"In premises litigation, use Rule 30 (Deposition of Organization). Find who in the corporation knows what you want to know, and what they know! Get the defendant doing the work and handing it to you."
"Use a hard-hitting and detailed notice of deposition of the premises liability defendant organization. Disconcert your opposition. Make your discovery smarter and better."
Seven page, single spaced, legal form for Notice of Taking Deposition of an Organization form (plus seven page of law summary and tactical tips for you). Written only for the benefit of attorneys on one side of a lawsuit (plaintiffs), and only for one class of cases (premises liability).
For the purpose of using this form, consider “premises liability cases” to be any case involving an accident occurring on the premises of the defendant corporation. It could be a slip and fall case. It could be an assault by a security guard that gives rise to the case. It could be a case of machinery that injures your client. It could be an injury from fire on the premises. Any case involving an accident on the real estate of the defendant — these are the cases where you save hours of time and get a superior plaintiff's notice to nail the defendant.
If you have done a couple of depositions as a plaintiff in a premises case you understand the major importance of using a seven page, comprehensive form to draft the notice of taking the deposition of an organization. Do not start drafting that form yourself “off the top of your head”. Our form will save you hours of work and give you a superior work product. It is more complete than you could draft in hours of work! It is time tested to get you the witness you want to get, with the witness able to give you the information you want to get.
Because most premises liability defendants are corporations there is a special problem for a plaintiff in taking depositions of the defendant. That special problem arises because initially you do not know all of the possible sources of information that are within that organization. You don't want to play the defendant's shell game where they never tell you the employee or document that has the information you need to win. The defendant wants you to blindly take depositions of "likely" employees.
Your problem is aggravated not by the Federal Rule 30(a) which now limits you to ten depositions in the case. (Most states have similar deposition limitations.) You cannot just plow around taking multiple depositions and use up your limit without getting to the core fact or witness.
The solution to the problem is the deposition of the organization. Not the deposition of the president. Not the deposition of the manager. The deposition of the defendant premises liability organization.
It boils down to the fact that a Federal Rule 30 (b)(6) deposition (most states have a similar rule) is the most efficient way of gathering from a corporation the initial facts within several broad categories.
You can maximize your tactical and psychological advantage by a multi-page, comprehensive, well-drafted, notice of taking deposition of the organization. You know that. But it takes a lot of time to really get a form notice of taking deposition that really does what you want.
What if I could hand a form notice that would relieve you of a large chunk of preparation time in drafting a killer notice of deposition of that opposition corporation? And what if this simple item would be easy and inexpensive to buy? And what if it works for all your slip and fall cases, your premises security cases, your property fire and explosion cases, and for any of your cases that involve an accident on the real property o the defendant
Here is more great news -- Notice of Deposition of Organization is furnished to you, in PDF format, right to your computer, as the closing part of your purchase. If you are counsel with a premises liability case, buy now the Notice of Deposition of Organization, and put the defendant on the defensive right now!
For the plaintiff's attorney, the form shows the areas and questions which you want to investigate. We have additional forms for premises liability cases, but this form is the first one a plaintiff's lawyer should use. Notice of Deposition of Organization should be -- and will be -- used in all your premises liability personal injury cases, as a first step..
A real value for the time it saves you! You cannot dictate a first draft yourself for what this battle-tested form costs. Notice of Deposition of Organization is a very low investment with a high value return.
A good checklist is a lawyer mentor in a box --- guiding you and preventing mistakes. Good forms assure that you have thought about the core items to be asked during discovery. Good forms assure that you leave a deposition you have taken of an adverse witness knowing that you did not forget to ask questions on the subjects that needed discovery. This peace of mind is the most important reason for preparing for a deposition by starting with a form.
You have everything to gain and nothing to lose by using the Notice of Deposition of Organization the next time you have a plaintiff's persona injury case.
don't have to worry about getting your money's worth because if you are not delighted,
you're completely protected by my 100%, No Questions Asked, Money Back Guarantee
You have nothing to lose.
IMPORTANT: Let me recap. . .
If Notice of Deposition of Organization saves you just one hour of time - ever - it will have paid for itself many times over. Attorneys who are using our forms right now are saving themselves hours every month.