Plaintiff’s Notice Of Depositions Of Driver And Corporate Representative

V I R G I N I A:





Case No.

PLEASE TAKE NOTICE that the Plaintiff, by counsel, will take the following depositions on March 3, 2010 starting at 11:30 AM and continuing until they are concluded.

1. Defendant :11:30 AM

2. Designated Representative of Corporate Defendant : 12:30 PM

Said deposition will take place at the Law Offices of Jeremy Flachs, Esq., Evergreen Office Park, 7006 Little River Turnpike, Suite G, Annandale, Virginia 22003 before an authorized court reporter and notary public.

The deponents and their counsel are directed to bring with them all documents relating to this cause, including but not limited to:

  1. original photographs of the scene of the collision and/or the vehicles involved in the collision;
  2. any appraisals or estimates of repair for any vehicle involved in the collision;
  3. A copy of Defendant's registration for the vehicle involved in the collision with Plaintiff;
  4. If not previously produced, a copy of the declaration pages for any liability or umbrella insurance policies covering defendant at the time of the
  5. collision with Plaintiff; and
  6. Defendant's driver's license.

The Designated Representative of Corporate Defendant shall be prepared to testify about the following matters:

  1. The collision of May 22, 2007 involving the vehicles operated by Plaintiff and Defendant Driver, including the reason for Defendant Driver's use of a car on the day of the collision, observations at the scene, statements made by any party or witness, the identify of any witnesses and any photographs of any person or thing involved in the collision;
  2. The employment relationship between Corporate Defendant and Defendant Driver, including but not limited to the manner in which Defendant Driver was hired and compensated, tax records pertaining to any compensation paid to Defendant Driver, Defendant Driver's employment duties, work schedule and hours, and supervision of Defendant Driver;
  3. Liability insurance coverage, including any umbrella or business policies providing coverage for the car driver by Defendant Driver or otherwise for the Corporate Defendant's business as a result of the collision occurring on 5/22/07;
  4. The precise nature of the legal entity (e.g. corporation, sole proprietorship, partnership, etc.) which employed Defendant Driver on 5/22/07 and which operated as the Corporate Defendant. Also provide documentation of the legal structure of this entity;
  5. The nature of the business (both in 2007 and at present) of Corporate Defendant, including but not limited to the products or services provided its customers, the number of employees and their duties, whether any vehicles were used to further the business, etc; and
  6. The extent of Defendant Driver's prior driving experience and any investigation into his competence to operate a vehicle.

Said Designated Representative should produce at deposition the following documents:

  1. all insurance policies requested above;
  2. all documents relating to the legal structure of Corporate Defendant on 5/22/07, including tax and legal records confirming the legal nature of the entity operating as Corporate Defendant on 5/22/07;
  3. all photographs of any person or thing involved in or relating to the collision; and
  4. all documents which explain the employment relationship between Defendant Driver and Corporate Defendant.

Respectfully Submitted,

By: _________________________________

Law Offices of Jeremy Flachs

Jeremy Flachs, Esq.

Counsel for Plaintiff

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