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Deposition Outline Checklist: Plaintiff’s Deposition of Defendant’s Employees: General Questions
DEPOSITION OUTLINE CHECKLIST: DEPOSE DEFENDANT’S EMPLOYEES
CORPORATE INFORMATION
For corporate representatives, officers or directors elicit the following information:
Type of business entity.
If incorporated, state of incorporation.
If a partnership, identify all partners, limited and general, etc.
Identify articles of incorporation and corporate by-laws.
Describe all related entities, subsidiaries, wholly owned or partially owned.
Net worth information regarding defendants and any related entities and parent corporation who may be potential defendants (note if the company in question is publically traded, much of this information should be available through the SEC and on the Internet).
KNOWLEDGE OF THE FACTS
What is the witness understanding of the facts surrounding plaintiff’s complaint/claim.
How did the witness gain this understanding (i.e. first-hand knowledge, through an investigation, something he overheard, etc.).
Identify documents the witness has reviewed which discuss or relate to plaintiff’s claims.
Did the witness participate in any investigation or give any statements concerning the plaintiff’s claims.
List persons who the witness believes have knowledge of plaintiff’s claims.
what general knowledge each witness has.
What is the witness’s understanding of any action by the company in response to plaintiff’s claims (have the witness give dates, names of persons involved and any other relevant information that he is aware of).
Is the witness aware of how the wrongful conduct effected the plaintiff.
Did he ever discuss the wrongful conduct with the plaintiff.
How did the plaintiff act, what did the plaintiff say.
Did the plaintiff appear to be distraught or upset.
Did the witness notice if the plaintiff’s performance or ability to work suffer following the wrongful act(s).
If the witness was personally involved or responsible for the investigation, have the witness discuss what happened, what was done, what procedures were instituted or followed.
Discuss any relevant documents generated as a part of the investigation. Use the witness to clear up anything that is illegible, unclear, etc. that the witness has knowledge of.
Use the witness to identify the sources of information, who drafted unsigned documents, the origin of documents contained in any investigative or employment files relating to the complaint.
If the witness was involved in the corporate action resulting from the investigation, discuss the specific details of what actions was taken, who made the decisions and the rationale for any decisions made.
After you have thoroughly discussed the details concerning the plaintiff’s complaint any subsequent investigation and/or employment action, then question the witness about corporate policies and procedures which were applicable and/or should have been followed.
Before showing the witness any policies or procedures, explore the witness’s knowledge concerning relevant policies and procedures (i.e. anti-harassment policies, policies related to complaints and investigations, policies related to employee disciplinary measures, suspension, termination, etc.).
For each relevant policy cited by the witness, inquire as to the reason or rationale for the...
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- Discovery Forms
- Medical records authorization
- Authorization for Texas Worker’s Compensation Commission Records
- Employment Records Authorization
- Scholastic Records Authorization
- Military Records Authorization
- Oral and Video Deposition Duces Tecum Propounded to Defendant for Employment Cases in General
- Oral and Video Deposition Duces Tecum to Plaintiff for Employment Cases in General
- Deposition Duces Tecum Propounded to Defendant City, Whistleblower Case
- Deposition Outline Checklist: Plaintiff’s Deposition of Defendant’s Employees: General Questions
- Deposition Checklist: Deposing the Plaintiff in Employment Cases (In General)
- Deposition Outline (Plaintiff) - False Imprisonment
- Standard Responses, Objections, and Answers to Interrogatories For Defendants and Plaintiffs
- Standard Responses, Objections, and Answers to Request for Production of Documents for Both Defendants and Plaintiffs
- Standard Instructions and Definitions for Defendant’s Written Discovery to Plaintiff
- Defendant's "Triple Threat" Discovery Propounded to Plaintiff in Employment Cases in General
- Defendant's "Triple Threat" Discovery Propounded to Plaintiff Employee's Spouse
- Sworn Statement by Non-Managerial Employee of Defendant
- Standard Instructions and Definitions for Plaintiff's Written Discovery to Defendant
- Plaintiff's "Triple Threat" Discovery to Defendant in Age Discrimination Case
- Plaintiff's Standard "Triple Threat" Discovery to Defendant in Employment Cases in General
- Plaintiff's "Triple Threat" Discovery Propounded to Defendant in Sexual Harassment Case
- Plaintiff's First Request for Production of Documents Propounded to Defendant City in a Whistleblower Case
- FOIA Request to the EEOC
- Open Records Request to the TCHR
- Standard Responses, Objections, and Answers to Interrogatories for Defendants and Plaintiffs Under Texas Rules of Civil Procedure
- Standard Responses, Objections and Answers to Request for Production of Documents for Defendants and Plaintiffs Under Texas Rules of Civil Procedure
- Request for Disclosures (Short Form) (State)
- Request for Disclosures (Long Form) (State)
- Discovery Plan (Worksheet)
- Deposition Outline - Economist
- Deposition Outline - Medical/Mental Health Professional
- Plaintiff's Proposed Pattern Interrogatories and Request for Production
- Level Three Discovery Control Plan
- Authorization for Release of Financial Records
- Motion to Compel Discovery (State)
- Deposition Outline - Corporate Representative - Products Liability
- "About Your Upcoming Deposition"
- Defendant's "Triple Threat" Discovery to Plaintiff - Race, Age & Firing
- Defendant's "Triple Threat" Discovery to Plaintiff - Sexual Harassment and Firing
- Plaintiff's "Triple Threat" Discovery to Defendant - Sex Discrimination (State Court)
- Plaintiff's "Triple Threat" Discovery to Former Employee Stealing Trade Secrets
- Petition Requesting Deposition Before Suit
- Opposition to Pre-Suit Deposition
- Order Authorizing Deposition
- Defendant's First Set of Interrogatories to Plaintiff-FLSA
- Defendant's First Set of Requests for Production to Plaintiff-FLSA
- Plaintiff's Triple-Threat to Defendant re: Stealing Trade Secrets
- Request For Disclosure To Defendant-FMLA, ADEA
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