Federal Rule of Civil Procedure ("FRCP") 30 (b) (6) governs the depositions of organizations, including corporations, partnerships, associations, and governmental agencies. 0000005124 00000 n Knowledge of all evaluations or criticism of the job performance of any of Defendant Rolfes's drivers by Jones Supply, including but not limited to annual evaluations, interim evaluations, or specific incidents that gave rise to an evaluation or criticism. 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. The issue in this writ proceeding is whether a corporate representative designated for deposition pursuant to Rule 57.03 (b) (4) can limit his or her deposition testimony to personal knowledge instead of testifying about facts that are known or reasonably available to the organization. In other words, the testimony of the corporate representative designated pursuant to Rule 57.03(b)(4) is not the deposition of that individual for his or her personal recollections or knowledge but is instead the deposition of the corporate defendant. Annin v. Bi-State Development Agency, 657 S.W.2d 382, 386 (Mo.App.1983). Knowledge of any maps, directions, or delivery instructions that were provided by Defendant Jones Supply to Defendant Rolfes drivers prior to the date of the subject collision. Defendant did not raise these objections before or during the deposition or in opposition to the motion to compel. 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. testify 'vicariously' at trial, as distinguished from at the Rule 30(b) (6) deposition, if the corporation makes the witness available at trial, he should not be able to refuse to testify to matters as to which he testified at the deposition on grounds that he had only corporate knowledge of the issues, not personal knowledge."8 With Knowledge of the entire personnel file of Defendant Dughly. LIST OF TOPICS FOR Jones Supply COMPANY, LP REPRESENTATIVE, Example 30(B)(6) Deposition Notice for Corporate Representative. 5 Yet, each designee's deposition is considered a separate deposition for the purpose of duration (i.e., seven hours in one day under Rule 30(d)(1)). 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. Knowledge of any publications, manuals, literature, guidelines, or other written materials provided by Defendant Jones Supply to Defendant Rolfes (or any of its' drivers) at any time prior to the date of the subject collision. 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 This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply. 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. 0000007631 00000 n It's time to renew your membership and keep access to free CLE, valuable publications and more. Knowledge of all cargo pickup and delivery documents prepared by Defendant Jones Supply, any transportation brokers, involved shippers or receivers, motor carriers operations/dispatch personnel, drivers, or other persons or organizations relative to the cargo transported and the operations of Defendant Dughly for the seven (7) days leading up to and including the date of the incident. 0000001521 00000 n 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. [1] The Council's goal is to advise the Chief Judge on an ongoing basis about matters concerning the Commercial Division of the Supreme Court of New York, to consider how the Commercial Division can better serve the needs of the . R. Civ. P. 1.310 (b) (6) and begin your discovery voyage. %PDF-1.4 % Plank v. Koehr, 831 S.W.2d 926, 928 (Mo. The importance of each function varies depending on the nature of the case and the amount in dispute. Knowledge of any compensation from Jones Supply to Defendant Dughly (or any other Rolfes driver), including any bonuses and/or discounts on Jones Supply products. Assuming the representative designated for appearance purposes is covered by the witness list, it could nonetheless be argued that allowing the plaintiff to call the representative as an adverse witness would effectively allow the plaintiff to designate the corporations representative on the particular subjects about which the representative is questioned. 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. 0000002399 00000 n . 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. xb```HVeaxd>N B$SJ8K5wT^{0;5|gZX\44R~A 6`uP*?' Knowledge of any and all documents relating to any investigation performed by Defendant Jones Supply concerning Defendant Dughly'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. corporation's behalf, thereby resulting in an inefficient and perhaps altogether useless exercise. A deposition lawfully taken and, if required, filed in any federal- or state-court action may be used in a later action involving the same subject matter between the same parties, or their representatives or successors in interest, to the same extent as if taken in the later action. SCR 206(a)(1) also grants subpoena power to depose a corporate representative who is a non-party to the case. 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. 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. Now what? Knowledge of all receipts for fuel for the tractor involved in this incident for the 12 months prior to the incident. 0000001311 00000 n (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 . R. Civ. White v. Gray, 141 S.W.3d 460, 463 (Mo.App.2004) (quoting State ex rel. Knowledge of all leases, understandings, memoranda and other documents relating to the use and/or possession of the tractor-trailer in question. Knowledge of all driver's licenses and truck driver certifications which Defendant Dughly possesses (currently) and did possess on the date of the incident. 370, 373-75 (D.D.C. Please try again. A fairly standard requirement is that potential witnesses must be identified on witness lists exchanged by the parties. R. Civ. You are advised that you must designate one or more officers, directors, managing agents, or other persons who will testify on your behalf regarding the matters listed in "Schedule A" which are known or reasonably available to Jones Supply Company, LP. The circuit court erroneously overruled relator's motion to compel production of a substitute corporate representative. Knowledge of the job description of the position that Defendant Dughly was initially hired, employed or retained to perform for Defendant Rolfes. See CCP 2025.420 (b) (12) (any party, deponent, or other affected person or organization may move for protective order to exclude designated personsother than the parties to the action and their officers and counsel . Knowledge of all documents relating to traffic accidents involving Defendant Rolfes, including logbook and hours of service violations and other regulatory violations for the duration of the company's engagement with Jones Supply. Knowledge of any statements, written, audiotaped, or otherwise recorded or memorialized of any of the parties or witnesses to the incident. 1. A party may, by oral questions, depose any person, including a party, without leave of court except as provided in Rule 30 (a) (2). 