0000024346 00000 n This is to include all documentation relative to a compliance review and/or safety review; In the absence of a safety rating, please produce a copy of the Motor Carrier Identification Report, form MCS-150, filed in accordance with. Knowledge of all correspondence writings and/or documents sent by Defendant Jones Supply to Defendant Rolfes regarding disciplinary action or suspension or termination of contracts. Knowledge of all payroll, compensation, incentive pay for Defendant Dughly for work performed covering the 5 years preceding the collision and including the date of the collision. P : 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 all driver call-in records, notes, logs or e-mail indicating communications between Defendant Rolfes and Defendant Dughly for the seven days prior to the incident and om the date of the incident. 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. The person being deposed is under oath and must answer all questions posed by the deposing attorney. Knowledge of all accident and/or incident reports and investigations prepared by Defendant Rolfes (prepared prior to any litigation) as a result of the crash other than the police report. representatives. 6 Theoretically . Many states also have similar rules providing a mechanism for deposing a corporation or other company Copyright 2023, Thomson Reuters. 0000001181 00000 n 0000001118 00000 n 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. 0000002757 00000 n As interpreted by many courts, Rule 30 (b) (6) imposes no obligation to reveal the identity of the corporate designee to testify until the 30 (b) (6) deposition actually takes place. The Court denied the plaintiffs motion. 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. In some instances, the appearance corporate representative also serves as the corporate representative under Federal Rule of Civil Procedure 30(b) (6). Knowledge of all documents reflecting any background check performed on Defendant Dughly with regard to his criminal history. Federal Rule of Evidence 615 does state that witnesses must be excluded at a party's request, but according to Rule 30(c) of the Federal Rules of Civil Procedure, "[t]he examination and cross . Knowledge of all documents reflecting any background check performed on Defendant Dughly with regard to his driver's record (including but not limited to traffic tickets, incidents, and prior employment as a driver). Knowledge of the entire file for Defendant Rolfes. (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 . Knowledge of any compensation from Jones Supply to Rolfes, including any bonuses and/or discounts on Jones Supply products. 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. banc 1994). Knowledge of all documents concerning any bills, attorney's fees, court costs, expenses, expert fees, formal or informal, that reduce the amount of liability insurance available to cover the Plaintiff. 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. 1999); Crimm v. Missouri Pac. 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. Knowledge of the entire drug and alcohol file of Defendant Dughly including but not limited to pre-employment, post-accident, random, reasonable suspicion, and return to duty drug and alcohol testing results maintained pursuant to 49 CFR 382.401, preserved pursuant to 49 CFR 379 (including Appendix A, Note A), and released pursuant to 49 CFR 40.323. When you take a corporate-representative deposition, how closely must your questions be correlated to the topics in your deposition notice? A party may, by oral questions, depose any person, including a party, without leave of court except as provided in Rule 30 (a) (2). The rule has two basic requirements. (a) When Depositions May Be Taken. Knowledge of all maintenance files and records from at least one year prior to accident maintained by Defendant Rolfes in accordance 49 CFR 396 on the truck tractor involved in the accident inclusive of any inspections, repairs or maintenance done to the tractor tractor. 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. . 0000002069 00000 n This would include any subcontractor agreements, commercial carrier agreements, broker agreements, and any agreements for Jones Supply to affix its logo to a Rolfes truck, including, but not limited to, the truck involved in the incident. Instead, Rule 57.03(b)(4) required the representative to testify regarding the Defendant's knowledge of these matters. %PDF-1.4 % (6) A party may in his notice name as the deponent a public or private corporation or a partnership or association or governmental agency and designate Arnette maintained that Eberwein's knowledge of This would include anyone who investigated Defendant Rolfes's safety rating, safety fitness, Federal Motor Carrier Safety Administration's safety measurement system rating, behavioral analyst and safety improvement category (BASICs) score, unsafe driving history, hours of service compliance, drivers qualifications, drivers history with controlled substances/alcohol abuse, vehicle accidents, list of crashes, roadside inspections, maintenance history, compliance with Federal and State regulations, records keeping violations, and commercial vehicle violations prior to the date of the subject collision. | Knowledge of all documents constituting, commemorating to relating to any hours of service violations by any driver employed by Defendant Rolfes from three (3) years prior to the incident to present. Knowledge of the title related to the tractor. Knowledge of all safety ratings issued to Defendant Rolfes by any federal government agency for the five years preceding the incident. Knowledge of all road or test cards, medical cards, DOT physical examination log forms, motor carrier certification of driver qualification cards and any other motor carrier transportation-related cards in the possession of the Defendant Rolfes regardless of card issuance date or origin. Because Plaintiff's counsel filed the motion to compel after the parties scheduled the deposition of the one corporate representative, Defendant 70163. 