You or your legal assistant or secretary will reach for this "Notice to Bring to the Deposition" legal form every time you set a deposition of an adverse driver or witness in a motor vehicle accident case.
Include this form as a part of your pre-deposition demands to the witness to get the half dozen physical items you always need from them. (Such as ALL items the witness used to refresh memory.)
I have found that a simple form cuts down the time waste and the excuses of the other side that he/she does not recall but might have something at home that would help. It seems to practically eliminate the problem of not having at the deposition everything the witness has to refresh his/her recollection of the car accident.
There are six classes of physical items that you want to see when you are taking the deposition of the adverse driver or witness. Like photos they took. And the diagram they made of the accident scene. So why not have a standard form of notice requiring these six classes of items to be brought to the deposition?
Insert this form into a subpoena duces tecum for a non-party driver witness, or into a formal demand for production for a party driver.
Sure, the other side is supposed to have disclosed the items or given them to you in response to interrogatories or other demands for production. But you know what happens many times. Step 1, the witness shows up at the deposition. Step 2, you ask the witness if there are any photos of his car except for the ones on the table in front of him. Step 3, the witness tells you he has a couple more at home he never gave the adverse attorney. (One of the time wasting events in a good attorney’s life is finding out that the adverse attorney was sloppy and really does not have or does not know that certain evidence exists - hence did not bring everything his client has to the deposition.). This form tells the driver to bring what he/she has!
More importantly - it practically eliminates your forgetting to ask for the existence of certain items that can help or hurt you. You use the form as a short checklist of some items to ask for at every motor vehicle accident driver and adverse witness deposition.
This Notice to Bring to the Deposition is so inexpensive that if it saves you ten minutes of time ---- ever ---- it would have paid for itself. But where you will really praise yourself for using this form is the first time it gets you pay dirt that allows a really good deposition of the witness, using the witness's own photos or diagrams.
You can own Notice to Bring to the Deposition for the price of only $6. It's one of those inexpensive, but handy and always used, items that make life easier.
You probably realize that it costs us about
$4 to get this $6 item to you, but we do not charge a handling fee for it. There is a reason we sell this
inexpensive but handy form. People who buy this item usually come back and buy other forms and
checklists from us. They realize our forms save time and are