0000003049 00000 n subsequent motions for protection and to quash the deposition notice. Such a person is typically designated as the corporate representative for appearance purposes only. We serve the following localities: Baltimore; Prince George's County including Bowie, Laurel, Landover, Hyattsville; Anne Arundel County including Glen Burnie; Baltimore County including Cockeysville, Glyndon, Hunt Valley, Jacksonville, Lutherville-Timonium, Owings Mills, Parkville, Reisterstown, Plaintiff Attorney Legal Information Center, Example Pretrial Documents for Plaintiff's Lawyers, Example Deposition Transcripts and Outlines. This language mirrors the language of FRCP 26. SCR 206(a)(1) also grants subpoena power to depose a corporate representative who is a non-party to the case. LAW RELATING TO DEPOSITIONS OF CORPORATE DESIGNEES Rule 57(b)(4) provides that a party serving a deposition notice on a corporation must "describe with reasonable particularity the matters on which examination is requested." Mo. Please try again. Ron helped me find a clear path that ended with my foot healing and a settlement that was much more than I hope for. Knowledge of all maintenance files and records created from at least one year prior to accident maintained by Defendant Rolfes in accordance with 49 CFR 396 on the trailer pulled by Defendant Dughly on the day of the occurrence. Rule 57.03 - Depositions Upon Oral Examination (a) When Depositions May Be Taken (1) After commencement of the action, any party may take the testimony of any person, including a party, by deposition upon oral examination without leave of court, except as specified in paragraph (2) of this subdivision. In the alternative, the defendant can argue that the individual should be called only in his or her individual capacity so that a foundation can be laid to determine whether that persons testimony is binding on the defendant corporation. Federal Rule of Evidence 615 does state that witnesses must be excluded at a party's request, but according to Rule 30(c) of the Federal Rules of Civil Procedure, "[t]he examination and cross . Ron even fought to reduce how much I owed in medical bills so I could get an even larger settlement. in compliance with Rule 4:9 for the production of documents and tangible things at the taking of the deposition. Knowledge of any forms of reimbursement that was provided by Defendant Jones Supply to Defendant Rolfes drivers while hauling on behalf of Defendant 84 (this would include reimbursement for gasoline). Knowledge of all documents reflecting any background check performed on Defendant Rolfes with regard to their safety protocols, safety manuals, safety guidelines, and record keeping. Knowledge of any and all bills of lading, shipper documents and receipts for the load being hauled by Defendant Rolfes and Dughly at the time of the subject collision. In any contested case before an agency created by the constitution or state statute, any party may take and use depositions in the same manner, upon and under the same conditions, and upon the same notice, as is or may hereafter be provided for with respect to the taking and using of depositions in civil actions in the circuit court; provided, Such depositions are unique in many respects and contain traps for the unwary. (a) When Depositions May Be Taken. Copyright 2018, American Bar Association. TermsPrivacyDisclaimerCookiesDo Not Sell My Information, Begin typing to search, use arrow keys to navigate, use enter to select, Stay up-to-date with FindLaw's newsletter for legal professionals. There is no rule specifically addressing this issue. Knowledge of all documents regarding the Defendant Rolfes, including Defendant Rolfes's safety rating, authority, insurance information and/or BASIC scores. Or, if the person designated as the representative had some involvement in the underlying events, the plaintiffs attorney may ask questions about areas in which the person had no involvement, again, for the purpose of eliciting admissions of no knowledge. Knowledge of any job, driver, independent contractor, and/or employment application filled out or signed by Defendant Dughly. B. The person being deposed is under oath and must answer all questions posed by the deposing attorney. When defending a corporate or other legal entity, one of the many strategic decisions made prior to the start of a trial is the selection of the particular person to attend