Premises Liability Deposition Checklist - of Plaintiff



“Use Rule 30. Get the defendant doing the work. Find who in the corporation knows what you want to know — And make your discovery preparation faster and better.”

This targeted Notice of Taking Deposition of an Organization form is written only for one side of a lawsuit, and only for one class of cases. It is written for plaintiffs in premises liability cases.

For the purpose of 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 need this form if you are a plaintiff's attorney.

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. Federal Rule of Civil Procedure 30(a) now limits you to ten depositions and 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 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.

The rules require the organization (not you!) do the work of determining who knows information relevant to the inquiries that you want to make.

You can maximize your tactical and psychological advantage by a multi-page, comprehensive, well-drafted, bullet-proof, 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? What if this doesn’t look like a form to the motions judge? And what if this simple item would be easy and inexpensive to buy?

Here is more great news — Notice of Deposition of Organization is furnished to you, in PDF format, right to your computer, immediately. If you are counsel with a premises liability case, buy Notice of Deposition of Organization and put the defendant on the defensive right now!

Let me tell you more about our Notice of Deposition of Organization checklist – form and why it will be a is a major help to you. For the plaintiff’s attorney, the form shows the areas and questions which you want to investigate. It not only gives you a checklist of areas to discover, it in effect is a subpoena duces tecum that delivers the other side’s documents to you right at the beginning of the case.

We have additional forms for bodily injury premises liability cases, but this form is the first one a plaintiff should reach for. Notice of Deposition of Organization will be used in all your premises personal injury cases.

Over the years, this notice checklist – form will save you hours of discovery and deposition time. — a real value for the time it saves you.!

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 personal injury case.

You 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!

IMPORTANT: Let me recap…

  • Notice of Deposition of Organization will help you organize your slip and fall case or your property construction defect case, depositions from beginning to end.
  • Notice of Deposition of Organization gives you a better notice, in less time.
  • Notice of Deposition of Organization will save you time and money.
  • Notice of Deposition of Organization is comprehensive, for your benefit; you can check and think about all the bases to cover. It is a confidence builder.
  • Notice of Deposition of Organization will keep the defendant at the other end of a laser focused on what you want. The adverse attorney knows you are a professional, not fumbling like an amateur.
  • Notice of Deposition of Organization is a very low investment with a high value return.

We are selling the Notice of Deposition Organization for only $24.90. 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.


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