Deposition outline-corporate representative-products liability
*Court Reporter: Indexed
DEPOSITION OUTLINE - CORPORATE REPRESENTATIVE
AGREEMENT ON DOCUMENTS
DOCS TO DEPO
1) Inves of Claim
2) Statements
INTRODUCTION
Swear in witness
State name
My name
Ever had depo taken
Informal setting, typed booklet form
Chance to visit with your lawyer
Under oath--judge & jury
Impeachment/perjury penalties
Don’t understand--agree to ask clarify/restate
I want everything you know or have heard
Do you understand the term hearsay
Want what you’ve heard or know from third party
Agree to tell me everything including hearsay
FULL & COMPLETE
Seeking truth
Whole story
Medications, drugs, illness
Feel ok to have depo
_________________________________________________________________
-
Address:
-
Telephone no.:
-
D/O/B:
-
S/S/N:
-
D.L. no.:
_________________________________________________________________
EDUCATION
High school:
Diploma:
Year:
College:
Major:
Degree:
Date:
Post college:
Trade shows
Trade schools/seminars:
Certifications/licenses:
a. Why not
HONORS
Awards
Honor societies
Honorary Degrees
FORENSICS TRAINING
-
What to say
-
How to take depo
MILITARY
Discharge:
Rank:
Date:
EMPLOYMENT BACKGROUND
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Employer:
-
Position:
-
Years:
-
Supervisor:
-
Why change job:
-
Previous employer:
-
Position:
-
Years:
-
Supervisor:
-
Why change job:
_________________________________________________________________
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Previous employer:
-
Position:
-
Years:
-
Supervisor:
-
Why change job:
_________________________________________________________________
-
Previous employer:
-
Position:
-
Years:
-
Supervisor:
-
Why change job:
_________________________________________________________________
-
Previous employer:
-
Position:
-
Years:
-
Supervisor:
-
Why change job:
_________________________________________________________________
-
Previous employer:
-
Position:
-
Years:
-
Supervisor:
-
Why change:
_________________________________________________________________
CURRENT EMPLOYER
When Employed:
Title:
Duties:
Responsibilities:
Supervisor:
Employees you supervise:
PREPARATION FOR DEPO
-
What documents:
-
What depositions:
-
What pleadings:
-
What testing:
-
What meetings:
-
What conferences w/atty:
-
What evidence reviewed:
-
What photos:
PROFESSIONAL MEMBERSHIPS
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Trade associations:
-
Officer
-
Committees
PRIOR DEPOS
-
-
When
-
Where
-
Court
-
Case name
-
Plaintiff
-
Defendant
-
Plaintiff’s attorney
-
Defendant’s attorney
-
Trial testimony
-
Allegations
-
Outcome
_________________________________________________________________
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When
-
Where
-
Court
-
Case name
-
Plaintiff
-
Defendant
-
Plaintiff’s attorney
-
Defendant’s attorney
-
Trial testimony
-
Allegations
-
Outcome
RELATIONSHIP OF CORPORATE ENTITIES
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Location of corp.
-
-
All offices.
-
Nerve center.
-
Home office.
-
Most activity.
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What is name of corporation
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Where does corporation do business
-
Where incorporated
-
When incorporated
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Are there any assumed name certificates filed
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If so, where are they filed
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Is the corporation known by any other names or d/b/a’s
I. Name all subsidiaries of the corporation
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Is corp or division/subsidiary of any other corp.
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Name all affiliated corps/companies/partnerships
L. Name major stockholders of the corp.
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Name all offices maintained by corp.
-
Name nature of business done by corp.
-
Do you contend we’ve sued wrong party
-
Do you contend we’ve sued wrong corp. name
CORP ASSETS
-
-
Gross income
-
Net profit
-
Major assets
-
Dividends
-
Inventory
CORPORATION’S OFFICERS
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Address, title, phone, duties
-
Shareholders and owners of corporation
RELATIONSHIP WITH OTHER CORPORATIONS
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Interlocking directorates
-
Common board member/directors
-
Common board stockholders
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Stock ownership by either corp.
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Common officers
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Common offices
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Common facilities
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Common employees
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Common income
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Tax status/tax treatment
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Any type of past affiliation
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Any type of present affiliation
DEPO DUCES TECUM
-
Go through documents produced
REVIEW ANSWERS TO INTERROGS
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Who answered
-
What basis
REVIEW ANSWERS TO ADMISSIONS
-
What grounds denied
PROFESSIONAL AFFILIATIONS
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Trade associations
-
Trade magazine subscriptions
-
Trade organizations
PRIOR LAWSUITS
-
All prior lawsuits threatened
-
All prior lawsuits filed
_________________________________________________________________
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Plaintiff
-
Defendant
-
City
-
Court
-
Cause No.
-
Other Defendants
-
Other Parties
-
Plaintiffs’ lawyer
-
Your lawyer
-
Allegations
-
Outcome
-
Terms of settlement
_________________________________________________________________
-
Plaintiff
-
Defendant
-
City
-
Court
-
Cause No.
-
Other Defendants
-
Other Parties
-
Plaintiffs’ lawyer
-
Your lawyer
-
Allegations
-
Outcome
-
Terms of settlement
_________________________________________________________________
-
Plaintiff
-
Defendant
-
City
-
Court
-
Cause No.
-
Other Defendants
-
Other Parties
-
Plaintiffs’ lawyer
-
Your lawyer
-
Allegations
-
Outcome
-
Terms of settlement
_________________________________________________________________
-
Plaintiff
-
Defendant
-
City
-
Court
-
Cause No.
-
Other Defendants
-
Other Parties
-
Plaintiffs’ lawyer
-
Your lawyer
-
Allegations
-
Outcome
-
Terms of settlement
_________________________________________________________________
PRIOR COMPLAINTS
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All oral complaints to you
-
All written complaints to you
-
All oral/written complaints to Contact 8/consumer watchdog.
-
Complaints to governmental entities/FTC/atty gen.
-
TCHR, EEOC, TEC
PIERCING QUESTIONS
PEOPLE WITH KNOWLEDGE
Most knowledge firing
Most knowledge job perform
Most knowledge employ procedures
Most knowledge prod
Most knowledge safety
Most knowledge about quality control
Most knowledge about investigation
Most knowledge of claim
LIABILITY ISSUES
-
Your company’s duties regarding product
-
How many produced
-
Where sold
-
To whom sold
PRODUCT IN QUESTION
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Des...
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