the trial throughout its duration as the corporate representative. . Casetext, Inc. and Casetext are not a law firm and do not provide legal advice. Sept. 6, 2018). Rule 30 (b) (6) requires that the party taking the deposition provide a notice of corporate deposition that lists topics on which testimony is sought, and requires that the company noticed. endstream endobj 46 0 obj <> endobj 47 0 obj <> endobj 48 0 obj <>/ColorSpace<>/Font<>/ProcSet[/PDF/Text/ImageC]/ExtGState<>>> endobj 49 0 obj <> endobj 50 0 obj <> endobj 51 0 obj <> endobj 52 0 obj <> endobj 53 0 obj <> endobj 54 0 obj [/ICCBased 63 0 R] endobj 55 0 obj <> endobj 56 0 obj <> endobj 57 0 obj <> endobj 58 0 obj <> endobj 59 0 obj <>stream The deposition will be recorded via stenographic, audio, and/or videotaped means for the purpose of discovery and/or used as evidence and/or any other purposes permitted by the Maryland Rules of Civil Procedure, including use at trial, and will continue day to day until completed. See Fed. 0000007631 00000 n Deposition questions vary on a case-by-case basis, but introductory, background and deposition preparation questions are fairly standard across the board. The Illinois Supreme Court rule is similar to the Federal Rule 30(b)(6). Knowledge of all medications being taken or prescribed to Defendant Dughly for the year prior to the occurrence. Knowledge of all maintenance files and records from at least one year prior to accident maintained by Defendant Rolfes in accordance 49 CFR 396 on the truck tractor involved in the accident inclusive of any inspections, repairs or maintenance done to the tractor tractor. Such depositions have a number of distinct characteristics and contain traps for the unwary. See TEX. Rule 56.01 (b) (2) will require a court to limit the frequency or extent of discovery in particular circumstances. 0000002469 00000 n applied the Federal Rules of Evidence (FRE) to deposition proceedings. Defendant Jones Supply Company, LP shall produce a corporate representative(s) with the knowledge and ability to testify regarding the topics described in the attached "Schedule A.". This same procedure is available under in Maryland state court under Maryland Rule 2-412(d) based on the federal rule. 0 : NOTICE OF VIDEOTAPED DEPOSITION OF CORPORATE REPRESENTATIVE FOR Jones Supply COMPANY, LP. Knowledge of any photographs taken of the tractor-trailer operated by Defendant Dughly at the scene of the incident, or any time after. Your corporate client just received a notice pursuant to Rule 30(b)(6) directing its corporate representative to be prepared to testify about every time a past, present, or future employee of the company sneezed over the last 15 years. Knowledge of all road and written test certificates issued by Defendant Rolfes or any other motor carrier or organization to Defendant Dughly regardless of the date issued or the originator of such certificates. Knowledge of all documents constituting, commemorating to relating to any hours of service violations by any driver employed by Defendant Rolfes from three (3) years prior to the incident to present. That deposition notice must set forth the areas of inquiry with enough specificity so the other party can reasonably designate and prepare the appropriate person (s) to testify. The Corporate Representative Deposition in Illinois Under Supreme Court Rule 206 (a)(1) AL. Under this rule, by notice an opposing corporation, partnership or association or by subpoena a third party must disclose and present a witness to testify on it's behalf on the subject of certain topics listed in the deposition notice/subpoena. Based on these rules, the defendant can argue that before the plaintiff is allowed to call to the stand as an adverse witness a person designated as a company representative for appearance purposes only, the court should inquire into the plaintiffs areas of examination. Corporate Representative Depositions: Notice Provision of Rule 30 (b)(6) by Carter E. Strang and Arun J. Kottha Federal Rule 30(b)(6) is the vehicle for taking de-positions of corporate representatives in civil cases. This CLE course will prepare trial attorneys to defend the depositions of corporate representatives during litigation. FindLaw.com Free, trusted legal information for consumers and legal professionals, SuperLawyers.com Directory of U.S. attorneys with the exclusive Super Lawyers rating, Abogado.com The #1 Spanish-language legal website for consumers, LawInfo.com Nationwide attorney directory and legal consumer resources. 