Sample Notice of Deposition of Truck Driver

COLE TAYLOR, Individually and as
Personal Representative of the
Estate of Helena Cain, deceased
v.
PEGASUS TRUCKING, INC.
and
LEE ADAMA

Case No. CV-1701-2011

Notice is hereby given, pursuant to the Federal Rules of Civil Procedure, Rule 30, that Plaintiffs, by and through their attorneys, intend to take the videotaped deposition duces tecum of Defendant Lee Adama on oral examination before a notary public or some other person duly qualified to administer an oath, on Tuesday, March 21, 2006, at 10:00 a.m. at the offices of Posner & Cord, LLC, or at some other date and location mutually agreed upon, to be continued from day-to-day until completed.

The deponent is hereby notified to personally appear and attend at the time and place specified for the purposes of having his deposition taken in accordance with the foregoing Notice.

The deponent is also requested to bring the documents listed and described on the sheet attached as Attachment A.

Respectfully submitted,

POSNER & CORD, LLC

________________________________
John Cord
Attorneys for Plaintiff

Served with Complaint

The deponent is hereby notified to produce at the time of the deposition the following documents. As used in this Notice, the term “document” means, without limitation, the following items, whether printed or recorded or reproduced by any other mechanical process, or written or produced by hand: agreements, communications, state and federal governmental hearings and reports, correspondence, telegrams, memoranda, summaries or records of telephone conversations, summaries or records of personal conversations or interviews, diaries, graphs, reports, notebooks, note charts, plans, drawings, sketches, maps, summaries or records of meetings or conferences, summaries or reports of investigations or negotiations, opinions or reports of consultants, radiographs, photographs, motion picture film, brochures, pamphlets, advertisements, circulars, press releases, drafts, letters, any marginal comments appearing on any document, and all other writings.

1. Any and all documents which were demanded in Plaintiff’s First Request for Production of Documents to Lee Adama.
2. Any and all documents which relate or refer to the subject matter of this litigation.
3. Any and all documents which the deponent has reviewed at the request of counsel.
4. Any and all documents which the deponent has reviewed in preparation for the deposition.
5. A copy of the deponent’s Curriculum Vitae, if any.
6. Any and all documents pertaining to the employment history for Lee Adama at Pegasus Trucking, Inc., and Pegasus Trucking Services, Inc., including documents related to his hiring and supervision.
7. Any and all documents related to the licensing of Lee Adama to drive tractor-trailers or other vehicles.
8. Any and all documents pertaining to the education or training received by Lee Adama by or through Pegasus Trucking, Inc., and Pegasus Trucking Services, Inc.
9. Any and all documents or photographs referring to the care, maintenance, inspection, and condition of the truck involved in the collision with Helena Cain.