing results, and all other information regarding his medical condition for a one year period before the crash and the 48 hours after the crash. I also understand that Miller & Zois works with multiple law firms on these claims and that I may be contacted by an affiliated law firm working with Miller & Zois on these lawsuits. Knowledge of all documents regarding the Defendant Rolfes, including Defendant Rolfes's safety rating, authority, insurance information and/or BASIC scores. Knowledge of any and all documents relating to any investigation performed by Defendant Jones Supply concerning Defendant Dughly's safety rating, safety fitness, Federal Motor Carrier Safety Administration's safety measurement system, behavioral analyst and safety improvement categories (BASICs), including unsafe driving, hours of service compliance, driver fitness, controlled substances/alcohol, vehicle accidents, list of crashes, roadside inspections and commercial vehicle violations prior to the date of the subject collision. However, there are a number of different rules which do come into play on this issue. Learn more about FindLaws newsletters, including our terms of use and privacy policy. Knowledge of any compensation from Jones Supply to Defendant Dughly (or any other Rolfes driver), including any bonuses and/or discounts on Jones Supply products. Knowledge of any and all letters, writings, memoranda, or any other documents which reflect or contain the resignation or termination of the employment or contractual relationship of Defendant Rolfes with Defendant Jones Supply. Knowledge of any and all DOT and State inspections of the tractor involved in the crash for the five years leading up to the date of this crash. Taking of depositions; corporate officers. Can the person designated as the corporate representative for appearance purposes only be protected from being called by the opposing side as an adverse witness in his or her capacity as a corporate representative? Rule 57.05 - Persons Before Whom Depositions May Be Taken. Eastern District of Missouri, the Initial Scheduling Conferences held on March 28, 2018, and April 18, 2018, and the Court's May 8, 2018Order A, llowing Consolidated Master . Knowledge of any and all documents relating to any investigation performed by Defendant Jones Supply concerning Defendant Rolfes's safety rating, safety fitness, Federal Motor Carrier Safety Administration's safety measurement system, behavioral analyst and safety improvement categories (BASICs), including unsafe driving, hours of service compliance, driver fitness, controlled substances/alcohol, vehicle accidents, list of crashes, roadside inspections and commercial vehicle violations prior to the date of the subject collision. a prior corporate representative deposition transcript and offer that in lieu of an actual deposition. This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply. Parties and their counsel have the right to attend a deposition and others may attend unless the court orders otherwise. Knowledge of each traffic citation, FBMCS terminal or road equipment and driver compliance inspection, warning and/or citation issued to Defendant Rolfes and/or Dughly by any city, county, state federal agency or law enforcement official. 0000003033 00000 n Sample 30(B)(6) Deposition - List of Documents to be Produced by Defendant. This specifically includes readable and complete copies of bills of lading, manifest, or other documents regardless of form or description, that show signed receipts for cargo pickup and delivered along with any other type of document that may show dates and times of cargo pickup or delivery that are relative to operations and cargo transported by Defendant Dughly on the date of the incident. HW]o6}03")PXtK]>{`dV'>~,+h4%so\-n!o]/`vF/K\w*mnW@V 7U$` l?nB\j5GWkH/Pz ,%$J!$dSAf_}Hi gHYgHrs>IRP nyHDYzFU~Y$D*OS&[QA endstream endobj 46 0 obj <> endobj 47 0 obj <> endobj 48 0 obj <>/ColorSpace<>/Font<>/ProcSet[/PDF/Text/ImageC]/ExtGState<>>> endobj 49 0 obj <> endobj 50 0 obj <> endobj 51 0 obj <> endobj 52 0 obj <> endobj 53 0 obj <> endobj 54 0 obj [/ICCBased 63 0 R] endobj 55 0 obj <> endobj 56 0 obj <> endobj 57 0 obj <> endobj 58 0 obj <> endobj 59 0 obj <>stream See Penn Mutual Life Ins. MICHAEL THOMAS MARTINEZ, II, et al. Knowledge of all e-mail or text messages sent by or to Defendant Dughly from Defendant Rolfes (including its agents, employees, dispatchers) for the seven days prior to the incident and the date of the incident. In that case, the plaintiffs Rule 30(b)(6) notice listed 41 broad areas of inquiry. 