Maryland Accident Law Blog
Below is a sample document of Notice To Take Deposition Duces Tecum. We filed this on behalf of our client in circuit court. This notice indicates that an expert for the opposing side, in this case a physician, will be deposed by the personal injury law firm of Lebowitz and Mzhen in court. We included a list of documents that the deponent had to bring with him on the day of his deposition:
SCHEDULE OF DOCUMENTS:
1. All cases, by case name, court and case number, in which you have testified for a plaintiff at trial.
2. All cases, by case name, court and case number, in which you have testified for a defendant at trial.
3. All cases, by case name, court and case number, in which you have testified upon oral deposition for a plaintiff.
4. All cases, by case name, court and case number, in which you have testified upon oral deposition for a defendant.
5. All fees, by client, date and amount, which you have received for testifying at trial or deposition for any plaintiff.
6. All fees, by client, date and amount, which you have received for testifying at trial or deposition for any defendant.
7. All fees and cases, by client name, case name, court and case number, not listed in response to paragraphs 1-6 above in connection with which you have received any fee for consultation, advice or other services.
8. All reports, records, notes (handwritten and typed), correspondence, bills, diaries, and materials of any type prepared by you and all records, notes, medical records, correspondence, bills, diaries, legal pleadings, deposition transcripts and materials of any type reviewed by you relating to this case.
9. Your curriculum vitae.
10. All other documents not referred to above upon which you relied in preparing your report in this case.
Download NOTICE TO TAKE DEPOSITION DUCES TECUM document. The names of the deponent have been redacted for purposes of confidentiality.
Here are some benefits that depositions have over other forms of recovery:
1) A deposition allows an attorney to evaluate that person’s ability to be a witness in front of a jury.
2) An attorney gets a chance to pose follow-up questions based on the expert’s testimony.
3) The attorney has the advantage of surprise when questioning the expert from the opposing side.
For more information, contact Lebowitz and Mzhen by email or call 1-888-311-HURT.