0000027881 00000 n Knowledge of all documents received, obtained or filed by Defendant Rolfes when qualifying Defendant Dughly as a truck driver in accordance with the Federal Motor Carrier Safety Regulations. No. %PDF-1.4 % The importance of each function varies depending on the nature of the case and the amount in dispute. 0000004412 00000 n Knowledge of all documents reflecting any background check performed on Defendant Dughly with regard to his driver's record (including but not limited to traffic tickets, incidents, and prior employment as a driver). LIST OF TOPICS FOR Jones Supply COMPANY, LP REPRESENTATIVE, Example 30(B)(6) Deposition Notice for Corporate Representative. Knowledge of every federal, state, county, municipal, insurer and/or internal motor carrier collision report or other collision reports concerning all collisions in which Defendant Rolfes (or one of Rolfes's drivers) has been involved, including the collision at issue in this cause and all collisions prior to the collision at issue in this cause, pursuant to Federal Motor Carrier Safety Regulation 390.15(b)(1) and 390.1 5(b)(2). The entity's adversary has few obligations in noticing the deposition of a corporate designee. 246) Plaintiffs requested a telephone conference with the Court to discuss whether Defendant Washington University should be allowed to not designate a representative to discuss three topics DEPONENT: Corporate Representative for Jones SupplyCompany, LPDATE:Friday March 5, 2021TIME: 10:00 a.m.LOCATION: Miller & Zois, LLC 1 South Street, 24th Floor Suite 2450 Baltimore, MD 21202 Respectfully submitted, MILLER & ZOIS, LLC Ronald V. Miller, Jr. 1 South Street, 24th Floor Suite 2450 Baltimore, MD 21202 Phone: 410-553-6000 Fax: 844-712-5151, Attorneys for the Plaintiff Taylor D. Martinez and the Estate of Abigail Martinez, A. Hopefully I won't need it again but if I do, I have definitely found my lawyer for life and I would definitely recommend this office to anyone! Knowledge of all safety ratings issued to Defendant Rolfes by any federal government agency for the five years preceding the incident. Knowledge of all memoranda, policies, procedures or correspondence given or sent to Defendant Rolfes about the falsification of records during their engagements with Jones Supply. %%EOF (1) After commencement of the action, any party may take the testimony of any person, including a party, by deposition upon oral examination without leave of court, except as specified in paragraph (2) of this subdivision. Baylor University | A Nationally Ranked Christian University . remain stationary in remote depositions. Relator asserts that the writ should be made peremptory because the circuit court misapplied Rule 57.03(b)(4) by not requiring Defendant to produce a corporate representative to testify regarding facts that are known or reasonably available to Defendant. This request specifically includes each out of service report or violation concerning each leased power unit or trailer utilized, maintained, or controlled by this defendant from the year prior to the collision through the present. 475, 476 (S.D. Knowledge of the driver manual, company handbook, or their equivalent issued to Defendant Rolfes and Dughly by Jones Supply. `qc l\! Knowledge of any documentation evidencing the completion or non-completion of training programs, safe driving programs, and driver orientation programs by Defendant Rolfes for Defendant Jones Supply. When a party notices the deposition of an entity, regardless of the number of designees, it is considered one deposition for the purpose of the default limit of 10 depositions. 51 The legislation also altered the procedures for taking depositions in civil cases. Knowledge of any employee handbook for Defendant Rolfes that was in effect at the time of the incident. The alternative writ of mandamus is made peremptory. Knowledge of all driver's record of duty status or driver's daily logs and 70/60 hour - 8/7 day summaries or otherwise described time worked records created by Defendant Dughly and/or any of his/her co-driver(s) for the period from at least 90 days prior to the accident and for 30 days after the accident. (2) With Leave. 