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.
"Best guarantee in the forms business." No questions. No
red tape. If you do not agree this
product is worth every penny, just ask for a refund in 60 days.
It's that easy. It's that quick. You keep our product, but get your
money back! In effect, you can try anything for Free!
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.
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