In both Florida and Federal cases, Plaintiffs can notice depositions with certain “areas of inquiry”. Those can be difficult to articulate, so below is a sample. Please seek legal advise before using such a thing, such as our lawyers. Our attorneys serve Gaiensville, Ocala, Lake City and the surrounding areas. The following is from an employment law case, but with modification it could easily be used to help the injured or in a divorce:
1. Each and every issue raised in Plaintiff’s first set of interrogatories.
2. The answers to Plaintiff’s first set of interrogatories.
3. The current location of each and every document requested in Plaintiff’s first request to produce.
4. Any and all issues related to allegations that the Plaintiff’s work performance was good, bad, poor and/or insufficient.
5. Any and all reasons for the Plaintiff’s termination, reprimands and/or demotion.
6. The job description and job duties of the Plaintiff.
7. Each and every one of the Defendant’s affirmative defenses.
8. The Defendant’s answer to the Plaintiff’s complaint.
9. Knowledge of factual circumstances surrounding Defendant’s answer and affirmative defenses.
10. Knowledge of factual circumstances surrounding Plaintiff’s complaint.
11. The job description and job duties of any and all of the Plaintiff’s supervisors.
12. The identify of any and all persons who’s job duties are similar to that of the Plaintiff.
13. The identity of all persons similarly situated to the Plaintiff.
14. All communications between the Plaintiff and any agent, director and/or employee of the Defendant.
15. All documents written by the Defendant (or its agents, directors and/or employees) to the Plaintiff.
16. All documents and/or letters written by the Plaintiff to the Defendant (or its agents, directors and/or employees).
17. All wages, benefits, earnings, and bonuses earned by the Plaintiff during the course of employment with the Defendant.
18. All reprimands provided (either verbally or written) by the Defendant (or its agents, directos and/or employees) to the Plaintiff.
19. All job duties of the Plaintiff’s supervisor.
20. All job duties of the person whom made (or was involved in any way) the decision to terminate the Plaintiff.
21. Any and all facts regarding those documents requested in Plaintiff’s first request to produce, including the authors of said documents and the circumstances surrounding their creation.
22. All employment policies and practices of the Defendant.
This is a sample corporate representative deposition notice, with areas of injury.
Michael Massey, Esq.