0000003033 00000 n Knowledge of any vehicle inspection report for the tractor or the trailer made by any person, company or agency during the five years before the incident and including the date of the incident. In Carriage Hills Condominium, Inc. v. JBH Roofing & Constructors, Inc., So. The first step in preparing for a corporate representative deposition is reviewing and analyzing the scope of the deposition notice. Knowledge of any and all documents regarding any loads transported by Defendant Rolfes and Dughly at the request of Defendant Jones Supply prior to the subject collision. The circuit court erroneously overruled relator's motion to compel production of a substitute corporate representative. 3d , 2013 WL 1136399, 38 [] . F : (504) 569-2999, Energy Centre, 1100 Poydras Street, 30th Floor, 0000001311 00000 n The deponent's attendance may be compelled by subpoena under Rule 45. The Commercial Division Advisory Council was created in 2013 as a follow up to Chief Judge Jonathan Lippman's Task Force on Commercial Litigation in the 21st Century. No party shall be permitted to offer such business records into evidence pursuant to this section unless all other parties to the action have been served with copies of such records and such affidavit at least seven days prior to the day upon which trial of the cause commences. However, this rule pertains to pretrial discovery and does not address calling a corporate representative at trial as an adverse witness. Defendant did not raise these objections before or during the deposition or in opposition to the motion to compel. Knowledge of any and all DOT and State inspections of the tractor involved in the crash for the five years leading up to the date of this crash. In . banc 1992). This mechanism allows plaintiffs' lawyers to obtain discovery against a corporation by specifying topics on which testimony is sought, requiring the organization to designate witnesses to provide testimony on these subject that may bound the corporation at trial. endstream endobj 86 0 obj<>/Outlines 15 0 R/Metadata 22 0 R/PieceInfo<>>>/Pages 21 0 R/PageLayout/OneColumn/OCProperties<>/StructTreeRoot 24 0 R/Type/Catalog/Lang(EN-US)/LastModified(D:20081215195513)/PageLabels 19 0 R>> endobj 87 0 obj<>/PageElement<>>>/Name(HeaderFooter)/Type/OCG>> endobj 88 0 obj<>/ColorSpace<>/Font<>/ProcSet[/PDF/Text/ImageB]/ExtGState<>>>/Type/Page>> endobj 89 0 obj<> endobj 90 0 obj<> endobj 91 0 obj[/ICCBased 98 0 R] endobj 92 0 obj<> endobj 93 0 obj<> endobj 94 0 obj<>stream A designated representative who gives testimony under Illinois Supreme Court Rule 206(a) may not be contradicted by any other corporate representative at trial. hYrF}WLa fp,+rD. Next . At FindLaw.com, we pride ourselves on being the number one source of free legal information and resources on the web. The rule provides that the corporate representative shall testify as to matters known or reasonably available to the organization. Rule 53.07(b)(4)'s plain language does not contain any provision permitting the representative to avoid testimony on the identified topics by stating that he or she has no personal knowledge of the subject matter. 3 The effectiveness of the Rule bears heavily upon the parties' reciprocal . %%EOF 3. (504) 569-2030 16 A. R. S. R. Civ. 0000002791 00000 n Knowledge of any and all documents setting forth any policies, procedures, guidelines, recommendations or directives regarding driver conduct, driver safety, driver hiring, subcontractor hiring, commercial carrier hiring, discipline or firing prepared or used by Defendant Jones Supply during the five (5) year period prior to the subject incident and through the present date, together with all amendments, revisions or supplements thereto. Insurance Company, because: (1) Plaintiff's amended corporate representative deposition notice improperly expanded the areas of testimony and added a duces tecum; (2) the corporate representative topics are vague and not limited in time; and (3) Plaintiff has still failed to withdraw th e Opdyke deposition notice." Dkt. The answer: Depose the corporate representative under Fla. R. Civ. Knowledge of any and all e-mail sent by, or to, Defendant Jones Supply (including its employees or agents) concerning the incident. I understand that submitting this form does not create an attorney-client relationship. However, a smart plaintiff attorney can defeat this strategy by calling that person as an adverse witness before putting on the plaintiffs key witnesses. After the deposition, the plaintiff moved for sanctions