Order Authorizing Deposition

CAUSE NO. __________

IN RE:

PETITION OF __________

(REQUESTING THE DEPOSITION OF:

_________ & OTHER

EMPLOYEES OF _________

MEDICAL CENTER)

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IN THE DISTRICT COURT

____ JUDICIAL DISTRICT

_________ COUNTY, TEXAS

ORDER AUTHORIZING DEPOSITIONS

On the ___ of [Month, Year], the Court heard the Petition of __________, requesting authority to take the deposition of three individuals associated with _________ Medical Center, to investigate a potential claim or suit.

It appearing to the Court that notice of this hearing has been duly and timely served on all parties entitled to notice, the Court considered the pleadings on file and heard the arguments of counsel. The Court finds the likely benefit of allowing the Petitioner to take the requested deposition(s) to investigate a potential claim outweighs the burden or expense of the procedure; the Court hereby grants authority for Petitioner to depose the witnesses.

IT IS THEREFORE ORDERED that Petitioner is authorized to take the deposition of:

(a) Nurse _________ (whose full name is known to _________ Medical Center), that was working at _________ Medical Center on or about [Date];

(b) ________, Vice President of Nursing Department, ________Medical Center; and

(c) The immediate supervisor of Nurse _________ (whose full name is known to _________Medical Center) who was working at _________ Medical Center on or about [Date].

At this point, depositions (b) and (c) referenced above will be limited to a length of one hour each on the record. Deposition (a) will be limited to a length of three hours on the record. If Petitioner reasonably believes that more time is necessary for any particular witness, Petitioner may notify the Court, and the Court will consider the request. If a lawsuit is later filed by Petitioner concerning her potential claims, any additional time for these depositions allowed under the Texas Rules of Civil Procedure will be reserved, and the deponents may be deposed at a later date on the merits of such lawsuit.

The depositions will occur confidentially at a location mutually agreeable to Petitioner’s counsel and counsel for _________ Medical Center. This location will be kept confidential to anyone not associated with this proceeding or counsel for the parties. The parties will work together in good faith for mutually agreeable times and dates for the depositions. However, they will...