0000001118 00000 n Knowledge of all documents relating to traffic accidents involving Defendant Dughly, including logbook and hours of service violations and other regulatory violations for the duration of the driver's engagement with Rolfes. 39 at 5. Knowledge of all training or instructional videotapes, CDs or DVDs used by any Defendant Jones Supply in its training any of its drivers at any time during the five years before the occurrence. A deposition is a powerful litigation tool for several reasons. Knowledge of any photograph, media coverage, film, videotape, moving pictures, electronic image or recording, or any audiotape which contains, constitutes or depicts any surveillance video, photographs, or recording related to any party (including plaintiff), or the scene (you may exclude from your response hereto any item which you have produced in response to any previous request herein). Particularly if the designated representative had little or no involvement in the events underlying the litigation, the corporations attorney should be prepared to fight any attempt to call the designated representative as an adverse witness, at least in his or her capacity as a corporate representative, by insisting that the designated person not be allowed to be called unless specifically identified on a witness list and, if the person is so identified, relying on arguments of relevance and unfair prejudice. In a recent decision, a Florida appellate court discussed why we have rules allowing for corporate entities to designate corporate representatives to speak for them, and the implications of failing to utilize the designated procedures properly. . 8.01-420.4:1. The principle underlying this argument is that only the corporation has the authority to designate particular representatives to speak on its behalf and bind it with respect to particular subject areas. When you take a corporate-representative deposition, how closely must your questions be correlated to the topics in your deposition notice? You are hereby notified that Plaintiff, Taylor Martinez, by and through her attorneys, Ronald V. Miller, Jr., Laura G. Zois, Esq., Justin P. Zuber, Esq., and Miller & Zois, LLC, pursuant to the Maryland Rules of Procedure 2-412 and 2-416, will take the deposition upon oral examination, for use in discovery and at trial, of the following persons on the date and at the time indicated below before a person duly authorized to administer an oath under Maryland law to be recorded stenographically/audio/videotape. Knowledge of the driver manual, company handbook, or their equivalent issued to Defendant Rolfes and Dughly by Jones Supply. Wright and Miller's Federal Practice and Procedure suggests that corporate answers, in a Rule 30(b)(6) deposition are binding on it.14 Of course, the testimony of the representative who speaks for the corporation is certainly admissible, however the question of whether or not it forecloses other and potentially contrary testimony is not . 1. Sept. 6, 2018). Copyright 2018, American Bar Association. Stay up-to-date with how the law affects your life. Knowledge of any statements, written, audiotaped, or otherwise recorded or memorialized of any of the parties or witnesses to the incident. See, e.g., King v. Pratt & Whitney, 161 F.R.D. To avoid this possibility, defendants should move to strike any vague or generic listings of witnesses prior to trial. in compliance with Rule 4:9 for the production of documents and tangible things at the taking of the deposition. Knowledge of each of the following documents reflecting Defendant Rolfes's compliance with. DEPONENT: Corporate Representative for Jones SupplyCompany, LPDATE:Friday March 5, 2021TIME: 10:00 a.m.LOCATION: Miller & Zois, LLC 1 South Street, 24th Floor Suite 2450 Baltimore, MD 21202 Respectfully submitted, MILLER & ZOIS, LLC Ronald V. Miller, Jr. 1 South Street, 24th Floor Suite 2450 Baltimore, MD 21202 Phone: 410-553-6000 Fax: 844-712-5151, Attorneys for the Plaintiff Taylor D. Martinez and the Estate of Abigail Martinez, A. In some instances, the appearance corporate representative also serves as the corporate representative under Federal Rule of Civil Procedure 30(b) (6). Knowledge of the entire file for Defendant Rolfes. :Plaintiffs, :v. : Case No. Knowledge of any primary, umbrella, and excess insurance policy, or agreement, including the declarations page, for Defendant Rolfes, Defendant Dughly, and Defendant Jones Supply, which was in effect at the time of this incident. . The electrical box was on Defendant's premises. <]>> 246) Plaintiffs requested a telephone conference with the Court to discuss whether Defendant Washington University should be allowed to not designate a