and to compel a second corporate deposition, alleging that the corporate representative was not adequately prepared to testify. The contact form sends information by non-encrypted email, which is not secure. b. rule 1.310(b)(6) and the binding effect of a corporate representative's testimony To place matters in a proper context we begin our review by summarizing how Florida Rule of Civil Procedure 1.310(b)(6)which governs corporate representative depositionsis supposed to operate, an exercise which illustrates that the present dispute . Knowledge of each of the following documents reflecting Defendant Rolfes's compliance with. 0000002753 00000 n 0000005124 00000 n Corporate Representatives Protected Work Product Most practitioners are familiar with the pur-pose and scope of corporate-representative depositions, commonly known as "30(b) (6) depositions" in federal court. Knowledge of any agreement or requirement to place the Jones Supply logo on the tractor or trailer involved in this incident. After all, if the plaintiff merely intends to ask a series of questions about which the individual has no knowledge, then the evidence is irrelevant in all probability or, at a minimum, unfairly prejudicial to the defendant corporation. 0000003109 00000 n The party seeking to depose the organization must "describe with reasonable particularity the matters for examination" in its deposition notice. As interpreted by many courts, Rule 30 (b) (6) imposes no obligation to reveal the identity of the corporate designee to testify until the 30 (b) (6) deposition actually takes place. Hopefully, you will be able to reach an amicable agreement about the reasonable bounds of the corporate representatives testimony. So, the next time you receive a deposition notice pursuant to Rule 30(b)(6), before preparing your witness, be sure to ask yourself whether the designated areas of inquiry are reasonable both in scope and description. Introductory Questions. Corporate representative witnesses shall be deposed where their principal office Corinne REIF, Relator, v. The Honorable Michael T. JAMISON, Respondent. The Missouri General Assembly recently enacted changes to the discovery rules, which became effective on August 28, 2019. Knowledge of any and all documents relating to any investigation performed by Defendant Jones Supply concerning Defendant Rolfes's safety rating, safety fitness, Federal Motor Carrier Safety Administration's safety measurement system, behavioral analyst and safety improvement categories (BASICs), including unsafe driving, hours of service compliance, driver fitness, controlled substances/alcohol, vehicle accidents, list of crashes, roadside inspections and commercial vehicle violations prior to the date of the subject collision. /content/aba-cms-dotorg/en/groups/litigation/committees/pretrial-practice-discovery/practice/2018/adequately-preparing-a-corporate-representative-for-deposition. Corporations and other entities have unique obligations regarding the depositions of corporate designees pursuant to Federal Rule of Civil Procedure 30(b)(6) and its state cognate, Pennsylvania Rule of Civil Procedure 4007.1(e). Knowledge of Defendant Dughly's trip reports, daily loads delivered or picked up reports or any otherwise titled or described work reports, work schedule reports, fuel purchased reports, or any other reports made by Defendant Dughly to Defendant Rolfes and/or Jones Supply, inclusive of daily, weekly or monthly cargo transported, time and/or distance traveled reports or work records excluding only those documents known as "driver's daily logs or driver's record of duty status" for the month of the incident. startxref 0000001100 00000 n The purpose of Rule 57.03(b)(4) is to permit a party to depose an opposing corporation's representative under circumstances in which the statements made by the witness on the identified topics will be admissible against and binding on the corporate party. Introductory questions serve two purposes. In this case, Defendant identified several of its employees who witnessed decedent's fall. Knowledge of all documents that indicate your company is a common carrier, a contract carrier, or a private carrier. Terry v. Holtkamp, 330 Mo. Additionally, Arizona codified remote online notarization as of July 2020. State ex rel. Initially, trial judges have great discretion in controlling litigation. (1) Representative Deponent. Knowledge of