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. 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 Solution Is Born. 45 24 Knowledge of all arrests and or/convictions of the Defendant Dughly. LA Terry v. Holtkamp, 330 Mo. 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.). The procedure of Rule 4:9 shall apply to the request. 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). 1999); Crimm v. Missouri Pac. remain stationary in remote depositions. I also understand that Miller & Zois works with multiple law firms on these claims and that I may be contacted by an affiliated law firm working with Miller & Zois on these lawsuits. The rule has two basic requirements. However, this rule pertains to pretrial discovery and does not address calling a corporate representative at trial as an adverse witness. Copyright 2023, Thomson Reuters. All rights reserved. Discovery has closed. 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. At FindLaw.com, we pride ourselves on being the number one source of free legal information and resources on the web. 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 . For the purposes of this section, "officer" means the president, chief executive officer, chief operating officer, or chief financial officer of a publicly traded company or of a subsidiary of such company that employs 250 or more people. 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. IN THE CIRCUIT COURT FOR BALTIMORE CITY, MARYLAND. Sept. 6, 2018). 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. 68 0 obj <>stream Knowledge of any investigations performed by Jones Supply regarding Defendant Rolfes's safety history, safety ratings, driver qualifications, driver fitness, accident history, drug, and alcohol testing, and vehicle maintenance. Knowledge of all evaluations or criticism of the job performance of Defendant Dughly by Rolfes, including but not limited to annual evaluations, interim evaluations, or specific incidents that gave rise to an evaluation or criticism. 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). 0000011346 00000 n Rule 57.06 - Presiding Officer for Deposition. Meanwhile, his Fighting for Missouri PAC received $3,000 from the aptly named Norfolk Southern Corporation Good Government Fund and $10,000 from BNSF before the 2020 election. Many states also have similar rules providing a mechanism for deposing a corporation or other company Rule 57.04 - Depositions upon Written Questions. Under the Federal Rules of Civil Procedure, the sequestration rule does not apply to pretrial depositions absent a special order, Fed. 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. 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). The electrical box was on Defendant's premises. Knowledge of all actual driver's motor carrier written tests administered to Defendant Dughly, including all answers. On June 18, 2021, the Texas Supreme Court held that a party could depose a corporate representative even if the company lacked personal knowledge of the underlying facts at issue, but the deposition must be narrow in scope. Knowledge of the entire driver investigation history file or its equivalent for Defendant Dughly maintained pursuant to 49 CFR 391.53 and preserved pursuant to 49 CFR 379 (including Appendix A, Note A). xb```b``)f`a``scg@ ~+s`X1'e5zUY3X,2 Because a deposition is sworn testimony, it can be used to prove perjury if a witness tries to change his or her testimony at trial. b`Sk>482?m``vMjmx@!f732 WpH3-00%iF ~ ` C Knowledge of all mileage logs and travel reimbursement records for Defendant Dughly for the month of the incident. Per the revised Rule 57.03(a), leave of court for a deposition would be required if the parties have not stipulated to the deposition and (i) the deposition would result in more than 10 depositions being taken under Rule 57.03 or Rule 57.04 by any party; (ii) the deponent has already been deposed in the case; or (iii) the plaintiff seeks to take Knowledge of all documents constituting, commemorating, or relating to any incidences of overweight citations or warnings issued for any tractor and/or trailer owned, leased or otherwise in the service of Defendant Rolfes. 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. SKU: LIT6400. Knowledge of any photographs taken of the tractor-trailer operated by Defendant Dughly at the scene of the incident, or any time after. 0000027881 00000 n Key Provisions of Rule 32 A deposition may be used by any party to contradict or impeach the testimony given by the deponent as a witness or for any other purpose allo wed by the Federal Rules of . 6 Theoretically . Knowledge of all documents reflecting the repair history for the truck and trailer involved in the occurrence. :Plaintiffs, :v. : Case No. 0000001433 00000 n I understand that submitting this form does not create an attorney-client relationship. %%EOF The issue in this writ proceeding is whether a corporate representative designated for deposition pursuant to Rule 57.03(b)(4) can limit his or her deposition testimony to personal knowledge instead of testifying about facts that are known or reasonably available to the organization. Knowledge of the company safety rules or its equivalent issued to Defendant Rolfes and Dughly by Jones Supply that were in effect on August 27, 2020, and for 1 year prior. 0000000016 00000 n 0 Rule (30) (b) (6) applies to depositions of both party and nonparty corporations. The principle underlying this argument is that only the corporation has the authority to designate particular representatives to speak on its behalf and bind it with respect to particular subject areas. (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. hYrF}WLa fp,+rD. State ex rel. A designated representative who gives testimony under Illinois Supreme Court Rule 206(a) may not be contradicted by any other corporate representative at trial. Knowledge of all documents concerning any bills, attorney's fees, court costs, expenses, expert fees, formal or informal, that reduce the amount of liability insurance available to cover the Plaintiff. Knowledge of the organizational charts and lists identifying the divisions and management structure for your company, its subsidiaries, parents, or affiliates of the year of the collision and four years prior. After being served with a notice of deposition, the organization shall designate a corporate representative to testify on its behalf. Knowledge of all records and reports of audits performed by the Bureau of Motor Carrier Safety or by any other state or federal agencies for Defendant Rolfes and/or Dughly. 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). Contact us. 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. 30 ) ( 6 ) deposition Notice for corporate representative who is a to... Of each function varies depending on the web and/or possession of the Defendant Dughly, all! 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