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Petition Requesting Deposition Before Suit
CAUSE NO. _______________
IN RE:
__________
(REQUESTING THE DEPOSITION OF:
__________)
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IN THE DISTRICT COURT
_______ JUDICIAL DISTRICT
_______ COUNTY, TEXAS
VERIFIED PETITION REQUESTING DEPOSITION BEFORE SUIT
TO THE HONORABLE COURT:
Petitioner __________ (hereafter referred to as “Petitioner”) submits this Verified Petition, requesting authority to take the deposition of __________ (hereafter referred to as “Deponent”), as authorized by Texas Rule of Civil Procedure 202.
I.
Petitioner seeks to investigate potential claims and/or causes of action that he may have against Deponent and/or __________ Co. Petitioner also seeks to preserve testimony and anticipates a suit being filed in _______ County, Texas.
II.
Petitioner seeks to depose Deponent, __________, who may be served with notice at [address].
III.
Petitioner is an individual. Deponent, __________ is an individual. The substance of the testimony Petitioner expects to elicit from Deponent involves any actions and/or omissions with respect to potentially defamatory and/or actionable statements and/or publications made by Deponent concerning Petitioner, in _______ County and perhaps elsewhere. Petitioner wishes to examine the identities of persons and/or entities to whom Deponent may have made such statements and/or publications. Petitioner further expects to illicit testimony from Deponent concerning the circumstances of Petitioner’s termination and whether said termination was discriminatory or otherwise wrongful. Further, Petitioner expects to examine Deponent with regard to whether Petitioner’s termination was in any way related to Petitioner’s age. Deponent possesses unique and superior knowledge relevant to Petitioner’s potential claims and the statements and/or publications he has made.
IV.
In addition to Deponent, the __________ Co. may have an interest adverse to Petitioner in a potential suit. __________ Co. may be served with notice of this petition by serving its registered agent __________, at [address].
VI.
The benefit of allowing the deposition outweighs the burden or expense of the procedure because Petitioner does not yet know whether he should invest the time and resources to develop his claims and file a lawsuit against Deponent or others. Rule 202 provides this procedure for investigating claims in such a situation.
Although Petitioner is outraged by the actions and inactions...
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Request your trial- Appendices
- 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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