each rental or lease agreement related to the tractor or the trailer. LA Knowledge of all documents relating to any disqualification of Defendant Dughly made pursuant to any Federal Motor Carrier Safety Regulation. Knowledge of the policies or procedures provided by Jones Supply to Rolfes, regarding safety, motor vehicle safety, travel policy, sleep and rest requirements, vehicle inspection, driver standards and hiring requirements that were in effect at the time of the incident, including, but not limited to driver safety manuals, driver safety operating procedures, driver safety training manuals/procedures/guidelines. This would include any suspension or termination of contracts to haul on behalf of Jones Supply as a commercial carrier. Knowledge of all payroll, compensation, incentive pay for Defendant Dughly for work performed covering the 5 years preceding the collision and including the date of the collision. The underlying purpose of Rule 57.03(b)(4) is reflected in the mandatory language employed. However, parties frequently include generic listings in their witness lists, such as references to a corporate representative of the defendant, or adopt the other partys witness list, which may be deemed sufficient to include the corporate representative designated for purposes of appearance at trial. Penn Mutual, 2011 WL 13228574 at *4. (a) Unless the court orders otherwise under Section 2025.260, the deposition of a natural person, whether or not a party to the action, shall be taken at a place that is, at the option of the party giving notice of the deposition, either within 75 miles of the deponent's residence, or within the county where the action is pending and . Depositions are routinely used by counsel to exert pressure on a party by attempting to depose high-level executives in inconvenient locations, sometimes thousands of miles and many time zones away, in an attempt to gain a strategic advantage over a party and move towards a potential settlement. The circuit court erroneously overruled relator's motion to . xd|dxh)G_X;oFs$0U{Ul~D,#p8F. 0000011346 00000 n Chassaing v. Mummert, 887 S.W.2d 573, 576 (Mo. Rule 32, thus, suggests that perhaps the corporations right to decide which particular individuals will testify on its behalf is not absolute. If the order terminates the Knowledge of a copy of the registration and title to the vehicle involved in this occurrence. Fla. Sept. 14, 2011) (citingBanks v. Office of the Senate Sergeant-At-Arms,241 F.R.D. The corporation, in turn, "shall designate one or more officers, directors, or 0000004190 00000 n A party may, by oral questions, depose any person, including a party, without leave of court except as provided in Rule 30 (a) (2). Because the person designated as the corporate representative is exempt from the sequestration of witnesses, it is frequently tempting to designate an important witness as the corporate representative to allow him or her to listen to the testimony of the plaintiffs witnesses. Rules Governing Civil Procedure in the Circuit Courts, Rule 57 - Interrogatories and Depositions, Rule 57.02 - Depositions Before Action or Pending Appeal, Rule 57.03 - Depositions Upon Oral Examination, Rule 57.04 - Depositions upon Written Questions, Rule 57.05 - Persons Before Whom Depositions May Be Taken, Rule 57.06 - Presiding Officer for Deposition, Rule 57.07 - Use of Depositions in Court Proceedings, Rule 57.08 - Depositions for Use in Foreign Jurisdictions, Rule 57.09 - Subpoena for Taking Deposition. Nonetheless, as noted, the trial judge has broad discretion in controlling the course of the trial. A party may in the notice and in a subpoena, if required, name as the deponent a public or private corporation or a partnership or association or governmental agency and describe with reasonable particularity the matters on which examination is requested. When defending the deposition, you should carefully review the taking-party's notice to ensure it is in strict compliance with Rule 1.310 (b) (6). Knowledge of the title related to the tractor. P. 199.2(b)(1) (setting the requirements for deposing an organization). Knowledge of the accident register maintained as required in. Under FRCP 30 (b) (6) and ORCP 39 (c) (6) (collectively "Rule 30 (b) (6)"), a party to a lawsuit has the right to issue a notice for the deposition of a "public or private corporation, a partnership, an association, a governmental agency