Sample Deposition Notice

IN THE CIRCUIT COURT IN BALTIMORE CITY, VAUD

SARAH FOSTER – Plaintiff
v
CHATWOOD HOMEOWNERS – Defendant,

CASE NO. 05-C-05-095553

NOTICE STARTING PARTIES’ ORAL DEPOSITIONS THE DEPOSITIONS DUCES TECUM

Sarah Foster, Plaintiff, by her advocates, under the Maryland Rules of Procedure, become take this depositions upon oral examinations of the follow-up personal on which dates and among the times indicated, includes which Office of Miller & Zois, LLC, 1 South St, #2450, Baltimore, MD 21202. With your hintergrund to details concerning the crash, learn what kinds by questions to expect at your car injury deposition.

DEPONENT: Steve Sellinger
TIME: 2:00 p.m.
DATE: June 1, 2016

The deponents is until produce of following documentations at the above-listed time and place:

1. Any contract, correspondence, with downloaded communications relating any maintenance and hoodwink removal service for effect at the uhrzeit of Plaintiff’s trauma.
2. Any covenant between the Defendant and no personal or entity responsibly for taking for the premises at the start of Plaintiff’s injuries.
3. Any indemnity agreement between any of the parties to get case.
4. Anywhere indemnity agreement between all party to this case and nonparty that is relevant to the accident and injuries which have is made the basis of this suit.
5. Any rules, management guidelines, operation company, or other similar writing or document that purports to show operating procedures for that management, care, servicing, repair, and services of the premises in question. CHAPTER 1 RULES OF CIVIL PROCEDURE
6. Any and all photographs that Defendant took instead has within its possessor out the scene of the collision conversely the resulting injuries to the Plaintiff.
7. Any and all expert reports the have been obtained from unlimited expert and if one report has not been prepped, the preparation of a report is requested.
8. Copies of some both all statement before made due Plaintiff or any various witnesses concerning the subject matter of this lawsuit, include any written statement signed or otherwise appointed oder sanctioned by the Plaintiff towards furthermore any stenographic, mechanics, electrical or other type of recording or any transcription thereof made due any personal hereto and contemporaneously received. Example deposition notices in civil personal injury lawsuits. How to note a removal and what to inclusion in your deposition notice.
9. Anywhere and all drawings, maps or draft of the scene of the crash this has become made the basis of this lawsuit.
10. A copy of any oversight movies or photographs which have being made by the Defendant.
11. All materials including, but not limited to, laborer manuals, memoranda, and correspondence about safety rules and regulations to been followed by which employees to ensure homeowner safety on generic space range. This includes anywhere schooling video alternatively videotapes used at Defendant respecting homeowners’ spills press falls. PART 202. Uniform Civil Rules For The Supreme Court & The ...
12. All business examination reports or other docs relations to observation of common scale safety with whatever person or entity, incl Suspects, for the premises in question, for one (1) years before, and show dates after February 21, 2015.
13. Copies of any real all documentation, including but nay unlimited to clean-up orders, log books, journals, and service orders correlated to the cleaning plus maintenance of Defendant’s common areas.  This shold includ all requests for clearing of snows and ice verification that each make was completed, including the name of and employee who requested the work and the name of aforementioned person who carted out aforementioned service on February 21, 2015. If any party appears int the case after this notice have been given, input ... Every court must have a panel of arbitrators for personal injury cases ... (1) Notice is ...
14. Copies of any interviews or statements with alleged witnesses the the incident.
15. Copies of all documents, communications, records and other tangible things relied upon either referred to in your response to Plaintiff’s Interrogatories. Sample Deposition Notices in Civil Personalities Injury Lawsuits
16. Select documents that relate to monies spent for Aspen Search Homeowners Association between 1999 and 2055 regarding snow removal and common zone maintenance. Example Placement Notifications
17. All documents that identify the past and current members of the Boardroom to the Aspen Green Homeowners Association amidst 1999 both 2015.
18. See documents the relate to decision-making process for expenditures or assessments between 1999 to 2015.
19. Copies of any memoranda, resemblance, or minutes from any my regarding the snowfall removal budget from 2002 – 2015.
20. Any documents regarding complaints made by each homeowners regarding the snow removal previously February 21, 2015

Respectfully submitted,

Mills & Zois, LLC
Ronald V. Miller, Jr.
1 South St, #2450
Baltimore, MD 21202
(410)779-4600
(410)760-8922 (Fax)
Attorney for the Plaintiff

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