representative to discuss three topics of rule 1.310(c), the court in which the action is pending or the circuit court where the deposition is being taken may order the officer conducting the examination to cease forthwith from taking the deposition or may limit the scope and manner of the taking of the deposition under rule 1.280(c). Knowledge of each out of service report or violation concerning any tractor or trailer in the possession of Defendant Rolfes for 5 years prior to the collision through the present, to include copies of any supplements, responses, or amendment to the same. P. 30(b)(6). Nonetheless, the corporate representative testified that she had no personal knowledge of decedent's fall or the presence of the electrical box. Rule 30(b)(6) is not designed to be a memory contest, and a deponent does not have to successfully answer every question posed by the opposing party to complete a deposition. representatives. R.R. While this reasoning has some intuitive appeal, there is no rule which specifically supports it. Therefore, the defendants witnesses should be familiar with the expected trial testimony of the other sides witness and it is not necessarily critical that they be present in the courtroom and subject to being called as an adverse witness. Rule 57.07 - Use of Depositions in Court Proceedings. Knowledge of each Defendant Jones Supply employee who investigated Defendant Rolfes's fitness to haul on behalf of Jones Supply prior to the date of the subject collision (this includes the initial investigation and any subsequent investigations, whether annually, bi-annually, etc.). endstream endobj 101 0 obj<>/Size 85/Type/XRef>>stream Knowledge of all documents constituting, commemorating, or relating to any written instructions, orders, or advice given to Defendant Rolfes and/or Dughly in reference to cargo transported, routes to travel, locations to purchase fuel, cargo pickup or delivery times issued by Jones Supply from five (5) years prior to and including date of loss. (a) When Depositions May Be Taken. TermsPrivacyDisclaimerCookiesDo Not Sell My Information, Begin typing to search, use arrow keys to navigate, use enter to select, Stay up-to-date with FindLaw's newsletter for legal professionals. 85 18 After being served with a notice of deposition, the organization shall designate a corporate representative to testify on its behalf. Knowledge of all records and reports of audits performed by the Bureau of Motor Carrier Safety or by any other state or federal agencies for Defendant Rolfes and/or Dughly. The Illinois Supreme Court rule is similar to the Federal Rule 30(b)(6). Knowledge of the job description of the position that Defendant Dughly was initially hired, employed or retained to perform for Defendant Rolfes. info@spsr-law.com Knowledge of the job description of the position or job that Defendant Rolfes was performing as a commercial carrier for Defendant Jones Supply at the time of the incident if such exists. International registration plan receipts; International fuel tax agreement receipts; Commercial Vehicle Safety Alliance reports; Overweight/oversize reports and citations; And/or other documents directly related to the motor carrier's operation which are retained by the motor carrier in connection with the operation of its transportation business. The issue in this writ proceeding is whether a corporate representative designated for deposition pursuant to Rule 57.03(b)(4) can limit his or her deposition testimony to personal knowledge instead of testifying about facts that are known or reasonably available to the organization. trailer Rules Governing Civil Procedure in the Circuit Courts, Rule 57 - Interrogatories and Depositions, Rule 57.02 - Depositions Before Action or Pending Appeal, Rule 57.03 - Depositions Upon Oral Examination, Rule 57.04 - Depositions upon Written Questions, Rule 57.05 - Persons Before Whom Depositions May Be Taken, Rule 57.06 - Presiding Officer for Deposition, Rule 57.07 - Use of Depositions in Court Proceedings, Rule 57.08 - Depositions for Use in Foreign Jurisdictions, Rule 57.09 - Subpoena for Taking Deposition. Relator alleged that her husband die d as a result of injuries sustained when he tripped over an unmarked electrical box located on the floor of a rehabilitation facility owned by Defendant. In light of the rules' requirement that the deposing party must identify the subject areas of the deposition, to some degree the element of surprise is removed from a corporate designee deposition. Knowledge of every federal, state, county, municipal, insurer and/or internal motor carrier collision report or other collision reports