7. Nonetheless, the corporate representative testified that she had no personal knowledge of decedent's fall or the presence of the electrical box. Knowledge of a copy of the registration and title to the vehicle involved in this occurrence. : NOTICE OF VIDEOTAPED DEPOSITION OF CORPORATE REPRESENTATIVE FOR Jones Supply COMPANY, LP. 0000001521 00000 n Missouri's amended Rule 56.01 (b) (1) will now limit the scope of discovery to information that is not only relevant but "proportional to the needs of the case.". Your corporate client just received a notice pursuant to Rule 30(b)(6) directing its corporate representative to be prepared to testify about every time a past, present, or future employee of the company sneezed over the last 15 years. A. Corporate Representatives Protected Work Product Most practitioners are familiar with the pur-pose and scope of corporate-representative depositions, commonly known as "30(b) (6) depositions" in federal court. 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. Sample 30(B)(6) Deposition - List of Documents to be Produced by Defendant. Rule 57.03 - Depositions Upon Oral Examination (a) When Depositions May Be Taken (1) After commencement of the action, any party may take the testimony of any person, including a party, by deposition upon oral examination without leave of court, except as specified in paragraph (2) of this subdivision. (2) With Leave. The circuit court abused its discretion by overruling Relator's motion to compel production of a substitute corporate representative prepared to testify regarding Defendant's organizational knowledge of the identified deposition topics.1 The alternative writ of mandamus is made peremptory. Knowledge of any and all incident, accident, or injury reports related to the incident that were prepared by Defendant Dughly, or by any employee, owner, or agent of Defendant Rolfes (prepared prior to any litigation). Knowledge of the entire driver investigation history file or its equivalent for Defendant Dughly maintained pursuant to 49 CFR 391.53 and preserved pursuant to 49 CFR 379 (including Appendix A, Note A). No. startxref Witness Selection A party seeking a deposition cannot demand or specify a particular officer, director, or employee for a Rule 30(b)(6) deposition because that privilege lies with the corporation. testify 'vicariously' at trial, as distinguished from at the Rule 30(b) (6) deposition, if the corporation makes the witness available at trial, he should not be able to refuse to testify to matters as to which he testified at the deposition on grounds that he had only corporate knowledge of the issues, not personal knowledge."8 With In any contested case before an agency created by the constitution or state statute, any party may take and use depositions in the same manner, upon and under the same conditions, and upon the same notice, as is or may hereafter be provided for with respect to the taking and using of depositions in civil actions in the circuit court; provided, See Lebron v. Royal Caribbean, 16-24687-CIV (S.D. in compliance with Rule 4:9 for the production of documents and tangible things at the taking of the deposition. 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 They quite literally worked as hard as if not harder than the doctors to save our lives. Knowledge of each out of service report or violation concerning the tractor or trailer involved in this incident from the year prior to the collision through the present, to include copies of any supplements, responses, or amendment to the same. 0000002753 00000 n 5 Yet, each designee's deposition is considered a separate deposition for the purpose of duration (i.e., seven hours in one day under Rule 30(d)(1)). Corporate representative witnesses shall be deposed where their principal office If the person designated as the appearance corporate representative is not listed by the plaintiff on its witness list, the plaintiff would normally be precluded from calling that corporate representative as an adverse witness for this reason alone. Knowledge of each rental or lease agreement related to the tractor or the trailer. In other words, the testimony of the corporate representative designated pursuant to Rule 57.03(b)(4) is not the deposition of that individual for his or her personal recollections or knowledge but is instead the deposition of the corporate defendant. Annin v. Bi-State Development Agency, 657 S.W.2d 382, 386 (Mo.App.1983). Introductory questions serve two purposes. 0000011392 00000 n Federal Rule of ivil Procedure 30(b)(6) is the vehicle for taking depositions of corporate representatives in civil cases. The rule which comes closest, and upon which the foregoing argument principally relies, is Rule 30(B)(6) of the Federal Rules of Civil Procedure and similar state rules. Knowledge of all disciplinary action contemplated or taken against Defendant Dughly involving the operation of the motor vehicle he was operating at the time of the collision. C. Motion to Compel Designation of Rule 30(b)(6) Designee (ECF No. R. Civ. Knowledge of each out of service report or violation concerning the tractor and trailer involved in this incident for the 5 years prior to this incident to the present, to include copies of any supplements, responses, or amendments to the same. 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. Knowledge of any employee handbook for Defendant Rolfes that was in effect at the time of the incident. Corinne Reif (Relator) filed a wrongful death action against Missouri Baptist Medical Center (Defendant). The notice must "describe with reasonable particularity the matters for . 0000003049 00000 n The Missouri General Assembly recently enacted changes to the discovery rules, which became effective on August 28, 2019. 