or other entity.". All Rule 30(b)(6 . Knowledge of the entire drug and alcohol file of Defendant Dughly including but not limited to pre-employment, post-accident, random, reasonable suspicion, and return to duty drug and alcohol testing results maintained pursuant to 49 CFR 382.401, preserved pursuant to 49 CFR 379 (including Appendix A, Note A), and released pursuant to 49 CFR 40.323. and Towson; Carroll County including Westminster; Frederick County including Frederick; Harford County including Abingdon, Bel Air, Belcamp, and Forest Hill; Montgomery County including Germantown and Rockville; Howard County including Ellicott City and Columbia, Washington, D.C. and Washington County including Hagerstown. 0000001118 00000 n Knowledge of all leases, understandings, memoranda and other documents relating to the use and/or possession of the tractor-trailer in question. You are hereby notified that Plaintiff, Taylor Martinez, by and through her attorneys, Ronald V. Miller, Jr., Laura G. Zois, Esq., Justin P. Zuber, Esq., and Miller & Zois, LLC, pursuant to the Maryland Rules of Procedure 2-412 and 2-416, will take the deposition upon oral examination, for use in discovery and at trial, of the following persons on the date and at the time indicated below before a person duly authorized to administer an oath under Maryland law to be recorded stenographically/audio/videotape. Energy Centre, 1100 Poydras Street, 30th Floor. A writ of prohibition [or] mandamus is the proper remedy for curing discovery rulings that exceed a court's jurisdiction or constitute an abuse of the court's discretion. State ex rel. :Defendants. 0000000950 00000 n Knowledge of each Defendant Jones Supply employee who investigated Defendant Rolfes's fitness to haul on behalf of Jones Supply prior to the date of the subject collision (this includes the initial investigation and any subsequent investigations, whether annually, bi-annually, etc.). 68 0 obj <>stream Relator filed a motion to compel Defendant to produce a substitute corporate representative prepared to testify about matters known or reasonably available to Defendant regarding the first and third deposition topics. Regardless of what role a designated corporate representative is expected to play at trial, the corporate representative should always be prepared for the possibility of being called as an adverse witness during the presentation of the other sides case. If the person designated as the appearance corporate representative is not listed by the plaintiff on its witness list, the plaintiff would normally be precluded from calling that corporate representative as an adverse witness for this reason alone. startxref When a company is noticed for a deposition, it has a duty to prepare its witnesses to fully and unevasively answer questions about the designated subject matters. Knowledge of any primary, umbrella, and excess insurance policy, or agreement, including the declarations page, for Defendant Rolfes, Defendant Dughly, and Defendant Jones Supply, which was in effect at the time of this incident. I understand that submitting this form does not address calling a corporate representative shall testify as to known... That submitting this form does not create an attorney-client relationship scr 206 ( a ) ( )... All medications being taken or prescribed to Defendant Rolfes, including Defendant Rolfes and Dughly by Jones as! Or the trailer for Defendant Rolfes 's compliance with Rule 4:9 for the production a... Requirement to place the Jones Supply as a commercial carrier related to organization. State court under Maryland Rule 2-412 ( d ) based on the tractor or trailer involved in this.! Commercial carrier following documents reflecting Defendant Rolfes 's safety rating, authority, insurance information BASIC... Underlying purpose of Rule 57.03 ( b ) ( 2 ) will require a court to limit the or... Deposition or in opposition to the discovery Rules, which is not absolute relator, v. the Honorable T.! Corporate representatives during litigation noted, the trial subpoena power to depose corporate. Indicate your COMPANY is a non-party to the discovery Rules, which effective... The nature of the following documents reflecting Defendant Rolfes 's safety rating,,! Answer: depose the corporate representatives during litigation rating, authority, insurance information and/or BASIC scores decedent. 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