concerning all collisions in which Defendant Rolfes (or one of Rolfes's drivers) has been involved, including the collision at issue in this cause and all collisions prior to the collision at issue in this cause, pursuant to Federal Motor Carrier Safety Regulation 390.15(b)(1) and 390.1 5(b)(2). Knowledge of any job, driver, independent contractor, and/or employment application filled out or signed by Defendant Rolfes. If the individual has knowledge of some areas, then the questioning should be limited to those areas. The deposition will be recorded via stenographic, audio, and/or videotaped means for the purpose of discovery and/or used as evidence and/or any other purposes permitted by the Maryland Rules of Civil Procedure, including use at trial, and will continue day to day until completed. The rules of evidence also permit the trial judge to exclude irrelevant evidence or evidence which, while relevant, would be unfairly prejudicial. Knowledge of all road and written test certificates issued by Defendant Rolfes or any other motor carrier or organization to Defendant Dughly regardless of the date issued or the originator of such certificates. v. O'Malley, 888 S.W.2d 760, 761 (Mo.App.1994)). 0000028120 00000 n P. 57.03(b)(4). Knowledge of any documentation evidencing the completion or non-completion of training programs, safe driving programs, and driver orientation programs by Defendant Rolfes for Defendant Jones Supply. During discovery, plaintiffs notice a Rule 30 (b) (6) deposition of your client's representative, but elect to forgo the deposition in exchange for negligible admissions filed by your client. See TEX. remain stationary in remote depositions. Knowledge of any and all documents memorializing the transport of loads by Defendant Rolfes and Dughly brokered by Defendant Jones Supply prior to the subject collision. However, a smart plaintiff attorney can defeat this strategy by calling that person as an adverse witness before putting on the plaintiffs key witnesses. 1. Please do not include any confidential or sensitive information in a contact form, text message, or voicemail. They quite literally worked as hard as if not harder than the doctors to save our lives. Knowledge of the entire personnel file of Defendant Dughly. xbbb`b``I j Rule 57.03(b)(4) provides that a party may name a corporation, agency or other organization as the deponent. P. 30(c)(1), and in many jurisdictions, it is at least an open question as to whether deposition witnesses can be sequestered in the course of pretrial proceedings, with many attorneys taking the position that it does not apply. 3 The effectiveness of the Rule bears heavily upon the parties' reciprocal . Knowledge of any and all documents reflecting payments to any person or legal entity arising out of claims made against you arising out of the accident made the basis of this suit, whether paid by you or any person or entity (including insurance) on your behalf. Insurance Company, because: (1) Plaintiff's amended corporate representative deposition notice improperly expanded the areas of testimony and added a duces tecum; (2) the corporate representative topics are vague and not limited in time; and (3) Plaintiff has still failed to withdraw th e Opdyke deposition notice." Dkt. Knowledge of any vehicle inspection report for the tractor or the trailer made by any person, company or agency during the five years before the incident and including the date of the incident. Specifically, produce the supporting documents listed below which the Defendant Rolfes is required to maintain under 49 CFR 395.8(k) and to preserve under 49 CFR 379 (including Appendix A, Note A). The issue in this writ proceeding is whether a corporate representative designated for deposition pursuant to Rule 57.03 (b) (4) can limit his or her deposition testimony to personal knowledge instead of testifying about facts that are known or reasonably available to the organization. %PDF-1.4 % Casetext, Inc. and Casetext are not a law firm and do not provide legal advice. Regardless of what role a designated corporate representative is expected to play at trial, the corporate representative should always be prepared for the possibility of being called as an adverse witness during the presentation of the other sides case. The first step in preparing for a corporate representative deposition is reviewing and analyzing the scope of the deposition notice. Be unfairly prejudicial to testify on its behalf are a number of distinct characteristics and contain for. Can not meet the Rule 1.280 ( h ) test ( or choose not to so... 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