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. The purpose of a writ of mandamus is to execute a clear, unequivocal and specific right, not to adjudicate. 102 0 obj<>stream 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 Knowledge of the job description of the position that Defendant Dughly was initially hired, employed or retained to perform for Defendant Rolfes. LA Knowledge of any agreement or requirement to place the Jones Supply logo on the tractor or trailer involved in this incident. Terry v. Holtkamp, 330 Mo. endstream endobj 101 0 obj<>/Size 85/Type/XRef>>stream :Plaintiffs, :v. : Case No. 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. Knowledge of all evaluations or criticism of the job performance of Defendant Dughly by Jones Supply, including but not limited to annual evaluations, interim evaluations, or specific incidents that gave rise to an evaluation or criticism. One purpose of Rule 57.03 (b) (4) is to permit a party to take the deposition of an opposing corporation's representative at a time when the party taking the deposition knows that the statements made by the witness on the identified topics will be admissible against and binding on the corporate party. Hopefully, you will be able to reach an amicable agreement about the reasonable bounds of the corporate representatives testimony. Deposition questions vary on a case-by-case basis, but introductory, background and deposition preparation questions are fairly standard across the board. In doing so, the court relied on three key principles: (1) Rule 30(b)(6) does not require a corporate representative to provide testimony regarding information that the corporation does not have, but rather requires an organization to testify about information known or reasonably available to the organization; (2) Rule 30(b)(6) does not require a deponent to testify with computer-like detail as to unreasonably broad topics; and (3) Rule 30(b)(6), pursuant to Federal Rule of Civil Procedure 26, does not require a deponent to be prepared to testify to matters that are not relevant to any party's claim or defense. SCR 206(a)(1) also grants subpoena power to depose a corporate representative who is a non-party to the case. Please do not include any confidential or sensitive information in a contact form, text message, or voicemail. This Court issued an alternative writ of mandamus. Such depositions are unique in many respects and contain traps for the unwary. Hopefully I won't need it again but if I do, I have definitely found my lawyer for life and I would definitely recommend this office to anyone! info@spsr-law.com The purpose of Rule 57.03(b)(4) is to permit a party to depose an opposing corporation's representative under circumstances in which the statements made by the witness on the identified topics will be admissible against and binding on the corporate party. Make your practice more effective and efficient with Casetexts legal research suite. Knowledge of any and all documents regarding any communications between Defendant Jones Supply and any Defendants, their agents or employees, concerning the load that was being transported by Defendant Rolfes and Dughly at the time of the collision. If the individual has knowledge of some areas, then the questioning should be limited to those areas. Nonetheless, the plaintiffs attorney may see this as an opportunity to call the representative as an adverse witness and force him or her to admit to lacking knowledge of all critical facts notwithstanding his or her status as the company representative. 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. 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 . %PDF-1.4 % Knowledge of all phone call logs, or correspondence reflecting complaints or criticisms of any kind received by Defendant Jones Supply from any source, including Jones Supply personnel, concerning the performance of Defendant Rolfes drivers while hauling for Defendant Jones Supply. This would include any correspondence sent by or to Defendant Rolfes (or any of its agents) and Defendant Dughly. 0000004190 00000 n A deposition can also be used to discover additional evidence to use at trial or discover information that can lead to admissible evidence. The case settled and I got a lot more money than I expected. This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply. 0000007631 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. Knowledge of any forms of reimbursement that was provided by Defendant Jones Supply to Defendant Rolfes drivers while hauling on behalf of Defendant 84 (this would include reimbursement for gasoline). 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 Dughly 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). Relator served Defendant with a notice requesting the deposition of a corporate representative. Corporations and other entities have unique obligations regarding the depositions of corporate designees pursuant to Federal Rule of Civil Procedure 30(b)(6) and its state cognate, Pennsylvania Rule of Civil Procedure 4007.1(e). 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. xref <]>> Atchison, Topeka & Santa Fe R.R. A Solution Is Born. Rule 57.05 - Persons Before Whom Depositions May Be Taken. All rights reserved. The entire team from the intake Samantha to the lawyer himself (Ron Miller) has been really approachable. Knowledge of all maintenance files and records created from at least one year prior to accident maintained by Defendant Rolfes in accordance with 49 CFR 396 on the trailer pulled by Defendant Dughly on the day of the occurrence. Defendant also argues that the circuit court properly overruled the motion to compel because the deposition topics included information subject to the attorney-client privilege and the work product doctrine. Knowledge of any documentation evidencing the completion or non-completion of training programs, safe driving programs, and driver orientation programs by Defendant Dughly for Defendant Rolfes. the appearance corporate representative is exempt from the sequestration of witnesses, thus enabling him or her to listen to all witness testimony. 0000004581 00000 n 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. Knowledge of all arrests and or/convictions of the Defendant Dughly. Federal Rule of Civil Procedure 26 (c) (1) (E) places the burden on the party seeking to exclude people from the deposition to move for a protective order "designating the persons who may be present while the discovery is conducted." Knowledge of the policies or procedures provided by Jones Supply to Rolfes, regarding safety, motor vehicle safety, travel policy, sleep and rest requirements, vehicle inspection, driver standards and hiring requirements that were in effect at the time of the incident, including, but not limited to driver safety manuals, driver safety operating procedures, driver safety training manuals/procedures/guidelines. Under FRCP 30 (b) (6) and ORCP 39 (c) (6) (collectively "Rule 30 (b) (6)"), a party to a lawsuit has the right to issue a notice for the deposition of a "public or private corporation, a partnership, an association, a governmental agency or other entity.". However, parties frequently include generic listings in their witness lists, such as references to a corporate representative of the defendant, or adopt the other partys witness list, which may be deemed sufficient to include the corporate representative designated for purposes of appearance at trial. Knowledge of all documents reflecting any background check performed on Defendant Dughly with regard to their employment history or job references, including letters of reference. Five (5) business days prior to any Rule 30(b)(6) deposition, the party that receives a notice of deposition pursuant to Rule 30(b)(6) shall provide via the MDL listservs the name(s) and title(s) of the witness or witnesses who will be providing testimony on that party's behalf, Yet the rule expressly permits properly designated corporate representatives to avoid sequestration and attend proceedings, even if they are fact witnesses. 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). 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. Initially, trial judges have great discretion in controlling litigation. I understand that submitting this form does not create an attorney-client relationship. The panel will also review the "meet and confer" requirement applicable when noticing a Rule 30(b)(6) deposition. Taking of depositions; corporate officers. Knowledge of all driver daily vehicle inspection reports (DVIRs) submitted by any driver(s) on the truck tractor from at least 30 days prior to the accident in the possession of Defendant Rolfes. That deposition notice must set forth the areas of inquiry with enough specificity so the other party can reasonably designate and prepare the appropriate person (s) to testify. 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). If the order terminates the Knowledge of all documents relating to any out of service records for the vehicle involved in this incident extending from the date of the incident and 5 years prior. /content/aba-cms-dotorg/en/groups/litigation/committees/pretrial-practice-discovery/practice/2018/adequately-preparing-a-corporate-representative-for-deposition. 0000027653 00000 n A designated representative who gives testimony under Illinois Supreme Court Rule 206(a) may not be contradicted by any other corporate representative at trial. 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. A party may in the notice and in a subpoena, if required, name as the deponent a public or private corporation or a partnership or association or governmental agency and describe with reasonable particularity the matters on which examination is requested. The contact form sends information by non-encrypted email, which is not secure. banc 1992). 0 0000000776 00000 n Knowledge of all mileage logs and travel reimbursement records for Defendant Dughly for the month of the incident. Knowledge of all driver's licenses and truck driver certifications which Defendant Dughly possesses (currently) and did possess on the date of the incident. Or, if the person designated as the representative had some involvement in the underlying events, the plaintiffs attorney may ask questions about areas in which the person had no involvement, again, for the purpose of eliciting admissions of no knowledge. The trial date is looming. Knowledge of all cellular telephone records and bills for any cellular telephone that was used by Defendant Dughly on the date of the incident and for the 3 days prior to the incident. Knowledge of the Defendant Jones Supply employees who were responsible for and played a role in negotiating and establishing the hauler relationship between Defendant Jones Supply and Defendant Rolfes. P. 1.310 (b) (6) and begin your discovery voyage. Are unique in many respects and contain traps for the five years preceding the incident Rule 57.03 ( b (... & Santa Fe R.R b ) ( 4 ) required the representative to testify regarding Defendant... Safety ratings issued to Defendant Rolfes by any federal government agency for the production of documents to be Produced Defendant... Representative testified that she had No personal knowledge of all arrests and or/convictions of the registration and title the! That she had No personal knowledge of some areas, then the questioning should be limited to areas... V. Bi-State Development agency, 657 S.W.2d 382, 386 ( Mo.App.1983 ) >! Then the questioning should be limited to those areas preceding the incident production of documents tangible! 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But introductory, background and deposition preparation questions are fairly standard across the board filed wrongful., or voicemail: notice of VIDEOTAPED deposition of a writ of is...
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